Epstein Secrets

examination of the Plaintiff has been made with Richard C.W. Hall, M.D. of Richard C.W. Hall, M.D., P.A. at 9:00 a.

[email protected] Co-counsel for Plaint/ff Jane Doe Case 9:08-cv-80119-KAM Document 459 Entere

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

one of the individuals apparently interviewed by Epstein's investigators; however, Plaintiff does not state that the investigators have identified Jane Doe 7 as a Plaintiff in this lawsuit. Defendant expects that in light of this court's recent order (DE 253) that Plaintiff will speciously amend her decla

laintiffs have experienced several incidents in their lives which affected them emotionally and psychologically. See ~-, Exhibit "D", Affidavit of Richard C.W. Hall, outlining the psychological issues experienced by Jane Doe 4 as a result of incidents in her life prior to Epstein, which cannot be discounted. As

fected them emotionally and psychologically. See ~-, Exhibit "D", Affidavit of Richard C.W. Hall, outlining the psychological issues experienced by Jane Doe 4 as a result of incidents in her life prior to Epstein, which cannot be discounted. As such, Plaintiffs should not, once again, be able to "handpic

e Plaintiff for an independent/psychological medical examination and states: 1. An appointment for examination of the Plaintiff has been made with Richard C.W. Hall, M.D. of Richard C.W. Hall, M.D., P.A. at 9:00 a.m. on March 1, 2010 at the offices of Richard C.W. Hall, M.D., 2500 West Lake Mary Blvd., Suite #21

591, 09-80656, 09-80802, 09-81092 --------------~/ DEFENDANT'S RE-NOTICE (DATE & LOCATION CHANGE) OF INDEPENDENT MEDICAL EXAMINATION OF PLAINTIFF, JANE DOE #7 (80993) Defendant, JEFFREY E. EPSTEIN, pursuant to Rule 35, Fed. R. Civ. P., notices the Plaintiff for an independent/psychological medical exa

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

the Defendant’s Motion to Compel and/or Identify Jane Doe et al. (DE 253). The Defendant’s Case 9:08-cv-8

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

ion for No-Contact Order (DE 113) and Plaintiffs Jane Does' 2-7 Notice of Joinder in Plaintiffs' Motion (DE

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

into the Plaintiffs' claims. The private investigators' activities, some of which have been documented through the Declarations of Jane Doe No. 4,1 Jane Doe No. 6, Jane Doe No. 7 and Jane Doe No. 4's sister, Y.B., are not intended to receive information from relevant witnesses, but rather to give informa

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

N Defendant. Plaintiff. JEFFREY EPSTEIN Defendant. CASE NO.: 08-80993-CIV-MARRA/JOHNSON CASE NO.: 08-80811-CIV-MARRA/JOHNSON 2 EFTA00729245 JANE DOE, Plaintiff, JEFFREY EPSTEIN et al, Defendants. CASE NO.: 08-80893-C1V-MARRA/JOHNSON DOE II, Plaintiff, JEFFREY EPSTEIN et al, Defendants. CA

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

sanctions pursuant to Rule 30(dX2) aril (3)(A) and (C) (referencing Rule 37(aX5)), Federal Rules of Civil Procedure and compelling the deposition of Jane Doe No. 4 within fifteen (15) days and as grounds therefore would state: 1. On August 16, 2009, the deposition of Jane Doe No. 4 was noticed for Septe

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

has met her burden, should the Court consider adopting such extraordinary relief. On its face, the motion does not meet the necessary burden as to Jane Doe 4, or Jane Does 2, 3, 5, 6, or 7. Discussion of Law Requiring the Denial of the Requested Protective Order Rule 26(c)(1XE), Fed.R.Civ P. (2009), gove