Epstein Secrets

inst such claims by the mo direct and traditional of metlmd,, Le., proof ilifil rnch drum, = Smpfy oot true. Id. l ----'-'""----4------- R ob e rt D. Critton, Jr. Attorney for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the C

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

E LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] /s/ Adam D. Horowitz Case 9:08-cv-80119-KAM Document 93 Entered on FLSD

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

E LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] /s/ Adam D. Horowitz 10 Case 9:08-cv-80119-KAM Document 94 Entered on F

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

Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Bradley James E

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