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have experienced several incidents in their lives which affected them emotionally and psychologically. See M•, Exhibits "C" and "D", Affidavits of Richard C.W. Hall, outlining the psychological issues experienced by Jane Does 4 and 6 as a result of incidents in their lives prior to Epstein, which cannot be disc
d whether there was any history of indiscriminate behavior that may have placed them at increased risk .... " Id. It is also important to know about Plaintffs' " ... previous sexual conduct, contact with police or welfare agencies, alcohol or drug use/abuse, voluntary sexual activity, contraceptive use, g
laintiffs have experienced several incidents in their lives which affected them emotionally and psychologically. See ~-, Exhibit "D", Affidavit of Richard C.W. Hall, outlining the psychological issues experienced by Jane Doe 4 as a result of incidents in her life prior to Epstein, which cannot be discounted. As
whether there was any history of indiscriminate behavior that may have placed them at increased risk .... " Id. It is also important to know about Plaintffs' " ... previous sexual conduct, contact with police or welfare agencies, alcohol or drug use/abuse, voluntary sexual activity, contraceptive use, g
have experienced several incidents in their lives which affected them emotionally and psychologically. See g., Exhibits "C" and "D", Affidavits of Richard C.W. Hall, outlining the psychological issues experienced by Jane Does 4 and 6 as a result of incidents in their lives prior to Epstein, which cannot be disc
alt all traditional investigatory methods which may lead to evidence that may diminish or disprove their claims and/or evidence that may prove that Plaintffs have made inconsistent statements relative to their allegations. 6. As this court is well aware, utilizing investigators prior to and during a la
Entities connected to both Richard C.W. Hall and Plaintffs

Jeffrey Epstein
PERSONJane Doe
PERSONIsidro Manuel Garcia
PERSON
Paul Cassell
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Salt Lake City
LOCATION
Adam D. Horowitz
PERSONMermelstein & Horowitz
ORGANIZATIONJack Patrick Hill
PERSONKatherine W. Ezell
PERSONRichard Horace Willits
PERSONAtterbury Goldberger & Weiss
ORGANIZATIONScott Rothstein
PERSONRobert C. Josefsberg
PERSONTheodore J. Leopold
PERSON
Marc Rich
PERSON
Palm Beach Gardens
LOCATIONJack Scarola
PERSONSpencer Kuvin
PERSON