IN THE CIRCUIT COURT OF THE FIRST JUDICIAL CIRCUIT IN AND FOR ESCAMBIA COUNTY, FLORIDA FAMILY DIVISION JACKIE

R. CAMERON Petitioner, vs. CHRISTINE S. CAMERON Respondent. ________________________________ RESPONDENTS PRO SE MOTION TO QUASH SUBPOENAS COMES NOW the Respondent, Christine S. Cameron, pro se, and, pursuant to Fl. Rules of Civ. P., submits this Motion to Quash Subpoenas for Production by a Non-Party and Motion for Protective Order and therefore states: GENERAL 1. Respondent objects and in no way consents to venue of this court for the Petition CASE NO: 2012-FY-1993

for Dissolution of Marriage filed by the Petitioner on May 23, 2012. 2. Although Respondent is an attorney (Florida Bar No: 528439 Christine Sue

Cook), Respondents license is or will be retired, she has no knowledge of Florida Family Law, she is a stay-at-home mother of an eight-month-old baby and, for the purposes of this motion, is acting as a lay person. FACTS 3. instant case. 4. On May 29, 2012, Respondent was served with a Summons and the Petition for On May 23, 2012, Petitioner filed the Petition for Dissolution of Marriage in the

Dissolution of Marriage.

5.

On June 12, 2012, Petitioner filed Notices of Production for Non-Parties for Ben-

Ezra and Katz, PA, The Law Office of Marshall Watson, and Patrick McCaghren. 6. Respondent had twenty (20) days within which to file a response to the Summons

and Petition for Dissolution of Marriage, which time expired on June 18, 2012. 7. Chris Ragano, Esq., on behalf of Respondent, filed a Notice of Limited

Appearance on June 15, 2012, and later filed a Motion to Transfer Venue on June 25, 2012. The hearing for the Motion to Transfer Venue is scheduled before this Honorable Court on August 7, 2012. 8. Respondent has not yet retained an attorney to represent her for the substantive

matter and, because venue may be decided to be proper in Fort Lauderdale, Broward County, Florida, she is unable to engage proper counsel until venue is decided. 9. The case was not at issue when Petitioner filed his Notice of Production from a

Non-Party and therefore, the discovery process had not yet commenced. 10. Petitioner is a skilled attorney who frequently practices Florida Family Law in the

First Circuit, Escambia and Santa Rosa Counties, Florida. 11. Petitioners continual filing of substantive motions and notices before venue has

been decided is aimed to intimidate, embarrass, annoy, oppress and harass Respondent. 12. Respondent would be severely prejudiced were Petitioner able to subpoena and

use the records of non-parties simply because Respondent had not yet retained counsel for substantive matters in this case. 13. On June 16, 2012, Respondent filed her pro se Motion for Stay of Proceedings

until venue is decided. WHEREFORE, Respondent, Christine S. Cameron, pro se, respectfully requests this

Honorable Court grant this motion and order the subpoenas issued to Ben-Ezra & Katz, The Law Office of Marshall Watson and Patrick McCaghren quashed. I HEREBY CERTIFY that a copy of the foregoing was furnished to Jackie R. Cameron, Petitioner, via email jrod@jrodcameron.com this _____ day of July 2012. CHRISTINE S. CAMERON 1177 N.W. 171 Terrace Pembroke Pines, FL 33028 (850) 572-7159 ________________________ Christine S. Cameron, pro se