LEMONS, Justice.
In this appeal, we consider whether an anonymous litigant may utilize the coercive powers of Virginia courts under the Virginia Uniform Foreign Depositions Act, Code § 8.01-411 et seq. ("UFDA"). Pursuant to Rules 4:1(c) and 4:9(c), America Online, Inc. ("AOL") sought to quash a subpoena duces tecum issued to it by the Clerk of the Circuit Court of Fairfax County and sought a protective order barring the discovery sought by an anonymous...
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