Epstein Secrets

One commentator has noted that once the identity of persons and similarity of circumstances are removed, “probative value all but disappears.” See Ordover, Admissibility of Patterns of Similar Sexual Conduct: The Unlamented Death of Character for Chastity, 63 Cornell L. Rev. 96, 106 (1977). The disc

STRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSO

moved, “probative value all but disappears.” See Ordover, Admissibility of Patterns of Similar Sexual Cond

__________________________________/ PLAINTIFFS JANE DOE NOS. 2-8’ MEMORANDUM IN RESPONSE TO DEFENDANT’S

One commentator has noted that once the identity of persons and similarity of circumstances are removed, "probative value all but disappears." See Ordover, Admissibility of Patterns of Similar Sexual Conduct: The Unlamented Death of Character for Chastity, 63 Cornell L. Rev. 96, 106 (1977). The discov

Interrogatory (# 18) seeking to unearth explicit information on every bit of possible sexual conduct and activity in chronological order which each Jane Doe might have engaged in since age 10, including the names and phone numbers of all persons with whom they had sexual contact.' Plaintiffs properly ob

. One commentator has noted that once the identity of persons and similarity of circumstances are removed, "probative value all but disappears." See Ordover, Admissibility of Patterns of Similar Sexual Conduct: The Unlamented Death of Character for Chastity, 63 Cornell L. Rev. 96, 106 (1977). The discov

quest #s 10, 11, 17 and 18) requests that seek to unearth all recordings and depictions of every instance of sexual conduct and activity which each Jane Doe might have engaged and documents evidencing the names and contact information of each sexual partner over the past nine years. Plaintiffs properly