Epstein Secrets

e, Overrule Objections, and for an Award of Reasonable Expenses be denied in their entirety. Dated: May 6, 2009 Respectfully submitted, By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) ahorowitz@sexabuseattor

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

fendant Jeffrey Epstein) Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mennelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 [email protected]

ative explanation for why victim exhibited behavioral manifestations of sexually abused child.). 14. In further support of Defendant's motion, See Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), as it is on point to the discovery issues in this action, and

ounsel of record identified on the following Service List in the manner specified by CM/ECF on this$ day of May, 2009: Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 [email protected]

that the requested information is not relevant? 7. Next, despite Plaintiffs' strained interpretation and application of the discovery requests in Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), that case is instrumental in that, once again, we are at the "

l of recor_!:J,Jdentified on the following Service List in the manner specified by CM/ECF on thi6Z~day of April, 2009: Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 [email protected]

tive explanation for why victim exhibited behavioral manifestations of sexually abused child.). In further support of Defendant's motion, a copy of Balas v. Ruzzo, 703 So.2d 1076 {Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), is attached hereto as Exhibit A as it is on point to the disc

Interrogatories and for an Award of Reasonable Expenses be denied in their entirety. Dated: May 6, 2009 Respectfully submitted, By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERME

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

sel of recoWJ,dentified on the following Service List in the manner specified by CM/ECF on thisc1_~ay of April , 2009: Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 [email protected]

tive explanation for why victim exhibited behavioral manifestations of sexually abused child.). In further support of Defendant's motion, a copy of Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), is attached hereto as Exhibit A as it is on point to the disc

unsel of re rd *dentified on the following Service List in the manner specified by CM/ECF on thi day of April, 2009: Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. Counsel for Plaintiff Jane Doe #1 Jack Alan Goldberger Atterbury Goldberger & Weiss. P.A. Co-Counsel for Defe

levancy and discoverability of Plaintiffs history of sexual activity and any payment, therefore. See interrogatories 8, 22 and 30 propounded in the Balas case and footnote 1 herein. 1 Additionally and significantly, in other pending state court civil actions against Defendant EPSTEIN attempting to ass

l of recorpdentified on the following Service List in the manner specified by CM/ECF on thisa_n-day of April , 2009: Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger

levancy and discoverability of Plaintiffs history of sexual activity and any payment, therefore. See interrogatories 8, 22 and 30 propounded in the Balas case and footnote 1 herein. 1 Additionally and significantly, in other pending state court civil actions against Defendant In Balas v. Ruzzo, supra,

uce, Overrule Objections, and for an Award of Reasonable Expenses be denied in their entirety. Dated: May 6, 2009 Respectfully submitted, By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERMELSTEI

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

d by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing. /s/ Adam D. Horowitz -7- EFTA00175230 Case 9:08-cv-80993-KAM Document 86 Entered on FLSD Docket 06/10/2009 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DIST

bpoenas on medical doctors is a basic discovery need related to the claims alleged by JANE DOE for which Plaintiff's counsel refuses to compromise. Balas v. Ruzzo 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998)(discoverability of Plaintiff's history of sexual activity is rel