Epstein Secrets

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

s Order. Plaintiffs have otherwise worked cooperatively with Defendant in providing relevant discovery. Plaintiffs' counsel initiated a draft of a HIPAA compliant protective order, which was stipulated by the parties and entered by the Court on July 2, 2009. Additionally, Plaintiffs have provided De

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

t DOC privacy procedures should be directed to the DOC Privacy Officer at . Complaints to DOC about the way DOC handles your PHI, compliance with HIPAA (see footnote, p.1 of this Notice), or if you believe your privacy rights have been violated must be filed as Offender Grievances pursuant to Rule 3

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

t DOC privacy procedures should be directed to the DOC Privacy Officer at . Complaints to DOC about the way DOC handles your PHI, compliance with HIPAA (see footnote, p.1 of this Notice), or if you believe your privacy rights have been violated must be filed as Offender Grievances pursuant to Rule 3