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

2 is merely an evidentiary rule that should be disregarded in discovery disputes has been routinely rejected in federal courts. See, e.g., Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996) (granting protective order pursuant to Rule 412 to prevent a sexual battery and harassment victim from having to disc

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]

vents discovery of Plaintiffs' sexual activities deal specifically with employer liability for workplace sexual harassment claims. See M-, Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996)(reasoning in a sexual harassment case, employer was entitled to Plaintiff's sexual history while on-duty but not her

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

restriction on discovery to preclude inquiry into areas which will clearly fail to satisfy the balancing test” set forth in Rule 412. See Barta v. City and County of Honolulu, 169 F.R.D. at 135. In Barta, the Court confronted this issue in the context of a discovery motion in a civil case. 169 F.R.D. at 133. A former

9, 2009. Respectfully submitted, By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245)

rejected in federal courts. See, e.g., Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996) (granting protect