Epstein Secrets

.A. 250 S. Australian Avenue Suite 1400 West Palm Beach, FL 33401 561-202-6360 Fax: 561-828-0983 [email protected] Counsel/or Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Leopold-Kuvin, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 561-684-6500 Fax:

@brucereinhartlaw.com Counsel/or Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq

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

ric examination in C.M.A. v. Jeffrey Epstein and Sarah Kellen (Case No. 08- CIV -80811 ), as to time, subject m

xamination in C.M.A. v. Jeffrey Epstein and Sarah Kellen (Case No. 08- CIV -80811 ), as to time, subject m

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

ourt inspect the documents in camera in order to assess whether, in fact, continued closure is proper. 3 See, e.g.. "Defendants Jeffrey Epstein and Sarah Kellen's Motion for Stay," C.M.A. v. Epstein, Case No. 08-80811 (S.D. Fla. July 25, 2008) (filed publicly Jan. 7, 2009). 09/12/2079 CONFIDENTIAL Agency to

See, e.g.. "Defendants Jeffrey Epstein and Sarah Kellen's Motion for Stay," C.M.A. v. Epstein, Case No.

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