Epstein Secrets

E NO.: 09-CV-80656-MARRA/JOHNSON I PLAINTIFF, C.M.A.'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 GLORIA C.

ty must allege a specific mental or psychiatric disorder or intend to offer expert testimony to support their claim of emotional distress. Turner v Imperial Stores, 161 F.R.D. 89 (S.D.Cal. 1995). The evidence sought is also protected under the substantive privacy rights recognized in Florida Statute §§90.503 an

pposition to Plaintiff, Carolyn Margaret Andriano's Motions For Protective Order Regarding Treatment Records From Parent-Child Center, Inc. And Dr. Serge Thys, Records Of Dominique Hyppolite/School District Of Palm Beach County, Good Samaritan Hospital, St, Mary's Hospital 2 Florida Atlantic University And

ental or psychiatric disorder or intend to offer expert testimony to support their claim of emotional distress." (DE 207) Plaintiff cites Turner v. Imperial Stores, 161 F.R.D. 89 (S.D. Cal. 1995); however, that case dealt primarily with compelling the mental examination of a patient, not the production of recor

f Defendant's Reasonable Expenses (D.E. 54). EPSTEIN is seeking from Plaintiff the production of certain treatment records of hers from the and Dr. Serge Thys 8. Neither the treatment records from th nor■ will have any relevance whatsoever in the event that Plaintiff pursues only those statutory damage

ty must allege a specific mental or psychiatric disorder or intend to offer expert testimony to support their claim of emotional distress. Turner v Imperial Stores, 161 F.R.D. 89 (S.D.Cal. 1995). The evidence sought is also protected under the substantive privacy rights recognized in Florida Statute §§90.503 an

through her undersigned attorneys, hereby files her Motion For Protective Order Regarding Treatment Records From Parent-Child Center, Inc. and Dr. Serge Thys and Incorporated Memorandum of Law, and in support there of states as follows: 1. This is an action to recover money damages against Defendant, J

ty must allege a specific mental or psychiatric disorder or intend to offer expert testimony to support their claim of emotional distress. Turner v Imperial Stores, 161 F.R.D. 89 (S.D.CaI. 1995). The evidence sought is also protected under the substantive privacy rights recognized in Florida Statute §§90.503 an