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

SON 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 Motion for Protective O

R REGARDING TREATMENT RECORDS FROM PARENT-CHILD CENTER, INC., DR. SERGE THYS, 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., WITH INCORPORTATED MEMO OF LAW {DE 207) The Plaintiff, CAROLYN

of 6 Opposition to Plaintiff, Carolyn Margaret Andriano's Motion for Protective Order Regarding Treatment Records From Parent-Child Center, Inc. Dr. Serge Thys, Records of Dominique Hyppolite/School District of Palm Beach County, Good Samaritan Hospital, St. Mary's Hospital, Florida Atlantic University and

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

. 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 Records From Palm Beach

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

na. However, on June 5, 2009, Plaintiff then filed a Motion for Protective Order Regarding Treatment Records From Parent-Child Center, Inc. and Dr. Serge Thys (DE 114). On June 17, 2009, Plaintiff filed a subsequent Motion for Protective Order Regarding Treatment Records From Palm Beach County School Dist

13). On June 17, 2009, Plaintiff 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). While Plaintiff agreed to allow Defendant to identify her

r Plaintiff allowed Defendant to use her name in third party subpoenas, Defendant served subpoenas on: a. Palm Beach County School District b. Dr. Serge Thys c. Parent/Child Center d. Good Samaritan Hospital e. St. Mary's Hospital f. Dr. Gloria C. Hakkarinen g. Florida Atlantic University CMA then f

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

is case; and state as to each the date of treatment or examination and the injury or condition for which you were examined or treated. ANSWER Dr. Serge Thys (Psychiatrist) 2151 45th Street West Palm Beach, FL. 33407 Date: I do not recall the date. I would defer to the Doctor's records. Susan Pope (Co

tective Order Regarding Treatment Records from Parent-Child Center, Inc., Dr. Serge Thys, Dominique Hyppolite/School District of Palm Beach County, Good Samaritan Hospital, St. Mary's Hospital, Florida Atlantic University and Glorida C. Hakkarainen. M.D. and Incorporated Memorandum of Law by C.M.A.. (Attachments: # 1

7/16/2009. (ir) (Entered: 07/16/2009) 207 Plaintiff's MOTION for Protective Order Regarding Treatment Records from Parent-Child Center, Inc., Dr. Serge Thys, Dominique Hyppolite/School District of Palm Beach County, Good Samaritan Hospital, St. Mary's Hospital, Florida Atlantic University and Glorida C.

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,

) (Entered: 06/05/2009) 06/05/2009 114 Plaintiff's MOTION for Protective Order Regarding Treatment Records From Parent-Child Center, Inc. and Dr. Serge Thys and Incorporated Memorandum of Law by C.M.A.. (Hill, Jack) (Entered: 06/05/2009) 06/08/2009 115 RESPONSE to Motion re (91 in 9:08-cv-80I19-KAM) De