Epstein Secrets

Page 9 of 11 if the plaintiff has a substantial privacy interest that outweighs the presumption of openness in judicial proceedings. Id., citing, Doe v. Frank, 951 F.2d 320, 323 (11th Cir. 1992)(requiring complaint to include the names of the parties serves more than administrative convenience, it protects

o eliminate the likelihood of surprise and to insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 1.280(b)(1); see also Surf Drugs, Inc., v. Vermette, 236 So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their

g the legitimate interests of either party. 6 EFTA00221215 Case 9:08-cv-80993-KAM Document 52 Entered on FLSD Docket 05/07/2009 Page 7 of 12 Doe v. Frank, 951 F.2d at 323. Plaintiff does not fall under any of the factors. Moreover, even if she did meet one of the factors, "[t]he fact that [a] Doe [Pl

o eliminate the likelihood of surprise and to insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 1.280(b)(1); see also Surf Drugs, Inc., v. Vermette, 236 So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their

6 of 11 decide if the plaintiff has a substantial privacy interest that outweighs the presumption of openness in judicial proceedings. Id., citing, Doe v. Frank, 951 F.2d 320, 323 (11" Cir. 1992)(requiring complaint to include the names of the parties serves more than administrative convenience, it protects

o eliminate the likelihood of surprise and to insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 1.280(b)(1). see also Surf Drugs, Inc., v. Vermette 236 So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their