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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 prostitut

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