Epstein Secrets

ative explanation for why victim exhibited behavioral manifestations of sexually abused child.). 14. In further support of Defendant's motion, See Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), as it is on point to the discovery issues in this action, and

-polar disorder are more than simple allegations of emotional distress thus placing plaintiffs mental condition at issue). See also United States v. Bear Stops, 997 F.2d 451 (8th Cir. 1993)( dealing with "admissibility of other acts of sexual abuse by individuals Case 9:08-cv-80119-KAM Document 362 E

that the requested information is not relevant? 7. Next, despite Plaintiffs' strained interpretation and application of the discovery requests in Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), that case is instrumental in that, once again, we are at the "

complaints. See infra. b. Argument 5. The information sought above is relevant and discoverable even if not admissible at trial. United States v. Bear Stops, 997 F.2d 451 (8th Cir. 1993) deals with "admissibility of other acts of sexual abuse by individuals other than the defendant to explain why a victi

tive explanation for why victim exhibited behavioral manifestations of sexually abused child.). In further support of Defendant's motion, a copy of Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), is attached hereto as Exhibit A as it is on point to the disc

in her complaint, and whether she suffered injury and damages as a result of the other claimed sexual misconduct with males. See United States v. Bear Stops, 997 F.2d 451 (8th Cir. 1993)(Defendant charged with sexual abuse of six year old boy was entitled to admission of evidence relating to victim's se

Case 9:08-cv-80119-KAM Document 104 Entered on FLSD Docket 05/19/2009 Page 9 of 13 Page9 States v. Bear Stops. 997 F.2d 451 (8th Cir. 1993); Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998). The information sought in 4(e) is relevant and discoverable e

at same right in the instant matters. 8 Case 9:08-cv-80119-KAM Document 104 Entered on FLSD Docket 05/19/2009 Page 9 of 13 Page9 States v. Bear Stops. 997 F.2d 451 (8th Cir. 1993); Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998). The information sought in

levancy and discoverability of Plaintiffs history of sexual activity and any payment, therefore. See interrogatories 8, 22 and 30 propounded in the Balas case and footnote 1 herein. 1 Additionally and significantly, in other pending state court civil actions against Defendant EPSTEIN attempting to ass

lingly or not willingly engaged in sexual activity that has been photographed, or filmed by means of movie, dvd or videotapes. See United States v. Bear Stops, 997 F.2d 451 (8th Cir. 1993)(Defendant charged with sexual abuse of six year old boy was entitled to admission of evidence relating to victim's se

levancy and discoverability of Plaintiffs history of sexual activity and any payment, therefore. See interrogatories 8, 22 and 30 propounded in the Balas case and footnote 1 herein. 1 Additionally and significantly, in other pending state court civil actions against Defendant In Balas v. Ruzzo, supra,

d in her complaint, and whether she suffered injury and damages as a result of the other claimed sexual misconduct with males. See United States v. Bear Stops 997 F.2d 451 (8th Cir. 1993)(Defendant charged with sexual abuse of six year old boy was entitled to admission of evidence relating to victim's sex

bpoenas on medical doctors is a basic discovery need related to the claims alleged by JANE DOE for which Plaintiff's 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 Plaintiff's history of sexual activity is rel

A 1997), rev. denied, 719 So.2d 286 (Fla. 1998)(discoverability of Plaintiff's history of sexual activity is relevant to damages); United States v. Bear Stops 997 F.2d 451 (81h Cir. 1993)(deals with "admissibility of other acts of sexual abuse by individuals other than the defendant to explain why a victi