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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
conduct or predisposition in civil cases, which will be continued to be governed by Fed. R. Civ. P. 26. In order not to undermine the rationale of Rule 412, however, courts should enter appropriate orders pursuant to Fed. R. Civ. P. 26 (c) to protect the victim against unwarranted inquiries and to ensu
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,
conduct or predisposition in civil cases, which will be continued to be governed by Fed. R. Civ. P. 26. In order not to undermine the rationale of Rule 412, however, courts should enter appropriate orders pursuant to Fed. R. Civ. P. 26 (c) to protect the victim against unwarranted inquiries and to ensu
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
urt "must impose certain restriction on discovery to preclude inquiry into areas which will clearly fail to satisfy the balancing test" set forth in Rule 412. See Barta I. 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 c
Entities connected to both Balas and Rule 412

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSONStuart S. Mermelstein
PERSON
Adam D. Horowitz
PERSON
Alan Dershowitz
PERSONRobert D. Critton
PERSONAtterbury Goldberger & Weiss
ORGANIZATION
Sarah Kellen
PERSONMichael J. Pike
PERSONBear Stops
ORGANIZATIONMermelstein & Horowitz
ORGANIZATIONMcGregor Electronic Industries, Inc.
ORGANIZATIONSouthern District
LOCATION
Scarlett Johansson
PERSONDonahay
PERSON
United States
LOCATION
Bradley Edwards
PERSONJANE DOE NO.
PERSON