Epstein Secrets

opportunity. Lingle v. Dion, 776 So.2d 1073 (Fla. 41h DCA 2001). The Florida Constitution establishes the right commonly known as access to courts. Mitchell v. Moore, 786 So.2d 521 (Fla. EFTA00221216 Case 9:08-cv-80993-KAM Document 52 Entered on FLSD Docket 05/07/2009 Page 8 of 12 2001). Courts sha

ubpoenas on medical doctors is a basic discovery need related to the claims alleged by JANE DOE for which Plaintiffs 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 Plaintiffs history of sexual activity is relevant to

lie to the police, don't you? 20 A. No. 21 Q. Well, you lied to the police in your 22 tape-recorded statement that you gave to Detective 23 Michelle Pagan three years ago, didn't you? 24 A. To my knowledge, no, I did not. 25 Q. Well, you lied to the police when you Ph. 561.682.0905 - Fax. 5

sake of the defendant, but because [the courts] will not lend their aid to such a plaintiff" (quoting Holman, 98 Eng. Rep. 1120)) (emphasis added); Balas v. Ruzzo, 703 So. 2d 1076, 1082 (Fla. 5th DCA 1997) (Harris, J., concurring) (remarking in the context of an action brought against an alleged prostitution

lie to the police, don't you? 20 A. No. 21 Q. Well, you lied to the police in your 22 tape-recorded statement that you gave to Detective 23 Michelle Pagan three years ago, didn't you? 24 A. To my knowledge, no, I did not. 25 Q. Well, you lied to the police when you Ph. 561.682.0905 - Fax. 5

sake of the defendant, but because [the courts] will not lend their aid to such a plaintiff" (quoting Holman, 98 Eng. Rep. 1120)) (emphasis added); Balas v. Ruzzo, 703 So. 2d 1076, 1082 (Fla. 5th DCA 1997) (Harris, J., concurring) (remarking in the context of an action brought against an alleged prostitution