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ane Does 2-8, attempt to use the Affidavit of Dr. Kliman for every motion for protective order/objection
the deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition. This is
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
verned 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 trauma" set forth in her complaint. Jane Doe No. 11 is also a Plai
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
ontinue to attempt to control how discovery 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.
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
ontinue to attempt to control how discovery 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.
Entities connected to both Kliman and Jane Doe II

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