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TES MAGISTRATE JUDGE CC: The Honorable Kenneth A. Marra All Counsel of Record Case 9:08-cv-80119-KAM Do
UNITED STATES MAGISTRATE JUDGE CC: The Honorable Kenneth A. Marra All Counsel of Record Case 9:08-cv-80119-KAM Do
ircumstances may be held to prevent mere discovery, is not applicable in this instance, where Plaintiff has placed her past sexual history at issue. Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5 DCA 1997), rev. th denied,719 So.2d 286 (Fla. 1998)(allowing discovery of plaintiff’s employment history which incl
ions to Epstein's Motion to Compel and/or Identify. This Notice should only be filed in 08-80119, not in all of the Epstein cases.. Signed by Judge Kenneth A. Marra on 5/20/2009. Associated Cases: 9:08-cv-80119-KAM et al. (1c3) (Entered: 05/20/2009) 05/22/2009 15 Clerks Notice of Docket Correction and Instruc
No. 102 v. Epstein Assigned to: Judge Kenneth A. Marra Lead case: 9:08-cv-80119-KAM Member case: (View
bpoenas on medical doctors is a basic discovery need related to the claims alleged by JANE DOE for which Plaintiff's counsel refuses to compromise. Balas v. Ruzzo 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998)(discoverability of Plaintiff's history of sexual activity is rel
UTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY
levancy and discoverability of Plaintiffs history of sexual activity and any payment, therefore. See interrogatories 8, 22 and 30 propounded in the Balas case and footnote 1 herein. 1 Additionally and significantly, in other pending state court civil actions against Defendant EPSTEIN attempting to ass
UTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY
levancy and discoverability of Plaintiffs history of sexual activity and any payment, therefore. See interrogatories 8, 22 and 30 propounded in the Balas case and footnote 1 herein. 1 Additionally and significantly, in other pending state court civil actions against Defendant In Balas v. Ruzzo, supra,
F FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defen
ording of the conduct which was the subject of the complaint, and a description of her damages. 703 So.2d 1077-78. At no time were the plaintiffs in Balas asked to disclose their entire sexually history beginning at age 10. Id. Thus, the three state court cases cited in the Motion are not helpful to t
F FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defen
d 6 EFTA00222176 Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05)06:2009 Page 7 of 10 1077-78. At no time were the plaintiffs in Balas asked to disclose their entire sexually history beginning at age 10. Id. Thus, the three state court cases cited in the Motion are not helpful to t
Entities connected to both Kenneth Marra and Balas

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
George W. Bush
PERSONSouthern District
LOCATIONRobert D. Critton
PERSONRobert C. Josefsberg
PERSONMichael J. Pike
PERSON
Adam D. Horowitz
PERSONScott Rothstein
PERSON
Sarah Kellen
PERSON
United States District Court
ORGANIZATIONJack Scarola
PERSONRichard Horace Willits
PERSONKatherine W. Ezell
PERSONBruce E. Reinhart
PERSON