Epstein Secrets

ations that someone would ordinarily do in the course of defending a civil case would constitute a violation of the agreement? (Ex. "A," p.34). Ms. Villafana: No, your honor. I mean, civil litigation is civil litigation, and being able to take discovery is part of what civil litigation is all about.. .. B

h assert that Epstein has undertaken any action in the civil cases that was not discussed with and approved by all Plaintiffs' attorneys (including Maria Villafana, USAO) at the June 12, 2009 hearing with Judge Marra and as set forth in the transcript (supra); and also found to be appropriate as set forth in t

ected to past sexual history (whether consensual or by force such as molestation or rape), although Jane Does 2 through 7's psychiatrist expert Dr. Kliman, had Jane Does 2 through 7 complete detailed questionnaires including past sexual history and then interviewed them on tape about their past sexual

ations that someone would ordinarily do in the course of defending a civil case would constitute a violation of the agreement? (Ex. "A," p.34). Ms. Villafana: No, your honor. I mean, civil litigation is civil litigation, and being able to take discovery is part of what civil litigation is all about.. .. B

Docket 09/23/2009 Page 7 of 13 Page 7 action in the civil cases that was not discussed with and approved by all Plaintiffs' attorneys (including Maria Villafana, USAO) at the June 12, 2009 hearing with Judge Marra and as set forth in the transcript (supra); and also found to be appropriate as set forth in th

ected to past sexual history (whether consensual or by force such as molestation or rape), although Jane Does 2 through 7's psychiatrist expert Dr. Kliman, had Jane Does 2 through 7 complete detailed questionnaires including past sexual history and then interviewed them on tape about their past sexual

t 247 Entered on FLSD Docket 08/05/2009 Page 8 of 19 defending a civil case would constitute a violation of the agreement? (Ex. "A," p.34). Ms. Villafana: No, your honor. I mean, civil litigation is civil litigation, and being able to take discovery is part of what civil litigation is all about. ...

ormed or intends to perform on Plaintiffs, thereby joining in on this organized and calculated effort to prevent discovery. In fact, it appears Dr. Kliman had each Plaintiff complete a questionnaire. Is it Plaintiffs' position as well the Defendant is not entitled to that information? 3. In fact, it

violation of the agreement? (Ex. "A," p.34). Ms. Villafana: No, your honor. I mean, civil litigation is civi

ane Does 2-8, attempt to use the Affidavit of Dr. Kliman for every motion for protective order/objection

would ordinarily do in the course of 7 EFTA00725747 defending a civil case would constitute a violation of the agreement? (Ex. "A," p.34). Ms. Villafana: No, your honor. I mean, civil litigation is civil litigation, and being able to take discovery is part of what civil litigation is all about.... B

ormed or intends to perform on Plaintiffs, thereby joining in on this organized and calculated effort to prevent discovery. In fact, it appears Dr. Kliman had each Plaintiff complete a questionnaire. Is it Plaintiffs' position as well the Defendant is not entitled to that information? 3. In fact, it

ations that someone would ordinarily do in the course of defending a civil case would constitute a violation of the agreement? (Ex. "A," p.34). Ms. Villafana: No, your honor. I mean, civil litigation is civil litigation, and being able to take discovery is part of what civil litigation is all about... But

me 50 plus visits to the Defendant's home prior to the time that she hired an attorney. Even in her interview with attorney's handpicked expert, Dr. Kliman, by her own comments, her significant emotional trauma relates to physical and verbal abuse by a prior boyfriend, Preston Vineyard, and deaths asso

gations that someone would ordinarily do in the course of defending a civil case would constitute a violation of the agreement? (Ex. "A," p34). Ms. Villafana: No, your honor. I mean, civil litigation is civil litigation, and being able to take discovery is part of what civil litigation is all about... But

n can that circumstance be addressed by a motion such as the instant one.) 11. Next, Plaintiffs, Jane Does 2-8, attempt to use the Affidavit of Dr. Kliman for every motion for protective order/objection filed to date. This also includes the two most recent motions, which attempt to prevent Defendant's