Epstein Secrets

CASE NO.: 08-CV-80119-MARRA-JOHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. I ------------- Related Cases: 08

9-81092. I ------------- SEP 11 2009 Defendant Epstein's Emergency Motion To Strike Plaintiff's Motion F

specifically stated that "Please be advised that Mr. Epstein plans to be in attendance at the deposition of yo

9-80802, 09-81092. I ------------- SEP 11 2009 Defendant Epstein's Emergency Motion To Strike Plaintiff's Motion F

And Emergency Motion To Allow The Attendance Of Jeffrey Epstein At The Deposition Of Plaintiffs And Respo

oup, Inc., of San Francisco, California, of which Gilbert W. Kliman, lv.lD, is the medical director. Dr. Kliman's in

Aug 04 09 04:58p Richard C. Hall, MD 407-322-8169 p.22 Jane Doe #6 v. Jeffrey Epstein AFFIDAVIT OF RICHARD C.W. HALL M.D. STATE OF FLORIDA COUNTY OF SEMINOLE On this day personally appeared before me, the undersigned authority, Ric

c injuries, including mental, psychological, and emotional damages. 11. She alleges the intentional infliction of emotional distress and that Mr. Epstein's conduct caused severe emotional distress, severe mental anguish and pain. 12. She further alleges that she has suffered personal injury including

cords indicate the following concerning Jane Doe #6. 14. Plaintiff's interrogatories note a diagnosis of PTSD following an auto accident in 2003. (Pre-Epstein) (Page 5, Plaintiff's Answers to Defendant's First Interrogatories) 15. Plaintiff noted "nervous about driving here. Hit by a semi June 2003.1 wasn

school by four girls and allegedly battered by two of the girls subsequent to a verbal conflict at school. (Police Offense Report) 25. "I met Mr. Jeffrey August 2004.. . I was between repeating sixth grade. ...I was not yet 14. an. came to my house to get me to go and we called a cab to go to Jeffrey'

, and had had suicidal ideation prior to meeting Mr. Epstein. For further elaboration of her history and back

iman of the Psychological Trauma Center, a division of Preventive Psychiatry Associates Medical Group, Inc., of San Francisco, California, of which Gilbert W. Kliman, MD, is the medical director. Dr. Kliman's initial records indicate the following concerning Jane Doe #6. 14. Plaintiff's interrogatories note a d

Case 9:08-cv-80119-KAM Document 247 Entered on FLSD Docket 08/05/2009 Page 1 of 19 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-cv-80119-MARRA/JOHNSON ----------~! JANE DOE NO. 3, CASE NO.

9-80656-CIV-MARRA/JOHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. __________ ___,! Reply To Plaintiffs', Jane Does 2-7, Response In Opposition To Epstein's Motion To Compel And/Or Identify Jane Does In The Style Of This Case And Motion To Identify Jane Doe In Third-Party Subpoenas For Purposes Of Dis

m Of Law (the "Motion to Identify"). In support, Mr. Epstein states as follows: I. Introduction 1. Prior t

amended complaints filed by Jane Does 2-7 against Jeffrey Epstein make allegations of sexual assault and a

nditions and were not highlighted for the court in Plaintiffs' expert's affidavit attached to Plaintiffs' Opposition Motion (i.e., the Affidavit of Gilbert W. Kliman, M.D.). Instead of addressing each Jane Doe individually and highlighting their past experiences prior to Epstein (which are obviously relevant to

Plaits & Testimony DECLARATION OF GILBERT KLIMAN, M. D. June 4,2009 RE: EXPECTATION OF HARM FROM DISCLOSING THE PLAINTIFFS' IDENTITIES IN DOES V JEFFREY EPSTEIN 1. I, Gilbert W. Kliman, M.D., of 2105 Divisadero Street, San Francisco, California, CA. Physicians License G55912, declare the following under pen

d in part to adolescent aspects of psychology. 5. The plaintiffs do not hold their heads high with pride for having been sexually controlled by Mr. Epstein. They hold their heads low with shame. The internal life of a typical adolescent, into late adolescence and early adult years in the best of circum

DISCLOSING THE PLAINTIFFS' IDENTITIES IN DOES V JEFFREY EPSTEIN 1. I, Gilbert W. Kliman, M.D., of 2105 D

ith pride for having been sexually controlled by Mr. Epstein. They hold their heads low with shame. The intern

ocket 06'08/2009 Page 1 of 5 The Psychological Trauma Center a division of Preventive Psychiatry Associates Medical Group, Inc. Medical Director: Gilbert W. Kliman, M. D. 2105 Divisadero St.. San Francisco. CA 94I IS Phonc (415)292.7I 19 Fax (415) 749.2802 Will..exuenehridasychiatn , corn Forensic Child Psy

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-cv-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN Defendant. CASE NO.: 08-CV-80380-MARRA/JOHNSON

s Of Discovery, Or Alternatively, Motion To Dismiss Sua Sponte, With Incorporated Memorandum Of Law 3 EFTA00725743 Defendant, JEITREY EPSTEIN ("Epstein" or "Defendant"), by and through his undersigned attorneys, hereby files his Reply to Plaintiffs', Jane Does 2-7, Response in Opposition to Epstein

NO.: 08-cv-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, CASE NO.: 0

m Of Law (the "Motion to Identify"). In support, Mr. Epstein states as follows: I. Introduction 1. Prior t

nditions and were not highlighted for the court in Plaintiffs' expert's affidavit attached to Plaintiffs' Opposition Motion (i.e., the Affidavit of Gilbert W. Kliman, M.D.). Instead of addressing each Jane Doc individually and highlighting their past experiences prior to Epstein (which are obviously relevant to