Epstein Secrets

Jack Scarola Florida Bar No.: Jack P. Hill Florida Bar No.: CM= Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm rida 33409 Phone: Fax: Attorneys for Plaint' 4 EFTA00201404 Case 9:08-cv-80811-KAM Document 121 Entered on FLSD Docket 06/17/2009 Page 5 o

karainen, M.D.; and F. Florida Atlantic University. 3. Plaintiff previously filed a Motion For Protective Order Regarding Treatment Records From Parent-Child Center, Inc. and Dr. Serge Thys and Incorporated Memorandum of Law (D.E. 114), which is currently pending before this Court. (Attached hereto as Exhibit "B"). P

ing its Motion to Intervene and Petition for Access before the Honorable Jeffrey Colbath, Palm Beach County Courthouse, 205 N. Dixie Hwy., Room 11F, West Palm Beach on June 10, 2009 at 10:40 a.m. or as soon thereafter as counsel may be heard. Time reserved: 10 Minutes THOMAS, LOCICERO & BRALOW PL Anna K

laintiff respectfully moves for the entry of a protective order pursuant to Fed. R. Civ. Pro. 26(c) regarding Plaintiffs treatment records from the Parent-Child Center, Inc. and Dr. Serge Thys. More particularly, Plaintiff requests the entry of an order precluding the discovery of those records until such time as the Cou

ing its Motion to Intervene and Petition for Access before the Honorable Jeffrey Colbath, Palm Beach County Courthouse, 205 N. Dixie Hwy., Room 11F, West Palm Beach on June 10, 2009 at 10:40 a.m. or as soon thereafter as counsel may be heard. Time reserved: 10 Minutes THOMAS, LOCICERO & BRALOW PL atm K.

, Plaintiff, MI, , respectfully requests that this Court enter a protective order preventing the discovery of Plaintiffs treatment records from the Parent-Child Center, Inc. and Dr. Serge Thys 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 e