Epstein Secrets

ed, it does not appear that an analogous argument was made in any of the state court cases relied upon by Defendant. Furthermore, the discovery in Balas v. Russo, 703 So.2d 1076 (Fla. 3d DCA 1997) was far narrower than that which is at issue here. It was limited to asking plaintiffs for their employ

to prevent a sexual battery and harassment victim from having to disclose off-duty sexual contacts with persons other than defendant in discovery); Herron v. Eastern 4 Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 4 of 10 Industries, Inc., 2007 WL 2781211 (N.D. Fla

eed, it does not appear that an analogous argument was made in any of the state court cases relied upon by Defendant. Furthermore, the discovery in Balas v. Russo, 703 So.2d 1076 (Fla. 3d DCA 1997) was far narrower than that which is at issue here. It was limited to asking plaintiffs for their emplo

to prevent a sexual battery and harassment victim from having to disclose off-duty sexual contacts with persons other than defendant in discovery); Herron v. Eastern Industries, Inc., 2007 WL 2781211 (N.D. Fla. Sept. 19, 2007); Gibbons v. Food Lion, Inc., 1999 WL 33226474 (M.D. Fla. Feb. 19, 1999); P.

ircumstances may be held to prevent mere discovery, is not applicable in this instance, where Plaintiff has placed her past sexual history at issue. Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5 DCA 1997), rev. th denied,719 So.2d 286 (Fla. 1998)(allowing discovery of plaintiff’s employment history which incl

f’s sexual activities, Plaintiff cites to a string of employment related cases, Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996); Herron v. Eastern Industries, Inc., 2007 WL 2781211 (N.D. Fla. Sept. 19, 2007); Gibbons v. Food Lion, Inc., 1999 WL 33226474 (M.D. Fla. Feb. 19, 1999); P.J.

ording of the conduct which was the subject of the complaint, and a description of her damages. 703 So.2d 1077-78. At no time were the plaintiffs in Balas asked to disclose their entire sexually history beginning at age 10. Id. Thus, the three state court cases cited in the Motion are not helpful to t

to prevent a sexual battery and harassment victim from having to disclose off-duty sexual contacts with persons other than defendant in discovery); Herron,. Eastern Industries. Inc. 2007 WL 2781211 (N.D. Fla. Sept. 19, 2007); Gibbons'. Food Lion Inc. 1999 WL 33226474 (M.D. Fla. Feb. 19, 1999); P.J. He

d 6 EFTA00222176 Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05)06:2009 Page 7 of 10 1077-78. At no time were the plaintiffs in Balas asked to disclose their entire sexually history beginning at age 10. Id. Thus, the three state court cases cited in the Motion are not helpful to t

to prevent a sexual battery and harassment victim from having to disclose off-duty sexual contacts with persons other than defendant in discovery); Herron Eastern 4 EFTA00222174 Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 5 of 10 Industries. Inc. 2007 WL 2781211 (N