Epstein Secrets

Entered on FLSD Docket 09/11/2009 Page 14 of 33 Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue

E COURT: We'll get him to a microphone. 14 Mr. Willits is speaking. 15 MR. WILLITS: On behalf of my c

Jane -qoe_ #~ v_ Jeffrey Epstein AFFIDAVIT OF RICHARD C.W. HALL, M.D. STATE OF FLORIDA COUNTY OF SEMINOLE On t

lated Case No. 08-80893 In related Cases Nos. 08-80069. 08-80119, 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

have experienced several incidents in their lives which affected them emotionally and psychologically. See M•, Exhibits "C" and "D", Affidavits of Richard C.W. Hall, outlining the psychological issues experienced by Jane Does 4 and 6 as a result of incidents in their lives prior to Epstein, which cannot be disc

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provided to and used by the Defendant’s expert, Richard C.W. Hall, M.D.2 Defendant therefore is not by any stretc

obert D. Critton, Es . Bradley James Edwards Isidro Manuel Garcia Jack Patrick Hill Katherine Warthen Ezell Michael James Pike Paul G. Cassell Richard Horace Willits Robert C. Josefsberg 9 EFTA00729124

nsic psychiatric expert, Dr. Kliman, including videotaped interviews of Plaintiffs, which have been provided to and used by the Defendant's expert, Richard C.W. Hall, M.D.2 Defendant therefore is not by any stretch being unreasonably delayed or thwarted in obtaining nonparty discovery through the rules of civil p

305-931-2200 Fax: 305-931-0877 Counsel for Plaints,* In related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994 Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10a Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Re

have experienced several incidents in their lives which affected them emotionally and psychologically. See g., Exhibits "C" and "D", Affidavits of Richard C.W. Hall, outlining the psychological issues experienced by Jane Does 4 and 6 as a result of incidents in their lives prior to Epstein, which cannot be disc

[email protected] Counsel for Plaintiffs In related Cases Nos. 08-80069, 0840119, 08- 80232, 08-80380, 08-80381, 08-80993, 08- 80994 Richard Horace Willits, Esq. Richard H. Willits, PA 229010°i Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Rela

cally, with regard to Jane Doe No. 4, which is the deposition set for next week, September 16, 2009, the plaintiff has in her past (see affidavit of Richard C.W. Hall, M.D., an expert psychiatrist retained by Defendant to conduct exams on various claimants.) Exhibit "5" A. Sought counseling due to a dysfunctiona

Boulevard Suite 2218 Miami, FL 33160 Counsel or Paint: In related Cases Nos. 0840069, 08-80119, 08- 80232, 08-80380, 0840381, 0840993, 08- 80994 Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth. FL 33461 Fax: Counse for Plaintiff in Related Case No. 08- 80811 J

cally, with regard to Jane Doe No. 4, which is the deposition set for next week, September 16, 2009, the plaintiff has in her past (see affidavit of Richard C.W. Hall, M.D., an expert psychiatrist retained by Defendant to conduct exams on various claimants.) aet Exhibit "5" A B. C. EFTA00182048 Case 9:08-cv