Epstein Secrets

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

e Radiator, Inc. v. Radiator Express Warehouse, 2008 WL 842989 (M.D. Fla. 2007)(protecting investigative materials as work-product); and Hickman v. Taylor, 329 U.S. 495, 508, 67 S.Ct. 385, 91 L.Ed. 451 (1947)(noting, among other things and subject to exception, that work-product includes information w

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

ry of admissible evidence. Rule 26(b)(l), Fed.R.Civ.P.; Donahay v. Palm Beach Tours & trans., Inc., 242 F.R.D. 685 (S.D. Fla. 2007). See Hickman v. Taylor, 329 U.S. 495, 507-08 (1947); Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 351 (1978). In Oppenheimer, the Supreme Court discussed the concept

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

e Radiator. Inc. v. Radiator Express Warehouse, 2008 WL 842989 (M.D. Fla. 2007)(protecting investigative materials as work-product); and Hickman v, Taylor, 329 U.S. 495, 508, 67 S.Ct. 385, 91 L.Ed. 451 (1947)(noting, among other things and subject to exception, that work-product includes information w