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ot only the admissibility of evidence at trial, but must also “inform the discovery process.” Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996). The Committee Notes state, in relevant part, as follows: Courts should presumptively issue protective orders barring discovery unless the
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
ot only the admissibility of evidence at trial, but must also “inform the discovery process.” Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996). The 3 Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 3 of 10 Committee Notes state, in relevant part, a
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
a v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996) (granting protective order pursuant to Rul
rejected in federal courts. See, e.g., Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996) (granting protect
Entities connected to both D. Haw. and City and County of Honolulu

Jeffrey Epstein
PERSONJack Goldberger
PERSONJane Doe
PERSONHerron
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PERSONStuart S. Mermelstein
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Adam D. Horowitz
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Oliver Stone
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LOCATIONP.J. Herchenroeder
PERSONMermelstein & Horowitz
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