UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

LUIS GARCIA SAZ, and wife, MARIA DEL ROCIO GARCIA, Plaintiffs, vs. CHURCH OF SCIENTOLOGY RELIGIOUS TRUST; U.S. lAS MEMBERS TRUST; CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC. ; CHURCH OF SCIENTOLOGY FLAG SHIP SERVICE ORGANIZATION, INC. d/b/a Majestic Cruise Lines; and DAVID MISCA VIGE, Defendants.

Case No. 8:13-CV-220-T27 TBM

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PLAINTIFFS' OMNIBUS OBJECTION TO THE SWEEPING DOCUMENT PRODUCTION SOUGHT BY EXHIBIT A TO DEFENDANTS' FLAG AND SHIP SUBPOENAS DUCES TECUM

Plaintiffs, Luis A. Garcia Saz and Maria del Rocio Garcia, hereby object to the production of documents requested in multiple subpoenas duces tecum (the "Subpoenas") issued by Defendants Church of Scientology Flag Service Organization, Inc. and Church of Scientology Flag Ship Service Organization, Inc. ("Defendants"). The document requests issued by

Defendants, as set forth in Exhibit A to the Subpoenas, are identical, and impermissibly seek the sweeping production of documents by (i) the separate law firms representing Plaintiffs, (ii) individual counsel within those law firms ; and (iii) non-party Michael Rinder. Because the document requests are patently overbroad and unduly burdensome, Plaintiffs object, on their own

behalves and on behalf of each of the recipients of the Subpoenas, to the production sought by the Subpoenas.' (True and correct copies ofthe Subpoenas are attached as Composite Exhibit A.) Defendants purport to serve the Subpoenas in order to obtain discovery relating to its motion to disqualify all three law firms representing Plaintiffs in this action. The motion to disqualify is premised on the contention that the law firms of Babbitt Johnson Osborne & LeClainche and Weil Quaranta McGovern received confidential information from Gray Robinson's representation of Defendants over ten years ago. Yet Defendants' motion is now being used in an attempt to discover every communication among counsel relating to this suit for fraud against the Church of Scientology Defendants, including all communications with nonparty individuals named in these subpoenas. The document requests - catching in their net irrelevant and privileged communications among attorneys and their clients and their legal consultants- are indefensibly overbroad. As a preliminary matter, before permitting discovery, the Court should determine whether a conflict of interest even exists as a result of Mr. Johnson's past representation of FSO under Rule 4-1.9. This is particularly compelling in this case as Defendants do not allege that Mr. Johnson (i) ever represented Defendants in connection with this fraud suit by the Garcias, (ii) knew of the Garcias when he represented FSO over ten years ago, or (iii) has any confidential information about this case. Rather, Defendants allege that Mr. Johnson's past representation of Defendants on general matters, somehow, makes this case substantially related prior representation. Before requiring Plaintiffs to file a privilege log detailing all privileged

FSO has served the Subpoenas on the separate law firms of Gray Robinson, P.A., Babbitt, Johnson, Osborne & Le Clainche, P.A., and Weil Quaranta McGovern, P.A. FSO also served the Subpoenas on the individual attorneys within those separate firms, namely, Robert Johnson, Richard Zabak , Theodore Babbitt, and Ron Weil. FSO also served the Subpoenas on non-party Michael Rinder.
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communications, the Court should make that preliminary determination. If, in fact, no conflict exists, communications among the individuals subpoenaed are not only irrelevant and/or protected from discovery pursuant to the doctrines of work-product and attorney-client privilege, but the efforts required by Plaintiffs and their counsel which Defendants seek to trigger by the Subpoenas are unnecessary and, as such, burdensome and harassing.

Dated: July 12, 2013 Respectfully submitted, s/ Theodore Babbitt Theodore Babbitt, Esq. Florida Bar No: 091146 Babbitt Johnson Osborne & LeClainche, P.A. 1641 Worthington Road, Suite 100 West Palm Beach, FL 33409 T: 561-684-2500 F: 561-684-6308 tedbabbitt@babbitt-johnson.com

-andRonald P. Weil, Esq. Florida Bar No: 169966 Amanda M. McGovern Florida Bar No: 964263 Weil Quaranta McGovern, P .A. Southeast Financial Center, Suite 900 200 South Biscayne Blvd. Miami, FL 33131 T: 305-372-5352 F: 305-372-5355 RPW @weillaw.net amcgovern@weillaw.net

Counsel for Plaintiffs Luis A. Garcia Saz and Maria Del Rocio Burgos Garcia

CERTIFICATE OF SERVICE
We hereby certify that, on July 12, 2013 , we electronically filed the foregoing document with the Clerk of the Court using CM/ECF. We also certify that the foregoing document is being served this day on all counsel or pro se parties identified below in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filings.

F. Wallace Pope, Jr. , Esq. FBN 124449 Johnson Pope Bokor Ruppel &Bums, LLP P.o. Box 1368 Clearwater, FL 33757 Phone: (727) 461-1818 Fax: (727) 462-0365 E-mail: wallyp@ipfirm.com Counsel for Defendants

Nathan M. Berman, Esq. FBN 329230 E-mail: nberman@zuckerman.com Lee Fugate, Esq. FBN 170928 E-mail: lfugate@zuckerman.com Jack E. Fernandez, Esq. FBN 843751 E-mail: jfernandez@zuckerman.com Mamie V. Wise, Esq. FBN 65570 E-mail: mwise@zuckerman.com Zuckerman Spaeder, LLP 101 E. Kennedy Blvd., Suite 1200 Tampa, FL 33602 Phone: (813) 221-1010 Fax: (813) 223-7961 Counsel for Church of Scientology Religious Trust

Marie Tomassi, Esq. FBN 772062 Trenam Kember Scharf Barkin Frye O'Neill & Mullis, P.A. Bank of America Building 200 Central A venue, Suite 1600 St. Petersburg, FL 33701 Phone: (727) 820-3952 Fax: (727) 820-3972 E-mail: mtomassi@trenam.com Counsel for lAS Administrations, Inc. And U.S . lAS Members Trust