Epstein Secrets

80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994 Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811 [email protected] Jack Scarola, Esq. Jack P. Hil

oe has suffered and will continue to suffer severe mental anguish and pain." !s;L, at ,i,i 25-27. 4. In addition, Jane Doe #3 informed her expert, Gilbert Kliman, M.D that she comes from a broken family and had an abusive, alcoholic father. She further states that she has been depressed for a long time, has

Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Couns

4. In addition, Jane Doe #6 informed her expert, Gilbert Kliman, M.D that she doesn't drive, is afraid to drive

Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Couns

4. In addition, Jane Doe #2 informed her expert, Gilbert Kliman, M.D that she has always been a "nervous person.

80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994 Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811 [email protected] Jack Scarola, Esq. Jack P. Hil

on about Jane Doe #4 without the investigators even mentioning Jane Doe's name. Importantly, Jane Doe #4 provided Mr. Vinyard's name to her expert, Gilbert Kliman, M.D. In fact, she stated in the interview with Dr. Kliman that Mr. Vinyard was not a good influence on her and that he was an alcoholic. See Exhibi

80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994 Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811 [email protected] Jack Scarola, Esq. Jack P. Hi

oe has suffered and will continue to suffer severe mental anguish and pain." lg_,_ at ,r,r 25-27. 4. In addition, Jane Doe #5 informed her expert, Gilbert Kliman, M.D. that she is a "very depressed person inside" and is always "on edge." She indicates that as a child while in school, girls wanted and/or atte

Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Couns

er boyfriend's name, Mr. Vinyard, to her expert, Gilbert Kliman, M.D. In fact, she stated in the interview with D

NSON Plaintiffs Motion for Protective Order COUNSEL LIST Richard H. Willits, Esquire Richard H. Willits, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, Phone: Fax: Robert Critton, Esquire Burman Critton Luther & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm B 4 Phone: Fax: Jack

d that public disclosure of their real names would create a substantial risk to them of further psychological harm. See Exhibit "A", Declaration of Gilbert Kliman, M.D. 4. Dr. Kliman opines as follows: Releasing names of the plaintiffs to the public will reenact experiences of powerlessness and helplessness