Epstein Secrets

ictimize C.M.A . 9. Furthermore, C.M.A.'s treatment records from the Inc. and are protected by the psychotherapist-patient privilege pursuant to the Supreme Court's decision in Jaffee v. Redmond, 518 U.S. 1, 116 S.Ct. 1923 3 EFTA00201395 Case 9:08-cv-80811-KAM Document 114 Entered on FLSD Docket 06/05/2009

f Defendant's Reasonable Expenses (D.E. 54). EPSTEIN is seeking from Plaintiff the production of certain treatment records of hers from the and Dr. Serge Thys 8. Neither the treatment records from th nor■ will have any relevance whatsoever in the event that Plaintiff pursues only those statutory damage

re, .'s treatment records from the Parent-Child Center, Inc. and Dr. Serge Thys are protected by the psychotherapist-patient privilege pursuant to the Supreme Court's decision in Jaffee'. Redmond, 518 U.S. 1, 116 S.Ct. 1923 3 EFTA00182846 Case 9:08-cv-80811-KAM Document 114 Entered on FLSD Docket 06/05/2009

through her undersigned attorneys, hereby files her Motion For Protective Order Regarding Treatment Records From Parent-Child Center, Inc. and Dr. Serge Thys and Incorporated Memorandum of Law, and in support there of states as follows: 1. This is an action to recover money damages against Defendant, J

te and unlikely"). In discussing Twombly, the Eleventh Circuit in Watts v. Fla. International Univ., 495 F.3d 1289, 1295 (111h Cir. 2007), noted - "The Supreme Court's most recent formulation of the pleading specificity standard is that 'stating such a claim requires a complaint with enough factual matter (taken a

d: 06/05/2009) 06/05/2009 114 r 0.6 MB Plaintiff's MOTION for Protective Order Regarding Treatment Records From Parent-Child Centgrajugh and Dr. Serge Thys and Incorporated Memorandum of Law by .. (Hill, Jack) (Entered: 06/05/2009) 06/08/2009 115 r 3.8 MB RESPONSE to Motion re (91 in 9:08-cv-80119-