Epstein Secrets

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 Andriano's Motion for

lege. WHEREFORE, Plaintiff, C.M.A., respectfully requests that this Court enter a protective order preventing the depositions of Susan Pope and Dr. Serge until such time as the Court decides whether the statutory damages pursuant to 18 U.S.C. §2255 are available to a victim of an enumerated sexual of

reatment 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 Gloria C. 3 Case 9:08-cv-80119-KAM Document 207 Entered on FLSD Docket 07/20/2009 Page 4 of 9 Hakkarainen,

r the Defendant is not in agreement with Plaintiff's Motion For Protective Order Regarding Treatment Records From the 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 Glori

nas, 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 filed two (2) protective orders, and all records that were obtained (or were

. failed to disclose that on June 5, 2009 she filed a Motion for Protective Order Regarding Treatment Records From Parent-Child Center, Inc. and Dr. Serge Thys (DE 114), and of even date she filed her Conditional Notice of Intent to Exclusively Rely on the Statutory Damages provided by 18 U.S.C. 2255.