DEFENDANT/COUNTER-CLAIM PLAINTIFF'S AMENDED MOTION FOR PROTECTIVE ORDER AS TO DISCOVERY ABUSE

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                          Filing # 137947846 E-Filed 11/04/2021 05:38:42 PM

IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT
IN AND FOR INDIAN RIVER COUNTY, FLORIDA

CASE NO.: 312019CA000232
LEAH M. BROOKS

f/k/a LEAH M. HUBBARD (CONSOLIDATED WITH CASE NO.:
Plaintiff, 312018CC1057)

LEAH M. BROOKS

f/k/a LEAH M. HUBBARD
Counter-Claim Defendant,

VS.

THE YATES LAW FIRM
E. CLAYTON YATES, P.A.
Defendants,

E. CLAYTON YATES P.A.
Counter-Claim Plaintiff.

DEFENDANT/COUNTER-CLAIM PLAINTIFF’S
AMENDED MOTION FOR PROTECTIVE ORDER
AS TO DISCOVERY ABUSE
Defendant and Counter-Claim Plaintiff herein, pursuant to Fla. R. Civ. P. 1.280 (c)
moves this Court for a discovery protective order and in support thereof cites the history of this
litigation as shown in various, select docket entries, which although not entirely related to the
discovery engaged in, reveal that Ms. Brooks f/k/a Hubbard is abusing the legal process,
proceeding in bad faith, and using this litigation for frivolous, malicious, and particularly in …