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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
st Seven Hours in the Aggregate Page 3 of8 degrading names such as "whore," "slut," and "cunt" ilih at 29-30; 296-298); (3) three pregnancies 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 a
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
t on her, poured beer on her and called her degrading names such as "whore," "slut," and "cunt" (id. at 29-30; 296-298); (3) three pregnancies 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 a
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
t on her, poured beer on her and called her degrading names such as "whore," "slut," and "cunt" (id. at 29-30; 296-298); (3) three pregnancies 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 a
e Doe's name. Importantly, Jane Doe #4 provided Mr. Vinyard's name to her expert, Gilbert Kliman, M.D. In fact, she stated in the interview with Dr. Kliman that Mr. Vinyard was not a good influence on her and that he was an alcoholic. See Exhibit "A". In addition, on 9/20/04, a battery report was filed
tion of Jane Doe Number #4 9. As to Jane Doe #4' s declaration, investigators interviewed her former boyfriend, Preston Vinyard, by telephone. Mr. Vinyard commented that he knew the investigators wanted information about Jane Doe #4 without the investigators even mentioning Jane Doe's name. Importantl
ane Does 2-8, attempt to use the Affidavit of Dr. Kliman for every motion for protective order/objection
ry report was filed regarding Jane Doe No. 4 and Vinyard based on an argument where he grabbed her by the
D. In fact, she stated in the interview with Dr. Kliman that Mr. Vinyard was not a good influence on her
Doe #4 provided her former boyfriend's name, Mr. Vinyard, to her expert, Gilbert Kliman, M.D. In fact, she
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
and family issues. 17. There are police reports that reflect that: A. In September 2004, a battery report was filed regarding Jane Doc No. 4 and Vinyard based on an argument where he grabbed her by the neck and began spitting on her and calling ha a cheater. B. Also in September 2004, there was a d
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
and family issues. 17. There are police reports that reflect that: A. In September 2004, a battery report was filed regarding Jane Doc No. 4 and Vinyard bawd on an argument where he grabbed her by the neck and began spitting on her and calling her a cheater. B. Also in September 2004, there was a d
Entities connected to both Kliman and Vinyard

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSONJane Doe
PERSONJack Goldberger
PERSONMichael J. Pike
PERSONKatherine W. Ezell
PERSONJack Patrick Hill
PERSONRichard Horace Willits
PERSONRobert C. Josefsberg
PERSONIsidro Manuel Garcia
PERSON
Adam D. Horowitz
PERSONScott Rothstein
PERSONJack Scarola
PERSONMermelstein & Horowitz
ORGANIZATION
Sarah Kellen
PERSONBruce E. Reinhart
PERSONRobert D. Critton
PERSON
Lake Worth
LOCATION
Salt Lake City
LOCATION