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of $506,847.78 for 5 years of sexual harassment and sexual touching was reasonable). Unfortunately, the parties were unable to reach a agreement. Myers clearly demonstrates that Epstein's offer to agree to a net worth in excess of $50,000,00 is reasonable in light of the allegations made by Jane Doe
offer to agree to a net worth in excess of $50,000,00 is reasonable in light of the allegations made by Jane Doe as compared to the allegations in Myers. Moreover, allowing such discovery at this juncture goes against the grain and the law in that Plaintiff has not made a reasonable showing establish
siness (e.g., physicians) wherein the records themselves have assumed public aspects which render them analogous to public documents. ,ate In re Dr. John Doe, 97 F.R.D. 640, 641- 643 (S.D.N.Y. 1982). Usually, these documents are known to more than the filer and the agency in which the document(s) were fil
kes it clear that there is a compelling need for any net worth discovery not protected by the Fifth Amendment privilege. 5 Defendant relies upon Myers v. Central Florida Investment, Inc., 592 F.3d 1201 (11th Cir. 2010) for its “stipulation” argument. In Myers, however, the district court heard tes
Myers, however, the district court heard testimony regarding each of the defendant’s net worth. There was no unilateral statement of net worth in Myers as Defendant wishes to create in the instant case. To the extent that Defendant relies upon the Court’s holding in Myers regarding the reasonablen
further appears to argue that the “required records” exception should be limited to “highly regulated business (e.g., physicians)”, citing In re Dr. John Doe, 97 F.R.D. 640, 641-643 (S.D.N.Y. 1982). In Dr. John Doe, however, the Court held contrary to Defendant’s assertion and consistent with the case l
ures. Such a stipulation more than satisfies any necessity for the disclosure of the tax returns or any additional net worth information. See e.g., Myers v. Central Florida Investments, Inc., 592 F.3d 1201 (I Ith Cir. 2010)(reasoning that a compensatory award of $103,622.09 and a punitive damage award
of $506,847.78 for 5 years of sexual harassment and sexual touching was reasonable). Unfortunately, the parties were unable to reach a agreement. Myers clearly demonstrates that Epstein's offer to agree to a net worth in excess of $50,000,00 is reasonable in light of the allegations made by Jane Doe
usiness (e.g., physicians) wherein the records themselves have assumed public aspects which render them analogous to public documents. See In re Dr. John Doe, 97 F.R.D. 640, 641- 643 (S.D.N.Y. 1982). Usually, these documents are known to more than the filer and the agency in which the document(s) were fil
Amendment privilege. 5 Defendant relies upon Myers v. Central Florida Investment, Inc., 592 F.3d 120
here was no unilateral statement of net worth in Myers as Defendant wishes to create in the instant case
ed business (e.g., physicians)”, citing In re Dr. John Doe, 97 F.R.D. 640, 641-643 (S.D.N.Y. 1982). In Dr.
oint of being incomplete" and ask this court to vacate it and remand the case for further consideration. In support of that request, they rely on Myers v. Gulf Oil Corpora- tion,' in which we held that a district court's explanation that the defendant should be granted summary judgment "be- cause t
D STATES of America, John N. Mitchell, Attorney General of the V. S., Frederick II. InceY, United States AtFy for the District of New Jersey, and John Doe, any Federal Law Enforce- ment Officer Joseph Caruano, Appellant In No. 18903 Charles Majurf, Appellant in No. 15904. Nos. 18003, 18904. United S
Entities connected to both Myers and John Doe

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Joe Biden
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
Michael Jackson
PERSON
Virginia Giuffre
PERSON
Julie K. Brown
PERSON
Tampa
LOCATION
Prince Andrew
PERSON
Donald Trump
PERSONLeon Black
PERSON
Mobile
LOCATION
Supreme Court
ORGANIZATION
Stephen Hawking
PERSON
Scarlett Johansson
PERSON
George Mitchell
PERSONMaria Farmer
PERSONWalton
PERSON