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ercial sex act. Page 2 of 9 EFTA00182943 CT DATE(S) DEFENDANT(S) VICTIM(S) STATUTES/CHARGE 9 November 2004 - March 2005 --a N EPSTEIN ..NEPSTEIN Jane Doe #14 18 U.S.C. §§ 1591(aX1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaini
ravel to 358 El Brillo Way so that JEFFREY EPSTEIN could, in exchange for money, engage in lewd conduct with those minor females in order to satisfy JEFFREY EPSTEIN's prurient interests. Manner and Means 27. The manner and means by which the Defendants and other participants sought to accomplish the purpose and
ments to be made to, minor females in exchange for engaging in lewd conduct. EPSTEIN, (c) It was further a part of the conspiracy that Defendants JEFFREY a/k/a ," and other participants would ask females to recruit other minor females to engage in lewd conduct with Defendant JEFFREY EPSTEIN. (d)
the public association of their identities with Defendant Epstein and these assaults. 3. Dr. Gilbert Kliman,2 a w
ober 28, 2006 132. Lawrence LE, Viron M, Johnson JE, Hudkins A, Samples G, Kliman G: A school-based m
SISTANT UNITED STATES ATTORNEY 52 EFTA00182941 INDICTMENT SUMMARY CT DATE(S) kEFENDANT(S) VICTIM(S) STATUTES/CHARGE 1 2001 - October 2005 NEPSTEIN Jane Does 1-19 18 U.S.C. §§ 371 and 2 Conspiracy to use a facility or means of interstate commerce to persuade, induce, or entice minors to enga
m, rape, torture). Trauma of this origin has a tendency to produce more "severe or long lasting" posttraumatic stress disorder than natural events (DSM IV TR p. 464). A policy of deliberate revelation of the names of the victims would reinforce the sense of design, pattern and policy of human intentions.
records concerning Plaintiffs is the appointment of a special master, who would verify authenticity and completeness of the records. 10. Finally, Jeffrey Epstein's request that this Court order a "sua sponte" dismissal is illogical. Sua sponte means "[w]ithout prompting or suggestion; on its own motion." Black'
the private, highly sensitive and intimate facts pertaining to their sexual assaults, and the public association of their identities with Defendant Epstein and these assaults. 3. Dr. Gilbert Kliman,2 a well-known forensic psychiatrist with an expertise in the field of child trauma, has met with and ev
the public association of their identities with Defendant Epstein and these assaults. 3. Dr. Gilbert Kliman,2 a w
NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:
m, rape, torture). Trauma of this origin has a tendency to produce more "severe or long lasting" posttraumatic stress disorder than natural events (DSM IV TR p. 464). A policy of deliberate revelation of the names of the victims would reinforce the sense of design, pattern and policy of human intentions.
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
rm, rape, torture). Trauma of this origin has a tendency to produce more "severe or long lasting" posttraumatic stress disorder than natural events (DSM IV TR p. 464). A policy of deliberate revelation of the names of the victims would reinforce the sense of design, pattern and policy of human intentions.
Entities connected to both Jeffrey Epstein and DSM IV TR
Leon Black
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
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Kenneth Marra
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Paul Cassell
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New York
LOCATION
Scarlett Johansson
PERSONRobert D. Critton
PERSONRobert C. Josefsberg
PERSONMichael J. Pike
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Adam D. Horowitz
PERSONKatherine W. Ezell
PERSONRichard Horace Willits
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United States District Court
ORGANIZATIONJack Patrick Hill
PERSONIsidro Manuel Garcia
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Andrew Cuomo
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