Epstein Secrets

academic faculty at the University of Texas, in Houston, Texas where I served as Assistant Professor and

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

es, and served as a medical consultant to the Kennedy Space Center. 7. I am a former member of the academic faculty at the University of Texas, in Houston, Texas where I served as Assistant Professor and then Associate Professor of Psychiatry and Internal Medicine, Director of Clinical Research, Direct

she has suffered personal injury including mental, psychological and emotional damage. 13. Plaintiff's counsel has retained an expert witness, Dr. Kliman of the Psychological Trauma Center, a division of Preventive Psychiatry Associates Medical Group, Inc., of San Francisco, California, of which Gilb

iatry, White Plains, NY, October 30, 1995. 81. "A New Theory of Posttraumatic Stress Disorder," Grand Rounds, Baylor University School of Medicine, Houston, November 8, 1995. 82. "Raising IQ's in a Therapeutic Nursery: The Cornerstone Method. How it works as illustrated by video clips of the therapist

heir real names would create a substantial risk to them of further psychological harm. See Exhibit "A", Declaration of Gilbert Kliman, M.D. 4. Dr. Kliman opines as follows: Releasing names of the plaintiffs to the public will reenact experiences of powerlessness and helplessness in the face of a boun