Epstein Secrets

from Plaintiff’s forensic psychiatric expert, Dr. Kliman, including videotaped interviews of Plaintiffs,

provided to and used by the Defendant’s expert, Richard C.W. Hall, M.D.2 Defendant therefore is not by any stretc

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

Jane -qoe_ #~ v_ Jeffrey Epstein AFFIDAVIT OF RICHARD C.W. HALL, M.D. STATE OF FLORIDA COUNTY OF SEMINOLE On t

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

nsic 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 therefore is not by any stretch being unreasonably delayed or thwarted in obtaining nonparty discovery through the rules of civil p

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

cally, with regard to Jane Doe No. 4, which is the deposition set for next week, September 16, 2009, the plaintiff has in her past (see affidavit of Richard C.W. Hall, M.D., an expert psychiatrist retained by Defendant to conduct exams on various claimants.) Exhibit "5" A. Sought counseling due to a dysfunctiona

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

cally, with regard to Jane Doe No. 4, which is the deposition set for next week, September 16, 2009, the plaintiff has in her past (see affidavit of Richard C.W. Hall, M.D., an expert psychiatrist retained by Defendant to conduct exams on various claimants.) aet Exhibit "5" A B. C. EFTA00182048 Case 9:08-cv