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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
one of the individuals apparently interviewed by Epstein's investigators; however, Plaintiff does not state that the investigators have identified Jane Doe 7 as a Plaintiff in this lawsuit. Defendant expects that in light of this court's recent order (DE 253) that Plaintiff will speciously amend her decla
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
fected 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 such, Plaintiffs should not, once again, be able to "handpic
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
N Defendant. Plaintiff. JEFFREY EPSTEIN Defendant. CASE NO.: 08-80993-CIV-MARRA/JOHNSON CASE NO.: 08-80811-CIV-MARRA/JOHNSON 2 EFTA00729245 JANE DOE, Plaintiff, JEFFREY EPSTEIN et al, Defendants. CASE NO.: 08-80893-C1V-MARRA/JOHNSON DOE II, Plaintiff, JEFFREY EPSTEIN et al, Defendants. CA
Entities connected to both Plaintffs and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Adam D. Horowitz
PERSON
Salt Lake City
LOCATIONScott Rothstein
PERSONRobert C. Josefsberg
PERSONJack Scarola
PERSONKatherine W. Ezell
PERSONRichard Horace Willits
PERSONJack Patrick Hill
PERSONIsidro Manuel Garcia
PERSONMermelstein & Horowitz
ORGANIZATIONAtterbury Goldberger & Weiss
ORGANIZATIONBruce E. Reinhart
PERSONSpencer Kuvin
PERSON
Lake Worth
LOCATION
Marc Rich
PERSON
Palm Beach Gardens
LOCATION