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activity with third parties has no bearing on the issue of whether she consented to or complied with the sexual acts charged. See United States v. Stone, 472 F.2d 909, 919 (5th Cir. 1973); Virgin Islands v. Jacobs, 634 F.Supp. 933, 936-37 (D. V.I. 1986) (policy of rule disallowing evidence to show c
ed, it does not appear that an analogous argument was made in any of the state court cases relied upon by Defendant. Furthermore, the discovery in Balas v. Russo, 703 So.2d 1076 (Fla. 3d DCA 1997) was far narrower than that which is at issue here. It was limited to asking plaintiffs for their employ
activity with third parties has no bearing on the issue of whether she consented to or complied with the sexual acts charged. See United States v. Stone, 472 F.2d 909, 919 (5th Cir. 1973); Virgin Islands v. Jacobs, 634 F.Supp. 933, 936-37 (D. V.I. 1986) (policy of rule disallowing evidence to show c
eed, it does not appear that an analogous argument was made in any of the state court cases relied upon by Defendant. Furthermore, the discovery in Balas v. Russo, 703 So.2d 1076 (Fla. 3d DCA 1997) was far narrower than that which is at issue here. It was limited to asking plaintiffs for their emplo
with the sexual acts charged. See United States Stone, 472 F.2d 909, 919 (5th Cir. 1973)• Virgin Island
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
with the sexual acts charged. See United States,. Stone, 472 F.2d 909, 919 (5th Cir. 1973); Virgin Islan
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 Oliver Stone and Balas

Jeffrey Epstein
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