Epstein Secrets

76, and that was a decision of the Fifth District Court of Appeal, and I will quote headnote 3, "had the Petitioners brought their lawsuit against Ruzzo and the Board Room only under Section 769.09, evidence of Petitioner's past prostitution 8 including with the Board Room and their earnings 9 r

ourt they sit, is going to be entitled to a fair shake and a fair trial and entitled to the EFTA00776411 47 1 2 3 4 5 6 7 the Ballast vs. Ruzzo case. For the record, the citation is 703 So.2d. 1076, and that was a decision of the Fifth District Court of Appeal, and I will quote headnote 3,

CRITTON: No. 11 THE COURT: Hold on. 12 MR. BERGER: We have three clients. One 13 is in federal court, Jane Doe. Mr. Critton 14 wants to take Jane Doe's deposition in these two 15 cases, and III., so she's in front of you 16 as a nonparty on a motion for protective order. 17 THE COURT: I see, b

atement 2 or in her - she says, "I brought over 50 girls 3 there." brought girls and she was there on 4 multiple, tens upon tens of occasions. Jane Doe 5 was there on multiple occasions. 6 It's important to know these young ladies' 7 prior sexual history, whether it's consensual, 8 whether it's

lanation 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 the rele

0381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 I Defendant, Jeffrey Epstein's Reply to Plaintiff, Jane Doe 2-8, Response In Opposition To Defendant's Motions For Independent Examination Of Plaintiffs, With Incorporated Memorandnm Of Law Defendant, JEFFR

anation 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 discovery iss

0119-MARRA.JOHNSON JANE DOE NO. 2 Plaintiff, V. JEFFREY EPSTEIN, Defendant. ----------------'' DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, TO RESPOND TO DEFENDANT'S FIRST REQUEST TO PRODUCE & TO OVERRULE OBJECTIONS, & FOR AN AWARD OF DEFENDANT'S REASONABLE EXPENSES Defendant,

n 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. 8 Case 9:08-cv-80119-KAM Document 91 Entered on FLSD Docket 05/05/2009

CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, V. JEFFREY EPSTEIN, Defendant. I ------------- MOTION TO COMPEL AND/OR IDENTIFY JANE DOE IN THE STYLE OF THIS CASE AND MOTION TO IDENTIFY JANE DOE IN THIRD-PARTY SUBPOENAS FOR PURPOSES OF DISCOVERY, OR ALTERNATIVELY, MOTION TO DISMISS

anation 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 discovery iss

ANT'S REASONABLE EXPENSES Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, moves this Court for an order compelling Plaintiff, JANE DOE No. 2 to answer Defendant's First Set of Interrogatories and to overrule her objections asserted in Plaintiff's Answers To Defendant's First Interr

ces 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 included pros

________________________/ OMNIBUS ORDER THIS CAUSE is before the Court on the following motions: (1) Defendant Epstein’s Motion to Compel Plaintiff Jane Doe 2 to Respond to Defendant’s First Request to Produce and to Overrule Objections and For an Award of Defendant’s Reasonable Expenses (D.E. #67); and (

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 even if no

t. ---------~' JANE DOE NO. 7, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ---------~' C.M.A., Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, et al., Defendants. CASE NO.; 08-CV-80994-MARRA/JOHNSON CASE NO.; 08-CV-80993-MARRA/JOHNSON CASE NO.; 08-CV-8

e, prostitutes who sued a house of prostitution (as an "enterprise") for inflicting systematic and repetitive abuse on them, over time. See Baku v. Ruzzo, 703 So. 2d 1076, 1077 (Fla. 5th DCA 1997) (offering an example of a civil RICO claim against the operators of an alleged "house of prostitution,"

eorgia before a Georgia notary), DE 4-2, Jane Doe No. I v. Epstein, Case No. 08- 80069-Civ-Marra (1/29/08); Intervenor's Complaint, at ¶ 2 (filed by "Jane Doe's Mother" and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."). DE 5-2, Jane Doe No. I v. Epstein, Case No. 08-80

, prostitutes who sued a house of prostitution (as an "enterprise") for inflicting systematic and repetitive abuse on them, over time. See Bala: v. Ruzzo, 703 So. 2d 1076, 1077 (Fla. 5th DCA 1997) (offering an example of a civil RICO claim against the operators of an alleged "house of prostitution,"

eorgia before a Georgia notary), DE 4-2, Jane Doe No. 1 v. Epstein, Case No. 08- 80069-Civ-Marra (1/29/08); Intervenor's Complaint, at ¶ 2 (filed by "Jane Doe's Mother" and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."), I)E 5-2, Jane Doe No. I v. Epstein, Case No. 08-8