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uys [has she] been with? • Did [she] date older, rich guys? • Did [she] give massages for money? • Wh
from Plaintiff’s forensic psychiatric expert, Dr. Kliman, including videotaped interviews of Plaintiffs,
le relevance as to whether Plaintiffs gave "older-rich guys" "massages" for money and, as such, Defenda
e Doe's name. Importantly, Jane Doe #4 provided Mr. Vinyard's name to her expert, Gilbert Kliman, M.D. In fact, she stated in the interview with Dr. Kliman that Mr. Vinyard was not a good influence on her and that he was an alcoholic. See Exhibit "A". In addition, on 9/20/04, a battery report was filed
ys [has she] been with? • Did [she] date older, rich guys? • Did [she] give massages for money? •
e Court on July 2, 2009. Additionally, Plaintiffs have provided Defendant with extensive discovery from Plaintiff's forensic 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
Entities connected to both Marc Rich and Kliman

Jeffrey Epstein
PERSONDarren Indyke
PERSONLeon Black
PERSONRichard Barnett
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Woody Allen
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
John F. Kennedy
PERSON
Alfredo Rodriguez
PERSON
United States
LOCATION
Bill Clinton
PERSONMartin Weinberg
PERSON
Stephen Hawking
PERSON
Bradley Edwards
PERSON
Wilbur Ross
PERSON
Sarah Kellen
PERSON
New York
LOCATIONMaria Farmer
PERSON