Epstein Secrets

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

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-cv-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN Defendant. CA

e Court on July 2, 2009. Additionally, Plaintiffs have provided Defendant with extensive discovery from Plaintiff's forensic psychiatric expert, Dr. Kliman, including videotaped interviews of Plaintiffs, which have been provided to and used by the Defendant's expert, Richard C.W. Hall, M.D.2 Defendant

Document 266 Entered on FLSD Docket 08)1412009 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-8089

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

red on FLSD Docket 06/08/2009 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant.

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

t of a party's case-in- chief, and would not be allowed to testify "unless and until" the experts they were designated to rebut testified at trial); Johnson v. Grays Harbor Only. Hosp., No. C06-5502BHS, 2007 WL 4510313, at *2 (W.D.Wash. Dec. 18, 2007) (finding that experts designated as rebuttal witnesse

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

ervice List on this F te day of September 2009. 09/12/2019 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON 6 P CONFIDENTIAL Agency to Agency Requet: 19-411 SDNY_GM_00331962 EFTA 00204688 EFTA02729672 Case 9:08-cv-80119-KAM Document 305 Entered on

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

ment 114 Entered on FLSD Docket 06/05/2009 Page 8 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON VS. Plaintiff, JEFFREY EPSTEIN and Defendants. ORDER ON PLAINTIFF, C.M.A'S MOTION FOR PROTECTIVE ORDER REGARDING TREATMENT RECORDS FROM PARENT-

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

d Jane Doe 102's Motion for No-Contact Order EFTA00182031 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-8089

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

d Jane Doe 102's Motion for No-Contact Order EFTA01625662 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-8089