Epstein Secrets

rt C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami,

k. In fact, she stated in the interview with Dr. Kliman that her mother was severely injured and the air

61-832-7137 F [email protected] Counsel for Plaintiff in Related Case No. 08-80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 [email protected] [email protected] Counsel fo

t age eleven and at age fifteen (15) she was reped by her best friend's boyfriend's brother. See Exhibit "B" At age twelve, Jane Doe #3 informed Dr. Kliman that she was molested at a friend's house by Kevin Hoebee. This incident was also reported to the Royal Palm Beach Police Department. See Exhibit

61-832-7137 F [email protected] Counsel for Plaintiff in Related Case No. 08-80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 [email protected] [email protected] 13 Case

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

rt C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami,

D. In fact, she stated in the interview with Dr. Kliman that Mr. Vinyard was not a good influence on her

ISLAINE MAXWELL, Defendant. x June 20, 2016 9:12 a.m. CONFIDENTIAL Deposition of , pursuant to notice, taken by Plaintiff, at the offices of Podhurst Orseck, 25 West Flagler Street, Suite 800, Miami, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and

w information Plaintiff may present in her case-in-chief. Ms. Maxwell has filed well-founded motions in limine to exclude the testimony of both Dr. Kliman and Professor Coonan prohibiting from providing their credibility and vouching opinions. This is the subject matter of Dr. Esplin's rebuttal report

561.832-7137 F isidrogarcia@bellsouthoet Counsel for Plaintiff in Related Case No. 08- 80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Hagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358.2382 riosefsbetaloodhurstcom Isegellgyodhurstcom Counsel for P

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

A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 unse 80469 n elated Case No. 08- Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Hagler Street, Suite 800 Miami, FL 33130 ounse or atnt: s in Related Cases 09-80591 and 0940656 Jack Alan Goldberger, Esq. Nos.

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

1-832-7137 F isidromarciaabellsouth.net Counsel for Plaintiff in Related Case No. 08- 80469 Robert C. Josefsberg, E,sq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 riosefsbenzeoodhurst.com Itczell(apodhurst.corn Counsel

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