revented by Plaintiff. Then, on June 5, 2009, C.M.A. filed a Motion for Protective Order Regarding Treatment Records From Parent-Child Center, Inc. (Susan Pope) and Dr. Serge Thys (DE 114, now DE 207). On June 17, 2009, Plaintiff then filed a subsequent Motion for Protective Order Regarding Treatment Reco

CV-80591-MARRA/JOHNSON CASE NO.: 09-CV-80656-MARRA/JOHNSON PLAINTIFF, C.M.A.'S, EMERGENCY MOTION FOR PROTECTIVE ORDER REGARDING THE DEPOSITIONS OF SUSAN POPE AND DR. SERGE THYS AND INCORPORATED MEMORANDUM OF LAW Plaintiff, C.M.A., by and through her undersigned attorneys, hereby files her Emergency Moti

FOR PROTECTIVE ORDER REGARDING THE DEPOSITIONS OF SUSAN POPE AND DR. SERGE THYS THIS CAUSE is before the Cour

er states as follows: In light of the Court's Order Denying Plaintiff, C.M.A.'s Emergency Motion For Protective Order Regarding the Depositions of Susan Pope and Dr. Serge Thys (D.E. 246)("Absent an amended pleading or stipulation of the parties, Plaintiff's unilateral non-binding notice of intent cannot

motion as it relates to Dr. Thys, is denied. In the same Motion at issue here, styled as an emergency, Plaintiff sought to protect the taking of Dr. Susan Pope’s deposition which was then scheduled for the following day, August 6, 2009. As Dr. Pope’s deposition was scheduled to take place the day after the

e to have a meaningful compulsory psychological examination by a defense expert. For example, Defendant's attorneys recently took the deposition of Susan Pope, who counseled Plaintiff for the last 12 years. Significantly, Susan Pope could not identify anywhere in her records from 2003 through 2009 wherein

cally, Dr. Hall would testify that Alleged Victim 4 told him that she previously disclosed other sexual abuse to a prior mental health provider, Dr. Susan Pope, but did not disclose abuse by Epstein to Dr. Pope. Def. Br. at 16.2 Further, Dr. Hall would testify that in their interview Alleged Victim 4 "did

cally, Dr. Hall would testify that Alleged Victim 4 told him that she previously disclosed other sexual abuse to a prior mental health provider, Dr. Susan Pope, but did not disclose abuse by Epstein to Dr. Pope. Def. Br. at 16.2 Further, Dr. Hall would testify that in their interview Alleged Victim 4 "did

m and friend of C.M.A. 24. Ghislane Maxwell c/o Ghislane Corp. 3580 Brillo Way Palm Beach, FL 33480 Subject matter: Associate of Epstein. 25. Susan Pope Parent Child Center West Palm Beach, FL 26. 27. Subject matter: Counselor at Parent Child Center. Palm Beach Police Department 345 South Coun

im and friend of C.M.A. 24. Ghislane Maxwell do Ghislane Corp. 3580 Brillo Way Palm Beach, FL 33480 Subject matter: Associate of Epstein. 25. Susan Pope 26. 27. Subject matter: Counselor at Parent Child Center. Subject matter: Investigator. Subject matter: Investigator. 28. Haley Robson (Ad

rds o 08/27/09 Review, annotate and highlight records 45*min Total hours 45 min Rate: S400/hour $300.00 CMA Records reviewed: Deposition of Susan Pope Medical records of St. Mary's Medical Center CV of Susan Pope Treatment records of Parent-Child Center, lnc. Medical records of Serge Thys, MD H

annotate and highlight records 45*min Total hours 45 min Rate: S400/hour $300.00 Records reviewed: Deposition of Sus Medical records o CV of Susan Pope Treatment records Medical records o High school records Medical records from 09/01/09 Telephone conference with Attorney Pike 5 min 09/01109

09 Review, annotate and highlight records 45 min Total hours Rate: $400/hour Records reviewed: Deposition of Susan Po Medical records o CV of Susan Pope Treatment records of Medical records o High school records Medical records fro 45 min 09/01/09 Telephone conference with Attorney Pike 5 min

o 3 hr 30min 08/27/09 Review, annotate and highlight records 45 min Total hours Rate: $400/hour CMA Records reviewed: 45 min Deposition of Susan Pope Medical records of St. Mary's Medical Center CV of Susan Pope Treatment records of Parent-Child Center, Inc. Medical records of Serge Thys, MD H

Judge Kenneth A. Marra on 8/4/2009. (mkz) (Entered: 08/04/2009) 08/04/2009 245 EMERGENCY MOTION for Protective Order Regarding The Depositions of Susan Pope and Dr. Serge Thys and Incorporated Memorandum of Law by C.M.A.. (Attachments: # 1 main document continued. # 2 document continued. # 3 document co