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interview with attorney's handpicked expert, Dr. Kliman, by her own comments, her significant emotional
n behalf of C.M .. A., Adam Langino on behalf of B.B., William Berger on behalf of three Plaintiffs wer
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
d his partner, Mr. Luttier, had a court reporter and a videographer present. Additionally, Mr. Hill on behalf of C.M..A., Adam Langino on behalf of B.B., William Berger on behalf of three Plaintiffs were present for the deposition. 3 09/12/2019 Page CONFIDENTIAL Agency to Agency Requet 19-411 SDN
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
nd his partner, Mr. Luther, had a court reporter and a videographe• present. Additionally, Mr. Hill on behalf of C.M..A., Adam Langino on behalf of B.B., William Berger on behalf of three Plaintiffs were present for the deposition. 3 EFTA00182036 Case 9:08-cv-80119-KAM Document 305 Entered on FL
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
nd his partner, Mr. Luther, had a court reporter and a videographe• present. Additionally, Mr. Hill on behalf of C.M..A., Adam Langino on behalf of B.B., William Berger on behalf of three Plaintiffs were present for the deposition. 3 EFTA01625667 Case 9:08-cv-80119-KAM Document 305 Entered on FL
Entities connected to both Kliman and B.B.

Jeffrey Epstein
PERSONJack Goldberger
PERSONSpencer Kuvin
PERSON
Bradley Edwards
PERSONRobert D. Critton
PERSON
George W. Bush
PERSONScott Rothstein
PERSONJane Doe
PERSON
Palm Beach Gardens
LOCATIONMichael J. Pike
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSONRobert C. Josefsberg
PERSONRichard Horace Willits
PERSONKatherine W. Ezell
PERSONBruce E. Reinhart
PERSON
Adam D. Horowitz
PERSONLeopold-Kuvin
ORGANIZATIONGoldberger & Weiss
ORGANIZATION