EFTA01070501

Case 9:08-9v-80119-KAM 
Document 207-4 
Entered on FLSD Docket C.7/20120.49 . Page 15.af_48_ 
Case 9:08-cv-80811-KAM 
Document 54 
Entered on FLSD Docket 04/02/2009 
Page 15 of 18 
C.M.A. v. Epstein, et al. 
Page 15 
entitled to evidence which would show the nature of her relationship with males, 
whether she has suffered or engaged in other acts of sexual misconduct or activity as 
alleged in her complaint, and whether she suffered injury and damages as a result of 
the other claimed sexual misconduct or activity. See United States v. Bear Stops, 997 
F.2d 451 (8th Cir. 1993)(Defendant charged with sexual abuse of six year old boy was 
entitled to admission of evidence relating to victim's sexual assault by 3 older boys to 
establish alternative explanation for why victim exhibited behavioral manifestations of 
sexually abused child.). 
In further support of Defendant's motion, a copy of Bales v. Ruzzo, 703 So.2d 
1076 (Fla. 5th DCA 1997), rev. dented, 719 So.2d 286 (Fla. 1998), is attached hereto as 
Exhibit B as it is on point to the discovery Issues in this action, and the relevancy and 
discoverability of Plaintiff's history of sexual activity and any payment, therefore. See 
interrogatories 8, 22 and 30 propounded In the Balas case and footnote 1 herein. 3
Additionally and significantly, in other pending state court civil actions against. Defendant 
EPSTEIN attempting to assert similar claims and damages, the Circuit Court Judges 
have already ruled that such information is discoverable as it Is relevant to the damages 
claims of Plaintiff. See Composite Exhibits C and D hereto. Composite Exhibit C 
are the Orders, dated February 23, 2009, entered in the case of A.C. v. Epstein, and 
Case No. 502008CA025129 MB Al, 15th Judicial Circuit, In and For Palm Beach 
County, State of Florida, which granted Defendant's motion to compel therein directed 
3 In Bales v. Ru7zo supra, the Plaintiffs alleged a muiticount complaint Including claims for 
"coercion of prostitution" pursuant to §796.09, Fla. Stat.; for battery for the unwanted and 
offensive touching of petitioners' bodies; false imprisonment for physically confining the 
petitioners against their will; invasion of privacy; and intentional Infliction of emotional distress. 
EFTA01070501

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FISD.D.ock et 071201.2009. _Rag e_16_of_46. 
Case 9:08-cv-80611-KAM 
Document 54 
Entered on FLSD Docket 04/02/2009 , Page 16 of 18 
C.M.A. v. Epstein, et al. 
Page 16 
to discovery identical to Interrogatory no. 18 above. (In the A,C. case, the Plaintiff 
answered without objection interrogatories identical to nos. 19, 20, and 21 herein.) 
Composite Exhibit D is a portion the transcript from a March 3, 2009 hearing on 
Defendant's motion to compel discovery in the case of Jane Doe II v. Epstein, and 
Case No. 502008CA020614 MB AF, 15th Judicial Circuit Court, In and For Palm 
Beach County, State of Florida. Again, the Circuit Court Judge determined that the 
information sought is relevant to the Issue of damages and, thus, discoverable. 
Accordingly, Plaintiffs objections are required to be overruled and Defendant is 
entitled to the discovery sought. 
Interrogatory No. 23 
23. 
State the names, addresses, ages, phone numbers and dates of all 
females whom you claim were brought by you to Mr. Epstein's home to give him a 
massage or for any other reason. As to each female, state the amount of money you 
claim you were paid to bring each female. 
Answer: 
A.L. Age: 22 
West Palm Beach, FL 
I was paid $100.00 
Legal Argument Supporting Entitlement to Discovery 
Counsel for the respective parties also discussed this interrogatory In an effort to 
come to a resolution. Plaintiff does not object to the discovery requested. Plaintiffs 
counsel indicated that he had a "problem" disclosing the identity of A.L. to the extent 
she was a minor at the time. Defendant would agree to an order proteCting public 
disclosure of the true Identity of A.L. If she were indeed a minor at the time; however, as 
part of the order, Plaintiff should also be required to provide Defendant with the full 
EFTA01070502

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page_17 of  46 
Case 9:08-cv-80811-KAM 
Document 54 
Entered on FLSD Docket 04/02/2009; Page 17 of 18 
C.M.A. v. Epstein, et al. 
Page 17 
name of A.L. so that Defendant may conduct meaningful discovery. It is Plaintiff who 
claims she brought A.L. to Epstein's home as part of the alleged "scheme." In addition, 
Plaintiff failed to provide any date or dates as to when she brought A.L. to Epstein's 
home. Plaintiff's counsel indicated they would attempt to provide this information. 
Accordingly, In granting Defendant's motion to compel discovery, with respect t 
this interrogatory, Plaintiff should be required to provide the full name of A.L. (which 
Defendant agrees to keep confidential at this time), the date or dates which she brought 
A.L. or any female to Epstein's home, and how much she was allegedly paid each time. 
WHEREFORE, Defendant requests that this Court grant Defendant's motion to 
compel and award Defendant's reasonable expenses, including attorney's fees, 
associated with this motion. 
Rule 7.1 Certification 
I hereby certify that counsel for the respective parties communicated by 
telephone in a good faith effort to resolve the discovery Issues prior to the filing of this 
motion to compel. Some of the issues were resolved or in the process of being 
resolved. 
Robert D. C
Attorney for efendant Epstein 
yn, Jr. 
Certificate of Service 
I HEREBY CERTIFY that a true copy of the foregoing was electronically flied with 
the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being 
served this day on all counsel of re 
j entitled on the following Service. List in the 
manner specified by CMIECF on thi 
ay of April, 2009 
EFTA01070503

Cese.9:08-oy:§0119-KAM 
pospnent.207:4 
filtered on FLSD DooKet.01/2_9/2QQL_Page_113of.46. 
Case 9:08-cv-80811-KAM 
Document 64 
c.mA. v. Epstein, et al. 
Page 1B 
Richard Horace Willits, Esq. 
Richard 
vviiins, P.A. 
22901001 Avenue North 
Suite 404 
L 33461 
F 
Counsel for P alntiff C.M.A. 
realrhwfahotmail.com 
Entered on FLSD Docket 04/02/2009 
Page 18 of 18 
Jack Scarola, Esq. 
Jack P. Hill, Esq. 
Seamy Denney Scarola Bamhart 
Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
ach, FL 33409 
Fax: 
s)
js@serslasgin 
1phesearcvlaw.com 
Co-Counsel for Philntiff 
Jack Alan Goldberger, Esq. 
OkAlbe, got' & W0133,1;.A. 
250 Australian Avenue South 
, 
Suite 1400 
ach, FL 33401-5012 
F 
Jeoesaebellsouth.net 
Counsel for Defendant Jeffrey Epstein 
Bruce Reinhart, Esq. 
& Bruce E. Reinhart, P.A. 
250 S. Australian Avenue 
Suite 1400 
ach, FL 33401 
Fax: 
ecfabrucereinhartlaw 
Counsel for Defendan.
Respectfully subm' red, 
By: 
ROBERT D. 
ITTON, JR., ESQ. 
Florida Bar •. 224162 
rcrit(Obcicia .com 
MICHAEL J. PIKE, ESQ. 
Florida Bar #617298 
molkenbolclaw.conl 
BURMAN, CRITTON, LUTTIER & COLEMAN 
615 N. Flagler Drive, Suite 400 
; 
h, FL 33401 
Phone 
Fax 
(Cou
nsel 
for D•efendant Jeffrey Epstein) 
EFTA01070504

Case 
popyrne.nt?Q7.-.4 
on Fi-54 P0CKet 07/20/2,Q0_9__Page..19_0146 
Case 9:08-cv-80811-KAM 
Document 54-2 
Entered on FLSD Docket 04/02/201)9 
Page 1 of 2 
C.M.A. vs. Epstein, et 
case No.: 08-CV-80811-CIV-MARINJOHNSON 
Platatiff's Answers to Defendant's First Interroptories 
School behavioral problems, received counseling prior 
• 
8. 
Did you consume any alcoholic beverages or take any drugs or medications 
within 12 hours before the time of each incident(s) described in the complaidt? If 
so, state the type and amount of alcoholic beverages, drugs, or medication which 
were consumed, and when (dates) and where you consumed them. 
ANSWER 
1. On one occasion I had taken "Morning Glory" and "Angel Trurripets". I 
do not recall the date. 
2. On another occasion I used cocaine powder. I do not recall the date. 
9. 
Describe each injury (physical, emotional, mental) for which you are claiming 
damages In this case, specifying the part of your body that was Injured; the 
nature of the injury and as to any injuries you contend are permanent, the effects 
on you that you claim are permanent. 
ANSWER 
I have bipolar disorder and manic depression.1 lost my self-esteem. I 
began cutting myself on my arms and legs and developed drug problems. 
Permanent Injuries are psychological. 
10. 
Please state each Item of damage that you claim, and Include in your answer the 
count to which the Item of damages relates; the factual basis for each item of 
damages; and an explanation of how you computed each item of damages, 
including any mathematical formula used. 
ANSWER 
I am claiming compensation for mental anguish, mental pain, psychic 
trauma, and loss of enjoyment of life. These damages will be evaluated by 
a jury who will provide their own methods of computation in an amount of 
at least the statutory minimum established by 18 U.S.C.A. § 2255.1
Discovery is ongoing. 
11. 
List the names and business addresses of each physician (including psychiatrist, 
psychologist, chiropractor or medical provider) who hes treated or examined you, 
13 
stiv 
EXHIBIT :17 
EFTA01070505

Coe 9118-cv-801111cAM
Document 20724_ 
Case 9:08-cv-80811-KAM 
Document 54-2 
C.M.A. vs. Epstein, et el. 
Case No.: 03-CV-80811-CIV-MARRAC0HNS0N 
Plaintiff's Answers to Defendant's First Intecrogatortes 
....Entered on.ELSD.Dockel.07/20/2009.....RageZlof.46. 
Entered on FLED Docket 04102120th 
Page 2 of 2 
and 
w ere yo 
a 
for the injuries for which you seek damages in this case; and state as to each the 
date of treatment or examination and the injury or condition for which you were 
examined or treated. 
ANSWER 
Dr. Serge Thys (Psychiatrist) Date: I do not recall the date. I would defer 
2151 45 Street 
to the Doctor's records. 
West Palm Beach, FL. 33407 
a
Pope (Counselor/Therapist) Data: Since high school. Ongoing. 
Child Center 
2001 W. Blue Heron Boulevard 
12. 
List the names and business addresses of all other physicians, medical facilities, 
rehab facilities (drug, alcohol or psychiatric) or other health care providers 
including psychiatrist, psychologist, mental health counselor and chiropractors by 
whom or at which you have been examined or treated in the past 10 years; and 
state as to each the dates of examination or treatment and the condition or injury 
for which you were examined or treated. 
ANSWER 
Good Samaritan Hospital (3112/04, 312.6108) 
Child Birth 
1309 N Flagler Dr 
West Palm Beach, FL 33401 
St. Mary's Hospital (4107) 
DNC 
901 4511' Street 
West Palm Beach, FL 33407 
Gloria C. Hakkarainen, MD 
OblGyn 
2925 101h Avenue North, Suite 305 
Palm Springs, FL. 33461 
Theodore Ritota, DDS 
Dentist 
14 
EFTA01070506

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 21 of 46 
Case 9:08-cv-80811-KAM 
Document 54-3 
VVestiam 
703 So.2d 1076 
703 So.2d 1076,22 Fla. L. Weekly D2375, 23 Fla. I. Weekly D169 
(Cite as; 703 So.2d 1076) 
Entered on FLSD Docket 04/02/2009 Page 91fA 
Page 1 
District Court of Appeal of Florida, 
Fifth District. 
Kimberly BALAS and Teresa Shumate, Petitioners, 
v. 
Marjorie A. RUZZO, and Exec., Inc., etc., Re-
spondents. 
No. 97.82. 
Oct. 10, 1997. 
As MoOfled on Grant of Clarification Jan. 2, 1998. 
307A Pretrial Procedure 
rev own% €6. rt 
5.. -zit 
k no , 
307A11 Depositions and Discovery ; 
Plaintiffs brought action against alleged house of keteri3). 
307All(A) Discovery in General 
prostitution for, inter ado, coercion of prostitution. 
307Ak36 Particular Subjects of Disclos- um 
The Circuit Court, Brevard County, Frank Pound, 
307Ak36.1 k. In General. Most Cited 
J., granted in part defendants' motion to compel die- 
Cases 
covery. Plaintiffs filed petition for writ of carder- 
Evidence of plaintiffs' past prostitution and their 
art The District Court of Appeal, W. Sharp, J., held 
revenues relating to such activities, including activ-
that evidence of plaintiffs' past prostitution and 
ides with alleged house of prostitution against 
their revenues relating to such activities was dis• 
which they had filed suit, was disceverable, where 
covetable. 
plaintiffs brought action not only for coercion of 
prostitution, but also for battery, false imprison-
Petition denied. 
meat, invasion of privaoy, intentional infliction of 
emotional distress, violation of their civil rights, 
11111113, J., concurred specially and Bled opinion. 
and racketeering. Violent Crime Control and Law 
Enforcement Act of 1994, § 40302, 'a 
West Headnotes 
13961; West's FS.A. §{1 772.014, 796.09; West's 
F.S.A. RCP Rule 1280(*(1). 
D3 Pretrial Procedure 307A C=P31 
*1076 Richard E. Johnson and Heather Fisher Lind-
say, of Spriggs & Johnson, Tallahassee, for Peti-
tioners. 
Mark S. Peters of Amad, Theriac 4 Eisemnenger, 
P.A., Cocoa, for Respondents. 
307Ak31 k. Relevancy and Materiality. 
Most Cited Cases 
Party may be permitted to discover: evidence that 
would be inadmissible at trial, if It Would load to 
discovery of relevant evidence. West's P.S.A. RCP 
Rule 1.280(6)(1). 
[31 Pretrial Procedure 307A C=36.1 
307A Pretrial Procedure 
307A11 Depositions and Discovery 
307A11(A) Discovery In General 
307Ak31 k. Relevancy and Materiality. 
Most Cited Oases 
Discovery In civil cases must be relevant to subject 
matter of case and must be admissible or reason-
ably calculated to lead to admissible evidence. 
West's P.S.A. RCP Rule 12B0(6)(1). 
123 Pretrial Procedure 307A ca=31 
307A Pretrial Procedure 
307AE Depositions and Discovery 
307A11(A) Discovery in General 
W. SHARP, Judge. 
Baths and Shumate petition this court for a writ of 
certiorari to review certain portions of the lower 
court's order which granted, In pea, a motion to 
compel discovery Bled by respondents Rune and 
Exec., Inc. Petitioners argue that theise portions de-
part from the essential requirements Of law and will 
cause them irreparable harm because they will be 
2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. 
EXHIBIT yj 
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EFTA01070507

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
 Page 22 of 46 
Case 9:08-cv-80811-KAM 
Document 54-3 
Pgge 2 of 8 
Entered on FLSD Docket 04/02/2009 
Page 2 of 8 
703 So.2d 1076 
703 So.2d 1076, 22 Fla. L. Weekly D2375,23 Pla. L. Weekly D169 
(Cite as: 703 So.2d 1076) 
compelled to disclose Intimate details of their sexu-
 msteryrate,mog„040 ry 
the unit ntrertinrari 
Bales and Shumate filed suit against Ruzzo and Ex-
ec, Inc., doing business as 'The Boardroom." Ac-
cording to Baku and Shumate, The Boardroom op-
crates ostensibly as 9077 a leisure spa but actually 
is a house of prostitution. Batas worked at The 
Boardroom from December 1993 until February 
1996; Shumate worked there from October 1992 
until March 1996. Ruzzo, the sole officer and 
shareholder of Exec, Inc., collected about fifty to 
sixty percent of each employees' earnings from per-
forming sexual acts. 
According to Batas and Shumate, Ruzzo exerted 
mental and emotional control over her employees 
and thus she was able to exploit them as prostitutes. 
Ruzzo required her employees to pay her substan-
tial sums of money to attend "metaphysical work-
shops" conducted by Ruzzo or persons associated 
with her. At the work place, the employees were re-
quired to participate in religious and quasi-religious 
"circles," rituals and incantations. These practices 
were allegedly designed to break down the person-
alities of the women who worked for Ruzzo and to 
foster dependency and loyalty to herself. At one 
time when the earnings of a new employee were 
missing and believed to be stolen, Russo required 
that the petitioners be strip searched and body cav-
ity searched. Ruzzo caused the petitioners to be-
lieve their continued employment was dependent on 
their submission to these searches and that they 
might be arrested on felony charges if they refused 
to submit to the searches. 
Balsa end Shumate's second amended complaint 
against Russo contains seven counts. Count I is an 
action for coercion of prostitution pursuant to sec-
tion 796.09, Plorlda Statutes. Petitioners allege the 
requirement that they perform sexual acts to retain 
their employment constitutes Inducement and coer-
cion to engage in prostitution. Count II is a claim 
for battery for the unwanted and offensive touching 
of the petitioners' bodies. Count In Is a claim for 
false Imprisonment for physically confining the per 
Page 2 
titioners against their will. Count IV alleges that re-
spondents' actions constituted an Invasion of peti-
tioners' privacy. Count V is a claim )or the inten-
tional Infliction of emotional distress.,Count VI al-
leges a civil rights action-that respondents have vi-
olated petitioner? right to be free from crimes of vi-
olence motivated by gender within the meaning of 
42 U.S.C. section 13981. Finally, count VII seeks 
civil remedies for criminal practices or racketeering 
pursuant to section 772.104, FloridaiStatutes. The 
petitioners claim that they suffered emotional pain, 
anguish, humiliation, Insult, Indignity; loss of self-
esteem, inconvenience, hurt and emotional distress. 
They seek an award of general and punitive dam-
ages, among other relief. 
The discovery to which the petitioners am being re-
quked to respond Is as follows: 
I. 
Interrogatory 8: Please advise how long have you 
been engaged In prostitution... 
Interrogatory 22: State with specificity the man-
ner in which the acts as described !in your Com-
plaint have materially affected ho'/ you Interact 
with your husband, boyfriend, nuncio' [sic] or 
any other individual of the opposite sex. 
Request for Production 30: A copy of any photo-
graphs, movies or videotapes in which you per-
formed sexual acts and/or simulatUd sexual acts 
In exchange for money or other consideration. 
IV. 
Interrogatory 16: Please list the names, addressee, 
telephone numbers and rates of pay for all em-
ployers for which you worked. including the 
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EFTA01070508

Case 9:08-tv-801 1 9-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 23 of 46 
• 
" 
' 
Page of 8 
Case 9:08-cv-80811-KAM 
Document 54-3 
Entered on FLSD Docket 04/02/2009 
 3 of 8 
703 So.2d 1076 
703 So.2d 1076,22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169 
(Cite as: 703 So.2d 1076) 
nature of the work, during the five yens immedi-
 dtanmeshig4herdare 
amppinyenrnt "6th Ihr 
Boardroom and from the date of your termination 
with the Boardroom to the present, providing the 
names of your immediate supervisors at each 
place of employment and the reason for your 
leaving each place of employment. 
V. 
Interrogatory 26: Please state your total income 
while employed at the Boardroom, and state the 
source of that locome including any income from 
other employment or *1078 income earned from 
prostitution other than at the Boardroom. 
VI. 
Request for Production 34: Business records from 
any selfamp)oyment or owned business ventures 
in the last 5 years, including any records or list of 
customers, "special customer lists" or "sugar 
daddy's list." 
11112) Discovery in civil cases must be relevant to 
the subject matter of the case and must be admiss-
ible or reasonably calculated to lead to admissible 
evidence. See Allstate Insurance Co. v. Langston, 
655 So.2d 91 (Fia.1995); Ametue n Newman, 653 
Sold 1030 (FI41995); Russell v. Stardust Cruis-
ers, Inc., 69D So.2d 743 (Pia. 5th DCA 1997). The 
concept of relevancy Is broader in the discovery 
context than In the trial context and a party may be 
permitted to discover evidence that would be inad-
missible at tisk if it would lead to the discovery of 
relevant evidence, Allstate; Arnente. Florida Rule of 
Civil Procedure 1280(b)(1) delineates the proper 
scope of discovery: 
In General Parties may obtain discovery regard-
ing any matter, not privileged, that is relevant to 
the subject matter of the pending action, whether 
it relates to the claim or defense of the party 
seeking discovery or the olaim or defense of any 
other party, Including the existence, description. 
Page 3 
nature, custody, condition, and location of any 
hnnkc. documents, or other tangible things and 
the identity and location of persons having know-
ledge of any discoverable matter. It. Is not ground 
for objection that the information sought will be 
Inadmissible at the trial if the information sought 
appears reasonably calculated to lead to the dis-
covery of admissible evidence. 
Nonetheless, the discovery of certain kinds of in-
formation may cause material injury ,of an irrepar-
able nature. This includes the "cat-out-of-the-bag" 
material that could be used to injure another person 
or party outside the context of the litigation, materi-
al protected by privilege, trade ;carets or work 
product. Discovery was never intended to be used 
es a tactical tool to harass, embarrass or annoy 
one's adversary. Rather, pretrial discovery was im-
plemented to simplify the issues in a case, to elim-
inate the elements of surprise, to encourage the set-
tlement of cases, to avoid the cost of litigation, and 
to achieve a balanced search for the truth to ensure 
a fair trial. Elkins v. Sykes!, 672 So.2d 517 (Pla.1996). 
Hem the petitioners argue that the information 
sought to be discovered regarding prostitution and 
their sexual activities was propounded solely to em-
barrass them and to invade their right to privacy. 
The petitioners also claim that this Information is 
privileged under section 796.09 and is not calcu-
lated to lead to evidence which would be admiss-
ible at trial. 
Section 796.09 provides a person with a civil cause 
of action for compensatory and punitive damages 
against anyone who coerces that person into prosti-
tution, who coerces that penon to remain in prosti-
tution, or who uses coercion to collect or receive 
any part of that person's earning& derived from 
prostitution. In the course of Iltlgafion under this 
section, any transaction about which ? plaintiff test-
ifies or produces evidence does not subject the 
plaintiff to criminal prosecution or to any penalty or 
forfeiture. In addition, any testimony or evidence or 
any information produced by the plaintiff or wit-
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EFTA01070509

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 24 of 46.i
Case 9:08-ov-80811-KAM 
Document 54-3 
Entered on FWD Docket 04/02/2009 Wel 
of 8 
703 Sold 1076 
703 So.2d 1076,22 Fla. L. Weekly D2375,23 Fla. L. Weekly ID169 
(Cite as: 703 So.2d 1076) 
ness for the plaintiffs cannot be used against the 
vaunt-fro Of WillianT1- 27Irttinia 
proceeding, except ono for perjury. 
Section 796.09(5) specifically provides that it is not 
a defense that the plaintiff was paid or otherwise 
compensated for prostitution, that the plaintiff had 
engaged in prostitution prior to any Involvement 
with the defendant or that the plaintiff made no at-
tempt to escape from the defendant Section 
796.09(6) provides that convictions for prostitution 
or prostitution-related offenses are inadmissible for 
the purpose of attacking the plaintiffs' credibility. 
This legislation was the result of the Florida Su-
preme Court Gender Bias Study Commission, 
which conducted an extensive investigation of pros-
titution in this state. The Commission's activities 
included Interviews with law enforcement and cor-
rections personnel,*1079 judges, public defenders, 
prosecutors, drug rehabilitation counselors, social 
workers, medical personnel, prostitutes, clients and 
pimps. The Commission found prostitution to bo 
prevalent and uniform throughout the state and law 
enforcement largely unable to deter It under pre-
vailing social attitudes and judicial practices. The 
Commission further found that prostitutes arc often 
victims of economic, physical, and psychological 
coercion, that most persons do not chose to become 
prostitutes, but do so to survive, and that ninety 
percent of street prostitutes, both adult and chil-
dren, are controlled by pimps who use a variety of 
coercive methods to maintain this control. The 
Commission determined that clients and pimps are 
rarely prosecuted and, when prosecuted, receive 
light sentences; whereas prostitutes, who are mainly 
females, are frequently prosecuted and receive 
harsher treatment in the courts. The Commission 
recommended changes in the methods of Interven-
tion in prostitution from punitive to therapeutic, 
changes in the law to require more equal treatment 
by the courts of the prostitute In relation to the cli-
ent and the pimp and to lessen the incentive to 
traffic in human flesh by giving the prostitute ac-
cess to the judicial system without first having to be 
arrested. 
Page 
Under section 796.09, the petitioners' prior involve-
ment in prostitution and their earnings from prosti-
tution would be Irrelevant. Hence discovery should 
not be permitted because such InforMation would 
not be admissible at trial nor would it be reasonably 
calculated to lead to evidence ultimately admissible 
at trial. Even though the scope of discovery is gen-
erally quite broad, section 796.09 Is designed to en-
courage prostitutes to sue their pimps. Thus the 
usually broad scope of discovery may be tonsUlc-
ted so that prostitutes will not be embarrassed, har-
assed or hindered in their actions. 
• 
t3) Had the petitioners brought their lawsuit against 
Ruzzo and The Boardroom only undcr section 
796.09, evidence of petitioners' past prostitution. 
Including with the Boardroom, and their earnings 
relating to such activities, may not have been dis-
coverable. However, the petitioners filed a multi-
count complaint for compensatory . and punitive 
damages, alleging numerous causes of action 
against the respondents. These other causes carry 
no such protection from discovery, Since the In-
formation sought by discovery may he relevant or 
may Iced to the discovery of admissible evidence in 
one or more of these other causes of action or to 
determination of damages, we cannon conclude that 
the trial court departed from the essential require-
ments of law in granting this discovery. See Smith 
v. 778 Bank of the Keys, 687 So.2d 895 (Fla. 3d 
DCA 199'7) (by alleging fraud as well as breach of 
contract, purchaser placed at Issue her reliance on 
venders assertions, the veracity of financial docu-
ments she submitted to the vendor, and the state of 
her mental health, including memoryl problems she 
was experiencing at the time of the Alleged tortious 
conduct, thus deposition questions Concerning her 
state of mind were relevant). 
Petition for Writ of Certiorari DENIED. 
THOMPSON, J., concurs. 
HARRIS, 
J., 
concurs 
specially • with 
opin-
lon.HARRIS, Judge, concurring specially: 
CJ 2009 Thomson Reuicrs[Wcsi No Claim to0rIg. US Gov. Works. 
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EFTA01070510

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 25 of 46 
Case 9:08-cv-80811-KAM 
Document 54-3 
Entered on FLSD Docket 04102/2069 Pn eg5eqgf 8 
703 Sad 1076 
70380.2d 1076.22 Pb. L. Weedily D2375,23 FIL L. Weekly D169 
(Cite eel 703 So.2d 1076) 
Page 5 
There is a temptation in cases such as this to inquire 
any part of that person's earnings derived from 
which, the pot or the Kau°, trIMtruetrwith—thr 
prostriet  
darker hue. Indeed that may ultimately be the ques-
tion uppermost in the jurors' minds. But the Issue 
presently before us Is simply whether the pot, in or-
der to establish the parties' comparative complex-
ion, may discover the historical condition and the 
inherent characteristics of the kettle. 
We am here involved with parties that the limited 
record before us indicates were co-conspirators in a 
joint effort to violate Florida's laws against prosti-
tution. The defendant are the owner/operators of a 
"social club" whose primary service is prostitution; 
the plaintiffs am employees of tire club who 
provide such services. The employees are cuing the 
owner/operators for, among other counts, taking ad-
vantage of their vulnerabilities ("coercing" them to 
be prostitutes) through manipulation and exploita-
tion. In order to prepare a defense to the action, de-
fendants have flied certain interrogatories for the 
employees to answer. These interrogatories$1080 
request such information as how long the employ-
ees have been engaged in prostitution; how the em-
ployees have bean affected by the defendants' con-
duct; copies of photographs, movies, and video-
tapes in which the employees have performed sexu-
al acts or simulated sexual acts; the names of previ-
ous employers and previous rates of pay; and a 
statement of income received from defendants. 
These interrogatories survived the employees' ob-
jections. I agree certiorari should be denied. 
The employees' primary cause of action is based on 
section 796.09(1), Florida Statutes, which provides: 
(1) A person has a cause of action for compensatory 
and punitive damages against 
;a) A person who coerces that person into prostitu-
tion; 
1,b) A person who coerces that person to remain in 
prostitution, or 
',e) A person who uses coercion to collect or receive 
The employees resist discovery of thdir past prosti-
tution or their past or present earning experience on 
the basis of subparagraph 5 of section 796.09: 
;5) It does not constitute a defense to a complaint 
under this section that 
a) The plaintiff was paid or otherwise compensated 
for acts of prostitution; 
b) The plaintiff engaged in acts of prostitution pri-
or to any involvement with the defendant 
But the question before us is not whether prior acts 
of prostitution (or the receipts of earnings there-
from) which might be revealed by answering the in-
terrogatories could be used as a detente to the com-
plaint, but rather whether evidence of such conduct 
or such earnings would be relevant in determining 
whether the employees were, in fact, !'coerced" into 
prostitution, into remaining prostitutes, or Into shar-
ing the proceeds of their services with defendants. 
The relevancy of this information' depends, of 
course, on what constitutes coercion. 
if we apply the definition of "coercion" which Is 
commonly accepted, then the relevancy of the re-
quested information is apparent and this appeal has 
no merit at all. Webster defines "coercion" as: (1) 
to restrain or dominate by force, (2). to compel an 
act or choice, or (3) to enforce or tiring about by 
force or threat. In sexual battery cases, the legis-
lature has adopted the common moaning of the 
word "coercion" and has even placed limits on it. It 
has provided that consent will not be recognized if 
submission Is coerced by threats Drifters° or viol-
ence if the victim reasonably believes the perpetrat-
or has the present ability to exciting, the threat)," 
Consent also will not be recognized if submission is 
coerced by a threat of retaliation against the victim 
or another If the victim reasonably believes that the 
perpetrator has the ability to execute the threat in 
the future.loz And in sexual battery. cases, the le-
gislature hos vitiated what might otherwise be con-
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EFTA01070511

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 26 of 46 
Page 6 of 8 
Case 9:08-cv-80811-KAM 
Document 54-3 
Entered on FLSD Docket 04/02/2009 
Page 6 of 8 
703 So.2d 1076 
703 So.2d 1076, 22 Fla. L, 'iVeokly D2375, 23 Fla. L. Weekly 0169 
(ate ass 703 So.2d 1076) 
sidered as consensual If one exploits a known phys-
1,1) Promise of greater financial rewards! 
Page 6 
or her goal or takes advantage of one who is phys-
ically 
helpless 
or involuntarily 
intoxioateduc 
Therefore, even in sexual battery cases, before co-
ercion or exploitation will vitiate consent, the free 
will of the victim must be overcome by force or 
threat or some unfortunate circumstance suffered 
by tire victim. 
PHI. Section 794.011(4)(b), Florida Stat-
utes. 
P142. Section 794.011(4)(c), Florida Stat-
utes. 
PN3. Section 794.011(4)00,(d),00, and (I), 
Florida Statutes. 
But then we get to the definition of "coercion" con-
tained in section 796.09(3): 
1,3) As used in this section, Oro term "coercion" 
means any practice of dominion, restraint, or In-
ducement for the purpose of or with the reason-
ably foreseeable effect of causing another person 
to engage in or remain in prostitution or to relin-
quish earnings derived from prostitution, and in. 
eludes, but is not limited to: 
a) Phys teal force or throats of physical force. 
:b) Physical or mental torture. 
:c) Kidnapping. 
"1081 (d) Blackmail. 
;e) Extortion or claims of indebtedness. 
1) Threats of legal complaint or report of delin-
quency. 
;g) Threat to interfere with parental rights or re-
sponsibilities, whether by judicial or administrat-
ive action or otherwise. 
10 Promise of legal benefit. 
3) Promise of marriage. 
10 Restraint of Speech or communications with 
others. 
) Exploitation of a condition of developmental 
disability, cognitive limitation, affeetiva disorder, 
or substance dependency. 
:m) Exploitation of victimization by sexual abuse. 
:n) Exploitation of pornographic performance. 
;o) Exploitation of human needs for' food, shelter, 
safety, or affection. 
The definition urged by the employees heroin is the 
"promise of a greater financial reward." Whether 
the requested information is relevant r, the issue of 
coercion in this case will depend on what the legis-
lature intended by subsection (1) in the meaning of 
"coercion." 
1 agree with Judge Altenbernd's thoughtful analysis 
In State e Brigham, 694 So.2d 793 (19.97): 
there can be no dispute that the legislature's unusu-
al definition of "percent" is not a; common dic-
tionary definition. This is perhaps 'an appropriate 
ease in which to remind ourselves of Learned 
Band's famous observation that a "mature and de-
veloped Jurisprudence" does not "make a fortress 
out of the dictionary." 
But even so, one would expect some nexus between 
the commonly accepted meaning of a word and the 
definition of that word ascribed by the legislature. 
If, for example, the legislature defined "canine" as 
including cats, although one might, Jurisprodon-
daily speaking, expect to hear a meow emanate 
from a Great Dane, the courts should nevertheless 
closely examine the legislative history to sec if that 
Is really what the legislature Intended. The court in 
Young v. O'Keefe, 246 Iowa 1182, 60 N.W2d 534, 
537 (1955), stated this principle as', follows: But 
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EFTA01070512

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 27 of 46 
R
Ae 7 of
Case 9:08--cv-80811-KAM 
Document 54-3 
Entered on FLSD Docket 04/02/2009 PVargo 
of 8 
703 So.2d 1076 
703 So.2e1 1076, 22 Pla. L. Weakly 132375, 23 Pia. L Weekly D169 
(ate as: 703 So.2d 1076) 
before a definition is construed so as to expand the 
muwhing u 
onym 
the intention of the legislature to that ef-
fect must be clear." As Judge Campbell observed in 
Carron v. Roger Bohn, D.C., P.A., 580 So.2d 814, 
818 (Fla. 2d DCA 1991): 
ft la our primary duty to give effect to legislative 
intent and, if a literal interpretation of a statute 
leads to unreasonable results, then wo should ex-
ercise our power to interpret reason and logic to it. 
r*** r! 
Unfortunately, it is apparent that in enacting this le-
gislation, the legislature has, without redefining 
the terms for the purposes of this legislation, of-
ten used terms with commonly accepted mean-
ings for purposes at great variance from those 
commonly accepted meanings. 
In our case, the legislature did define the term for 
the purpose of the act. But because the term 
(coercion) as so defined can be interpreted two 
ways-one consistent with the commonly accepted 
meaning and one at variance-we should not accept 
the "antonym" unless such legislative intent is 
clear. A free will decision, even if based on a hope 
of financial gain, is the opposite of a coerced de-
cision. 
The employees urge that the mere promise of a 
greater reward brings them within the act. But if the 
mere promise of a greater reward is sufficient to es-
tablish coercion, then anyone who makes a volun-
tary end reasoned exercise of free will motivated by 
the hope of economic gain has been coerced. This 
definition removes the element of compulsion im-
plicit in the commonly accepted meaning of coer-
cion and substitutes therefor the mere desire for fin-
ancial gain. The employees herein assert that since 
they were offered "a greater financial reward" for 
providing the services performed by them through 
defendants establishment, they were coerced into 
their prostitution activities. This equates the giving 
Page 7 
of an opportunity to make a decision with the cou-
p of tr, t-rt 
Rut Rttlitertinn (I) can also 
mean *1082 that the promise of 'a greater reward is 
coercion only If such promised reward is sufficient 
to overcome one's natural revulsion to selling one's 
body for money. If there is no such revulsion, there 
can be no coercion. Becoming a prostitute only be-
cause one likes the hours and wages or "because it 
beats the heck out of working for a living" simply 
should not rneet the test of section 796.99(1). 
At oral argument herein, it was suggested without 
oontradiction, that at least one of the employees has 
a college degree and gave up a weir-paying, legit-
imate Job in order to engage in this profession for 
the greater reward. Section 796.09 doss not appear 
to be a general prostitute's relief act It is based on a 
report by the Gender Bias Study ComMission which 
recommended the equalization of treatment in rela-
tion to the prostitute, the client and the "pimp." It is 
based on the premise that prostitutes are generally 
victims of economic, physical, and • psychological 
coercion and choose prostitution in order to sur-
vive. Further, the Commission was concerned that 
90 percent of the street prostitutes are controlled by 
"pimps" who use a variety of coemlye methods to 
maintain control. It seems clear that the legislature 
was not intending to depart from the Precepts of the 
commonly understood meaning of `!coercion" and 
to redefine it to include both free will decisions and 
compelled decisions.. The interpretation urged by 
the employees seems at variance with the stated 
goal of the legislature and the Gender Bias Com-
mission. 
Since there is no cause of action prOvided for one 
who makes a reasoned and voluntary exercise of 
their free will to enter or continuo blithe profession 
solely for financial rewards (assuming "coercion" is 
given the definition more consistent iwIth its com-
monly accepted meaning and assuming that my In-
terpretation of legislative intent is emirect), coercion 
becomes the critical issue in the trial of such action. 
Tho interrogatories propounded by defendants ap-
pear relevant to the issue of coercion. 
O 2009 Thomson ReetersfiVest. No Claim to Orig. US Gov. Works. 
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EFTA01070513

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 28 of 46 
e 8 of 8 
Case 9:08-cv-80811-KAM 
Document 54-3 
Entered on FLSD Docket 04/02/2009 Pm 
rage of B 
703 So.2d 1076 
703 So.2d 1076, 22 Fla. L. Weekly 132375, 23 Ha.  Weekly 13169 
(Cite as: 703 So.2d 1076) 
This Is a case of first impression based one relat-
ively new statute, its unnttatil, 
legielaCyt. JAL 
tory of the new law suggests that the statute is de-
signed to assist those who were forced to enter 
prostitution in order to keep a roof over their heads 
or food on their table. It does not appear to be In-
tended to aid those who voluntarily enter the pro-
fession in order to drive a Mercedes instead of a 
Ford. The limited record before us indicates that 
even beginning employees of the defendants (those 
who do not have an established clientele) bring in 
$700 a day end can keep 50% of their earnings. 
Based on a five-day work week, this would reflect 
an income of $87,500 a year even with a two week 
vacation. And the employees herein are not begin-
ners. 
There is no indication that the legislature intended 
to legalize prostitution or to make it a respectable 
profession. It merely intended to place the prosti-
tute on the tame tooting with the client and the 
"pimp." If a prostitute voluntarily makes the de-
cision to participate, free from force, intimidation, 
or disadvantageous circumstance, then he or she is 
on the same footing as the other participants and 
should be treated the same. 
Although it might well serve a legitimate public 
purpose to permit the cannibalistic demise of such 
enterprises (and I am not unsympathetic with this 
view), that does not appear to be the policy behind 
the current statute. Therefore, in eases where coer-
cion is not present (and this may or may not be 
one), the court should continue its tradition of not 
interceding in civil conflicts involving transactions 
that are either Illegal or are against public policy. 
See Wechsler v. Novak 157 plc. 703, 26 So.2d 884 
(1946); Thomas v. Rattner. 462 So.24 1157, 1160 
(Fla. 3d DCA 1984), rev. dented 472 So.2d 1182 
(fla.1985) ("An action may Ile for Interference with 
an unenforceable contract and even perhaps a void-
able contract. No such cause of action lies for inter-
ference with a contract void as against public policy 
(another's representation of a client obtained by a 
cloctollavryer's illegal personal Minty solicitation 
Page 
in the hospital) and which makes one who is a party 
.L. 
br pp Pll reit In the insInnt haRn Milli,/ of 
a criminal act for entering into such an agree- ment") 
We are not asked in this proceeding to rule on the 
admissibility of the discovered information as evid-
ence at the trial of this cause. We are to determine 
only if the information might lead to admissible 
evidence. Even *1083 though we deity the Writ I 
suggest we certify the following question: 
DOES ONE, FREE FROM FORM, INTIMIDA-
TION, OR DISADVANTAGEOUS CIRCUM-
STANCE, WHO MARES A REASONED DE-
CISION TO BECOME OR REMAIN A PROSTI-
TUTE( OR TO SHARE TUB PROCEEDS 
THEREOF BECAUSE! OP A PROMISE OP A 
GREATER PD4ANCLAL REWARD HAVE A 
CAUSE 
OP 
ACTION 
UNDER 
SECTION 
796.09(1), FLORIDA STATUTES/ • 
ON MOTIONS FOR REERARING, FOR CLAN, 
FICAVON, FOR CER27FICATION, AND FOR REP 
MARINO RN BANC 
W. SHARP, Judge. 
Petitioners Bales and Shumate have, flied motions 
for rehearing, clarification and certification. We 
deny the motions in full except for qna regard. We 
delete the sentence in the last full paragraph of the 
opinion which reads: "These other causes of action 
carry no such protection from dist-only." 
Motion for Clarification GRANTED as stated 
abovr, Motion for Rehearing and Certification 
DENIM 
HARRIS and THOMPSON, D., cone*. 
Fla.App. 5 Dlst.,1997. 
Bales V. R1121.0 
703 So.2d 1076, 22 Ha. L. Weekly D2375, 23 Fla. 
L. Noddy D169 
END OP DOCUMENT 
© 2009 Thomson Reuters/West. No Claim to trig. US Gov. Works. 
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EFTA01070514

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 29 of 46 
• 
Case 9:08-cv-80811-KAM 
Document 54-4 
Entered on ELSD pocket 04/02/2009 
Page 1 of 2 
• 
IN THE COURT OF THE FIFTEENTH 
JUDICIAL CIRCUIT, IN AND FOR PALM 
DCACI I COUNTY, FLORIDA 
A.C., 
Plaintiff, 
v. 
ail
E. EPSTEIN, and 
CASE NO. 502008CA025129)COO(MB Al
•
 
Defendants. 
ORDER ON DEFENDANT EPSTEIN'S MOTION TO COMPEL RESPONSES TO 
FIRST REQUEST TO PRODUCE TO PLAINTIFF AND TO OVERRULE 
PLAINTIFF'S OBJECTIONS, & FO DEFENDANT'S,EXPENSEs; 
INCLUDING ATTORNEYS' FEES 
THIS CAUSE came before the Court on Defendant Epstein's Motion To 
Compel Responses To First Request To Produce To Plaintiff And To O'jrerruie 
Plaintiff's Objections, & For Defendant's Expenses, Including Attorneys! Fees 
and the Court having heard argument of counsel and being fully advised in these 
premises, it Is hereby 
denied  a, 
,to 4
 
22. 
41 /7 4 eglg 
AA-) 
Ovnittae? 
Lt 
asap Jabdim-td- 
to bk. Wave, 
DONE AND ORDERED at Palnech Cou 
urthouse, West Palm 
7,
Beach, Florida, this  
, day of 
•• 
ORDERED and ADJUDGED that Defendants Motion Is hereby grarited/ 
tsion‘L.L4 
1 2r, SOMnae.... 
Edward A. I arrison 
Circuit Judge 
Copies furnished: 
ROBERT D. CRYTTON, JRL, E&Q, and MICHAEL J. PIKE, ESCL, 515 North Gaoler DIM% Stifle 400, Won Palm Beach, 
M. 33401; JACK SCAROLA, ESQ., AND JACK P. HILL, ESQ., Seamy Denney Soarola Barnhart & 
ilhcra
ptPA, 2139 Palm Beech Lakes Blvd., West Palm Beach, FL 33409, and JACK A. 
oas, ESQ., Atterbury Goldberger & Weiss, PA, One Clearleke Centre, SuIte 1400, 250 
Australian Avenue South, West Palm Beach, FL 33401 
I 
lel  ty 
EXHIBI T
1 
EFTA01070515

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 30 of 46 
— 
— 
• • 
Case 9:08-cv-80811-KAM Document 54-4 
Entered on FLSD Docket 04/02/209 
Page 2 of 2 3r
A.G., • 
Rai*, 
v. 
Mit
E. EPSTEIN, and 
Defendants. 
IN THE COURT OF THE FIFTEENTH 
JUDICIAL CIRCUIT, IN. AND FOR PALM 
BEACH COUNT , 
I 
•
 
CASE NO. 502008CA025129)0,0004E3 Al 
• 
ORDER ON DEFENDANT EPSTEIN'S MOTION TO COMPEL ANSWERS TO 
INTERROGATORIES AND TO OVERRULE PLAINTIFF'S OBJECTIONS, & FOR 
DEPENDANT'S EXPENSES; INCLUDING ATTORNEYS' FEES 
THIS CAUSE came before the Court on Defendant Epstein's Motion To 
Compel Answers To Interrogatories And To Ovenuie Plaintiff's Objections, .5 For 
Defendant's Expenses, Including Attorneys' Fees, and the Court having heard 
argument of counsel and being fully advised In these premises, It Is hereby 
ORDERED and ADJUDGED that Defendant's Motion Is hereby granted/ 
Stet  
•c .z. 1-k, 415, 12 
iS 
4.2 , 
flEver".242„ 
at-o 
L 
JOAtta.,29 
eh 
dar. 
DONE AND ORDERED at Palm Beach Cougly Courthouse, West Palm 
Beach, Florida, this  23 day of  
fai 
award A. Garrison 
Circuit Judge 
Copies furnished: 
ROBERT D. CRITIC:N, JR., ESQ., end MICHAEL J. FEE, ESQ.. 61s North Finder Dam Guns 400, West Parm Beach, 
FL 33401; JACK SCAROLA, ESQ., AND JACK P. HILL, ESQ., Seamy Denney Scarola Barnhart & 
Shipley, P.A., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409, and JACK A. 
GOLDBERGER, ESQ., Atterbury Goldberger & Weiss, P.A., One Cleadake Centre, Butte 1400, 260 
Australian Avenue South, West Palm Beach, FL 33401 
EFTA01070516

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page A1 of 46_ 
• 
/
Case 9:08-cv-80811-KAM 
• 
Document 54-5 
Entered on FLSD Docket 04/02/2009 
Page 1 of 14 
1 
IN THE FIFTEENTH JUDICIAL CIRCUIT COURT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE NO. 50 2008CA020614XXXgMB At 
JANE DOE II, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN and 
Defendants. 
COPY 
COURT REPORTER'S TRANSCRIPT OF 
PROCEEDINGS HAD BEFORE 
THE HONORABLE DIANA LEWIS 
DATE: 
March 3, 2009 
PLACE: 
Palm Beach County Courthouse 
205 N. Dixie Highway 
West Palm Beach, Florida 33401 
U.S. Legal' Support 
EXHIBIT 
// 
1 
EFTA01070517

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 Page 32 of 46 
se 9:08-cv-80811-KAM 
Document 64-5 
Entered on FLSD Docket 04/02/2009 Page 2 of 14 
1 
2 
2 
APPEARANCES: 
a 
4 
5 
6 
7 
8 
10 
. 11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
2C 
25 
GARCIA LAW FIRM, P.A. 
224 Datura Avenue 
Suite 900 
West Palm Beach, Florida 33401 
Counsel for Plaintiff 
BY: ISIDRO M. GARCIA, ESQUIRE 
BURMAN, CRITTON, LUTTIER & COLEMAN 
515 N. Flagler Drive 
Suite 400 
West Palm Beach, Florida 33401 
Counsel for Defendant 
BY: ROBERT D. CRITTON, JR., ESQUIRE 
I 
EFTA01070518

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 33 of 46 
• 
• 
• 
• Case 9:08-cv 80811-KAM 
Document 54-5 
Entered on FLSD Docket 04/02/2009 Page 3 
of 14 
11 
1 
2 
4 
5 
6 
7 
8 
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1/ 
12 
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that but I'd just like to do that. 
THE COURT: Right. And if you want tb 
contact the other 
ua ti saying, 
you 
I'm the one that's questioning whether or not 
these need to be before one judge. You may have 
a different perspective than your colleagues who 
are prosecuting some of the cases. 
I understand the damages. I'm rot 
saying consolidate. I'm saying transfer. . It's 
not a consolidation issue. Everybody get that 
confused for some reason. The words are very 
different out of my mouth, your mouth and'how 
they're written. 
So let me go ahead and take a gander at 
this. I did read it last night. I'm not sure 
that we need to get -- we need names? 
MR. CRITTON: Right. Well, here's what some 
of the issues are is that, as an example L- if I 
could approach the bench. 
THE COURT; Sure. 
MR. CRITTON: This is some of the 
information that we've obtained through discovery 
from some of the -- from at least in this. 
instance, it would be this particular Jana Doe. 
THE COURT: You know who Jane Doe is I take 
U.S. Legal Support 
EFTA01070519

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 34 of 46 
Case 9:08-cv 86811-KAM 
Document 54-5 
Entered on FLSD Docket 04/02/2009 
Page 4 of 14 
12
3. 
2 
3 
4 
5 
6 
7 
B 
9 
10 
11 
12 
13 
7.4 
15 
16 
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it? 
MR. CRITTON: Right. 
THE COURT: xoulalow w u Lhe Jane Die+ is? 
MR. CRITTON: Yes, correct. And so this 
particular lady has kept in part a diary and 
she -- which appears to have started some time 
this is not in any way significant -- but!some 
time after she learned that she could file a 
lawsuit. I think she's also been to Oakwood 
Center some time after she learned she could file 
a lawsuit and seek damages from Mr. Epstein. 
There's no history of this lady. 
beforehand other than. in some of the Oakwood 
records where she. was Saker Acted, she started 
drinking beer at -16, she started Xanax at'16, 
started marijuina at'15, that she's sexually 
active: 
So how she has interacted -- she has a 
claim for emotional damages, mental pain and 
anguish, psychiatric-type damages. How she's 
interacted with friends, with family, the. events 
'in her life, school, work, her interpersonal 
relationships both with men and let's -- we'll 
use an'example men here, but other individuals. 
She's saying that this event with Mr. Epstein, 
U.S. Le al Su out'. 
EFTA01070520