Epstein Secrets

, 500 So. 2d 533, 536 (Fla. 1987). Orders compelling discovery constitute state action that may impinge on the constitutional right of privacy. See Berkeley, 699 So. 2d at 790. The court must balance the competing interests, privacy versus the need for discovery, that would be served by granting or deny

a discovery request is overly broad, burdensome or oppressive, by submitting evidence or offering evidence which reveals the nature of the burden." Coker v. Duke & Co., 1777 F.R.D. 682, 686 (M.D. Ala. 1998). Once the resisting party meets its burden, the burden shifts to the moving party to show the

As the district court itself found. "the plaintiffs have submitted significant proof that the landscape of the total work environment [".40] at the Berkeley plant was hostile towards African-Americans and that the defendants failed to take 'remedial action reasonably calculated to end the harassment."'

y the majority). This Court, too, has rejected anecdotal evidence of a similarly "damning character," this time in a racial discrimination case. See Coker v. Charleston Cnty. Sch. Dist., No. 92-1589, 1993 U.S. App. LEXIS 20836, 1993 WL 309580, at *6 (4th Cir. Aug. 16, 1993). We found that the plaintif

ucation Fall Conference, San Francisco, CA, October 21- 24, 1998. 98. Research and treatment with highly traumatized preschoolers. Wright Institute, Berkeley, Feb. 4, 2002. 12 EFTA00182872 Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 13 of 23 110. Presentations of v

McKinney's Sessions Laws of N.Y., a! 2211-2212 (quoted in Deborah S. v. Diorio, 153 Misc.2d 708, 583 N.Y.S.2d 872 (N.Y.City Civ.Ct.1992)); see also Coker'. Georgia, 433 U.S. 584, 597, 97 S.G. 2861, 53 L.Ed.2d 982 (1977) ("Short of homicide, [rape] is the ultimate violation of self'). As to the fourth