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

nditions and were not highlighted for the court in Plaintiffs' expert's affidavit attached to Plaintiffs' Opposition Motion (i.e., the Affidavit of Gilbert W. Kliman, M.D.). Instead of addressing each Jane Doe individually and highlighting their past experiences prior to Epstein (which are obviously relevant to

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

oup, Inc., of San Francisco, California, of which Gilbert W. Kliman, lv.lD, is the medical director. Dr. Kliman's in

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

nditions and were not highlighted for the court in Plaintiffs' expert's affidavit attached to Plaintiffs' Opposition Motion (i.e., the Affidavit of Gilbert W. Kliman, M.D.). Instead of addressing each Jane Doc individually and highlighting their past experiences prior to Epstein (which are obviously relevant to

she has suffered personal injury including mental, psychological and emotional damage. 13. Plaintiff's counsel has retained an expert witness, Dr. Kliman of the Psychological Trauma Center, a division of Preventive Psychiatry Associates Medical Group, Inc., of San Francisco, California, of which Gilb

iman of the Psychological Trauma Center, a division of Preventive Psychiatry Associates Medical Group, Inc., of San Francisco, California, of which Gilbert W. Kliman, MD, is the medical director. Dr. Kliman's initial records indicate the following concerning Jane Doe #6. 14. Plaintiff's interrogatories note a d