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oeder v. John Hopkins Univ. Applied Physical Lab, 171 F.RD. 179 (D. Md. 1997) (looking at both Rule 26 and Rule 412 in resolving discovery motion); Sanchez v. Zabihi, 166 F.R.D. 500 (D. N.M. 1996) (explaining that “[a]lthough the present motion arises in the context of discovery under Rule 26, the Court
ed, it does not appear that an analogous argument was made in any of the state court cases relied upon by Defendant. Furthermore, the discovery in Balas v. Russo, 703 So.2d 1076 (Fla. 3d DCA 1997) was far narrower than that which is at issue here. It was limited to asking plaintiffs for their employ
roeder v. John Hopkins Univ. Applied Physical Lab, 171 F.RD. 179 (D. Md. 1997) (looking at both Rule 26 and Rule 412 in resolving discovery motion); Sanchez v. Zabihi, 166 F.R.D. 500 (D. N.M. 1996) (explaining that “[a]lthough the present motion arises in the context Case 9:08-cv-80119-KAM Document 93
eed, it does not appear that an analogous argument was made in any of the state court cases relied upon by Defendant. Furthermore, the discovery in Balas v. Russo, 703 So.2d 1076 (Fla. 3d DCA 1997) was far narrower than that which is at issue here. It was limited to asking plaintiffs for their emplo
Lion, Inc., 1999 WL 33226474 (M.D. Fla. Feb. 19, 1999); P.J. Herchenroeder v. John Hopkins Univ. Applied Physical Lab, 171 F.R.D. 179 (D. Mad. 1997); Sanchez v. Zabihi, 166 F.R.D. 500 (D. N.M. 1996); and Stalnaker v. Kmart Corp., 1996 WL 397563 (D. Kan 1996). Plaintiff’s reliance on these cases in support
ircumstances may be held to prevent mere discovery, is not applicable in this instance, where Plaintiff has placed her past sexual history at issue. Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5 DCA 1997), rev. th denied,719 So.2d 286 (Fla. 1998)(allowing discovery of plaintiff’s employment history which incl
oeder I. John Hopkins Univ. Applied Physical Lab, 171 F.RD. 179 (D. Md. 1997) (looking at both Rule 26 and Rule 412 in resolving discovery motion); Sanchez'. Zabihi, 166 F.R.D. 500 (D. N.M. 1996) (explaining that la]lthough the present motion arises in the context of discovery under Rule 26, the Court m
d 6 EFTA00222176 Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05)06:2009 Page 7 of 10 1077-78. At no time were the plaintiffs in Balas asked to disclose their entire sexually history beginning at age 10. Id. Thus, the three state court cases cited in the Motion are not helpful to t
Entities connected to both Sanchez and Balas

Jeffrey Epstein
PERSONJack Goldberger
PERSON
United States
LOCATION
Alan Dershowitz
PERSONJane Doe
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Kenneth Marra
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George W. Bush
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Bradley Edwards
PERSONSouthern District
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Scarlett Johansson
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United States District Court
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Sarah Kellen
PERSONRobert C. Josefsberg
PERSONEmmy Taylor
PERSONRobert D. Critton
PERSONFlorida Bar
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Supreme Court
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Oliver Stone
PERSONMichael J. Pike
PERSONScott Rothstein
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