Epstein Secrets

ds of hers from the Susan Pope/Parent-Child Center, Inc., Dr. Serge Thys, a psychiatrist, Dominique Hyppolite/School District of Palm Beach County, Good Samaritan Hospital, St. Mary's Hospital, Florida Atlantic University and Gloria C. Hakkarainen, M.D. 9. Also pending before the Court is Plaintiff, Carolyn Margaret

CV-80591-MARRA/JOHNSON CASE NO.: 09-CV-80656-MARRA/JOHNSON PLAINTIFF, C.M.A.'S, EMERGENCY MOTION FOR PROTECTIVE ORDER REGARDING THE DEPOSITIONS OF SUSAN POPE AND DR. SERGE THYS AND INCORPORATED MEMORANDUM OF LAW Plaintiff, C.M.A., by and through her undersigned attorneys, hereby files her Emergency Moti

On June 17, 2009, Plaintiff then filed a subsequent Motion for Protective Order Regarding Treatment Records From Palm Beach County School District, Good Samaritan Hospital, St. Mary's Hospital Dr. Gloria C. Hakkarinen, and Florida Atlantic University (DE 121, now DE 207). While Plaintiff agreed to allow Defendant to i

revented by Plaintiff. Then, on June 5, 2009, C.M.A. filed a Motion for Protective Order Regarding Treatment Records From Parent-Child Center, Inc. (Susan Pope) and Dr. Serge Thys (DE 114, now DE 207). On June 17, 2009, Plaintiff then filed a subsequent Motion for Protective Order Regarding Treatment Reco

14). On June 17, 2009, Plaintiff filed a subsequent Motion for Protective Order Regarding Treatment Records From Palm Beach County School District, Good Samaritan Hospital, Case 9:08-cv-80119-KAM Document 273 Entered on FLSD Docket 08/17/2009 Page 3 of 11 St. Mary's Hospital Dr. Gloria C. Hakkarinen, and Florid

e to have a meaningful compulsory psychological examination by a defense expert. For example, Defendant's attorneys recently took the deposition of Susan Pope, who counseled Plaintiff for the last 12 years. Significantly, Susan Pope could not identify anywhere in her records from 2003 through 2009 wherein

t 10 years; and state as to each the dates of examination or treatment and the condition or injury for which you were examined or treated. ANSWER Good Samaritan Hospital (3/12/04, 3/25/08) Child Birth 1309 N Flagler Dr West Palm Beach, FL 33401 St. Mary's Hospital (4107) DNC 901 45th Street West Palm Beach, FL

m and friend of C.M.A. 24. Ghislane Maxwell c/o Ghislane Corp. 3580 Brillo Way Palm Beach, FL 33480 Subject matter: Associate of Epstein. 25. Susan Pope Parent Child Center West Palm Beach, FL 26. 27. Subject matter: Counselor at Parent Child Center. Palm Beach Police Department 345 South Coun

06/17/2009) 06/17/2009 121 Plaintiff's MOTION for Protective Order Regarding Records of Dominique Hyppolite/School District of Palm Beach County, Good Samaritan Hospital, St. Mary's Hospital, Florida Atlantic University and Gloria C. Hakkarainen, M.D. by C.M.A.. (Attachments: # 1 Exhibit Notice of Taking Deposition,

Judge Kenneth A. Marra on 8/4/2009. (mkz) (Entered: 08/04/2009) 08/04/2009 245 EMERGENCY MOTION for Protective Order Regarding The Depositions of Susan Pope and Dr. Serge Thys and Incorporated Memorandum of Law by C.M.A.. (Attachments: # 1 main document continued. # 2 document continued. # 3 document co