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ane Does 2-8, attempt to use the Affidavit of Dr. Kliman for every motion for protective order/objection
y, in Jane Doe II, the state court case, attorney Sid Garcia took the deposition of the Defendant and his cli
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
is conducted in this case and how this court has historically governed discovery. 9. Interestingly, in Jane Doe 11, the state court case, attorney Sid Garcia took the deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition. This is despite her claims of "emotional t
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
is conducted in this case and how this court has historically governed discovery. 9. Interestingly, in Jane Doe II, the state court case, attorney Sid Garcia took the deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition. This is despite her claims of "emotional t
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
is conducted in this case and how this court has historically governed discovery. 9. Interestingly, in Jane Doe II, the state court case, attorney Sid Garcia took the deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition. This is despite her claims of "emotional t
Entities connected to both Kliman and Sid Garcia

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSONJack Goldberger
PERSONScott Rothstein
PERSONRobert C. Josefsberg
PERSON
Paul Cassell
PERSONRichard Horace Willits
PERSONRobert D. Critton
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSONKatherine W. Ezell
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSONJack Patrick Hill
PERSONMermelstein & Horowitz
ORGANIZATIONIsidro Manuel Garcia
PERSONJack Scarola
PERSON
Lake Worth
LOCATIONRothstein Rosenfeldt Adler
ORGANIZATION