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t "B") dated October 26, 2007 in which she told a doctor: (a) she was sexually molested at age 13 by her friend's brother; and (b) raped at age 15. Jane Doe 3 did not claim to see Epstein until age 16. In light of the foregoing, can Plaintiffs' counsel legitimately assert to this court that the requested
requested information is not relevant? 7. Next, despite Plaintiffs' strained interpretation and application of the discovery requests in Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), that case is instrumental in that, once again, we are at the "discovery
action based on the same operative allegations), Jane Doe #3 v. Epstein, No. 08-CV-80232-KAM (S.D. Fla. filed
e, prostitutes who sued a house of prostitution (as an "enterprise") for inflicting systematic and repetitive abuse on them, over time. See Baku v. Ruzzo, 703 So. 2d 1076, 1077 (Fla. 5th DCA 1997) (offering an example of a civil RICO claim against the operators of an alleged "house of prostitution,"
action based on the same operative allegations), Jane Doe #3 v. Epstein, No. 08-CV-80232-KAM (S.D. Fla. filed
, prostitutes who sued a house of prostitution (as an "enterprise") for inflicting systematic and repetitive abuse on them, over time. See Bala: v. Ruzzo, 703 So. 2d 1076, 1077 (Fla. 5th DCA 1997) (offering an example of a civil RICO claim against the operators of an alleged "house of prostitution,"
Entities connected to both Virginia Giuffre and Ruzzo

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
New York
LOCATIONthe Southern District
LOCATION
Marc Rich
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSON
George Mitchell
PERSONEmmy Taylor
PERSON
Samantha Power
PERSON
Bill Richardson
PERSON
South
LOCATIONJack Goldberger
PERSON
Michael Douglas
PERSON
Abraham Lincoln
PERSON
Sarah Kellen
PERSON
Naomi Campbell
PERSON
the United States District Court
ORGANIZATION