Epstein Secrets

." In fact, she stated in her interview with Dr. Kliman that her parents divorced when she was three (3)

l for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Be

regnancies with Vinyard that ended in three abortions, which she failed to disclose to various physicians, including her own psychiatric expert, Dr. Kliman, and which she admitted caused her more emotional trauma than her encounters with Mr. Epstein (id. at 299-306); and (4) arrests, including a recent

sel for Plaintiff in Related Case No. 08804 08- 801-585-6833 Fax [email protected] Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F [email protected] Counsel for Plaintiff in Re

regnancies with Vinyard that ended in three abortions, which she failed to disclose to various physicians, including her own psychiatric expert, Dr. Kliman, and which she admitted caused her more emotional trauma than her encounters with Mr. Epstein (id. at 299-306); and (4) arrests, including a recent

oldkuvin.com Counsel for Plaintiff in Related Case No. 08804 08- [email protected] Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F [email protected] Counsel for Plaintiff in Re

regnancies with Vinyard that ended in three abortions, which she failed to disclose to various physicians, including her own psychiatric expert, Dr. Kliman, and which she admitted caused her more emotional trauma than her encounters with Mr. Epstein (id. at 299-306); and (4) arrests, including a recent

oldkuvin.com Counsel for Plaintiff in Related Case No. 08804 08- [email protected] Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F [email protected] Counsel for Plaintiff in Re

ected to past sexual history (whether consensual or by force such as molestation or rape), although Jane Does 2 through 7's psychiatrist expert Dr. Kliman, had Jane Does 2 through 7 complete detailed questionnaires including past sexual history and then interviewed them on tape about their past sexual

Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F [email protected] Case 9:08-cv-80119-KAM

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

Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F [email protected] Counsel for Plaintiff in Re

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

l for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Be

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

l for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Be

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

enfeldt Adler Counsel for Plaintiff in Related Case No. 08-80893 Paul G. Cassell, Esq. Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. Counsel for Plaintiff in Related Case No. 08-80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. SP= 18 EFTA00725758 Counsel for

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

0893 Paul G. Ciggell, Esq. Pro Hac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 Fax cou or atnt: Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.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, Es