Case 9:08-cv-80119-KAM Document 245-1 Entered on FLSD Docket 08/05/2009 Page 1 of 50 Case 9:08-cv-80811-KAM Document 54 Entered on FLSD Docket 04/02/2009 Page 12 of 18 C.MA. v. Epstein. et al. Page 12 objection Is required to be overruled, and Defendant is entitled to the Information sought in the Interrogatory. Interrogatory No. 18 18. List separately the names, addresses and phone numbers of all males, excluding Mr. Epstein, with whom you have had sexual activity since age 10 (by year) up through your current age. Describe the nature of sexual activity, the date(s) and whether you received money or other consideration from the person. Answer: Objection. Relevance and overbroad. Legal Argument Supporting Entitlement to Discovery Plaintiffs only objection Is relevancy and overbroad, without any factual support or showing as required by Rule 26(c) and Local Gen. Rule 26.1 H (S.D. Fla. 2008). Nowhere does C.M.A. explain how such interrogatory is overbroad. It is well settled that relevant information is discoverable, even if not admissible at trial, so long as the discovery is reasonably calculated to lead to the discovery of admissible evidence. Rule 26(bX1), Fed.R.Civ.P.; Donahav v. Palm Beach Tours & trans.. Inc., 242 F.R.D. 685 (S.D. Fla. 2007). Discoverabllity of an alleged victim's/plaintiffs sexual conduct or activity in civil cases is govemed by Rule 26, Fed.R.Civ.P., pursuant to which the scope of discovery Is broad. Donahav, supra, at 686, and cases cited therein. "Parties may obtain discovery regarding any matter, not privileged, which is relevant to the claims or defense of any party involved in the pending action." Id. In accordance with Rule 26, the discovery sought regarding Plaintiff's sexual activity with males and the nature thereof, Including whether she received any EFTA02745664