Epstein Secrets

er states as follows: In light of the Court's Order Denying Plaintiff, C.M.A.'s Emergency Motion For Protective Order Regarding the Depositions of Susan Pope and Dr. Serge Thys (D.E. 246)("Absent an amended pleading or stipulation of the parties, Plaintiff's unilateral non-binding notice of intent cannot

ws: In light of the Court's Order Denying Plaintiff, C.M.A.'s Emergency Motion For Protective Order Regarding the Depositions of Susan Pope and Dr. Serge Thys (D.E. 246)("Absent an amended pleading or stipulation of the parties, Plaintiff's unilateral non-binding notice of intent cannot be used to preclud

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

. 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

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

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

motion as it relates to Dr. Thys, is denied. In the same Motion at issue here, styled as an emergency, Plaintiff sought to protect the taking of Dr. Susan Pope’s deposition which was then scheduled for the following day, August 6, 2009. As Dr. Pope’s deposition was scheduled to take place the day after the

et 08/11/2009 Page 3 of 6 4 Affidavit of Plaintiff (D.E. #213); Plaintiff CMA’s Emergency Motion for Protective Order Regarding the Deposition of Serge Thys (D.E. #245); and, Plaintiff’s Request for Emergency Hearing on Plaintiff’s Motion for Protective Order (D.E. #250). Having reviewed the pleadings fil

FOR PROTECTIVE ORDER REGARDING THE DEPOSITIONS OF SUSAN POPE AND DR. SERGE THYS THIS CAUSE is before the Cour

REGARDING THE DEPOSITIONS OF SUSAN POPE AND DR. SERGE THYS THIS CAUSE is before the Court upon Plaintiff C.M

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

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

rds o 08/27/09 Review, annotate and highlight records 45*min Total hours 45 min Rate: S400/hour $300.00 CMA Records reviewed: Deposition of Susan Pope Medical records of St. Mary's Medical Center CV of Susan Pope Treatment records of Parent-Child Center, lnc. Medical records of Serge Thys, MD H

ion of Susan Pope Medical records of St. Mary's Medical Center CV of Susan Pope Treatment records of Parent-Child Center, lnc. Medical records of Serge Thys, MD High school records Medical records from Florida Atlantic University Community Wellness Center 09/01/09 Telephone conference with Attorney Pi

o 3 hr 30min 08/27/09 Review, annotate and highlight records 45 min Total hours Rate: $400/hour CMA Records reviewed: 45 min Deposition of Susan Pope Medical records of St. Mary's Medical Center CV of Susan Pope Treatment records of Parent-Child Center, Inc. Medical records of Serge Thys, MD H

ion of Susan Pope Medical records of St. Mary's Medical Center CV of Susan Pope Treatment records of Parent-Child Center, Inc. Medical records of Serge Thys, MD High school records Medical records from Florida Atlantic University Community Wellness Center 09/01/09 Telephone conference with Attorney Pi

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

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

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

) (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