Epstein Secrets

all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 1.L day of ~ , 2009 Res~itted, By:· ~ ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLE

ho may have or may ultimately see the Plaintiff and testify in court. 13. Defendant's counsel has retained the services of Richard Hall, M.D. and Ryan Hall, M.D., of C.W. Hall, M.D., P.A. located at 2500 West Lake Mary Blvd., #219 Lake Mary, FL 32746. Ryan Hall, M.D., will be performing the examination.

ST Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Isidro Manual Garcia [email protected] Case 9:08-cv-80119-KAM Document 346 Entered on FLSD Docket 10/

cular, the examiner proposes to ask Jane Doe about her previous “medical, . . . legal, social, criminal, [and] academic” background.” Affidavit of Ryan Hall, Attachment “D” to Defendant Epstein’s Motion to Compel Independent Medical Examination, [DE 301-4] Case 9:08-CV-80119- KAM. In addition, the exami

rd H. Willits, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, FL 33461 Phone: (561) 582-7600 Fax: (561) 588-8819 [email protected] Robert Critton, Esquire Michael J. Pike, Esquire Burman Critton Luttier & Coleman LLP 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 Phone: (561)

ant’s Reply to Plaintiff’s Motion for Protective Order regarding Defendant’s proposed mental examination of Plaintiff by his retained psychiatrist, Ryan Hall, M.D. 5. One of the grounds originally cited in Plaintiff’s Motion for Protective Order which sought to prevent the mental examination of Plaintiff

H. Willits, Esquire Richard H. Willits, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, FL 33461 Phone: (561) 582-7600 Fax: (561) 588-8819 Robert Critton, Esquire Burman Critton Luttier & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33414 Phone: (561) 842-2820 Fax: (561) 84

izes late in his "emergency"1 motion in that he seeks to have Plaintiff submit to a 6-8 hour compulsory examination with his retained psychiatrist, Ryan Hall, M.D. 3. Defendant has unilaterally selected August 20, 2009 for this examination. 4. Plaintiff has been hospitalized for the last two weeks suff

ounsel for Plaintiff BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 West Palm Be h, FL 33401 (561) 842- (561) 5 By: . Critton, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) 2 EFTA00598953 FIFTH SET OF INTERROGATOR

sponse to Request for Admissions No. 11 was anything other than an admission, please explain why you did not admit that the history you gave to Dr. Ryan Hall at your Compulsory Medical Examination on February 5, 2010 ("CME") was completely true and accurate and describe any false or inaccurate statements

Jaffe, Weissing, Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 02331-02334 05/08/2009 Susan Stirling Bradley Edwards Critton order Transcript Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible e

asonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05927 09/18/2009 Bradley Edwards Amy Swan Ryan Hall Psychiatrist Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evide

Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 02331-02334 05/08/2009 Susan Stirling Bradley Edwards Critton order Transcript Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible e

asonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05927 09/18/2009 Bradley Edwards Amy Swan Ryan Hall Psychiatrist Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evide