r Plaintiff allowed Defendant to use her name in third party subpoenas, Defendant served subpoenas on: a. Palm Beach County School District b. Dr. Serge Thys c. Parent/Child Center d. Good Samaritan Hospital e. St. Mary's Hospital f. Dr. Gloria C. Hakkarinen g. Florida Atlantic University CMA then f

E NO.: 09-CV-80656-MARRA/JOHNSON I PLAINTIFF, C.M.A.'S, MOTION FOR PROTECTIVE ORDER REGARDING TREATMENT RECORDS FROM PARENT-CHILD CENTER, INC, DR. SERGE THYS, DOMINIQUE HYPPOLITE/SCHOOL DISTRICT OF PALM BEACH COUNTY, GOOD SAMARITAN HOSPITAL, ST. MARY'S HOSPITAL, FLORIDA ATLANTIC UNIVERSITY AND GLORIA C.

pposition to Plaintiff, Carolyn Margaret Andriano's Motions For Protective Order Regarding Treatment Records From Parent-Child Center, Inc. And Dr. Serge Thys, Records Of Dominique Hyppolite/School District Of Palm Beach County, Good Samaritan Hospital, St, Mary's Hospital 2 Florida Atlantic University And

. 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 Records From Palm Beach

in Opposition to Plaintiff, Carolyn Margaret Andriana's Motion for Protective Order Regarding Treatment Records From Parent-Child Center, Inc., Dr. Serge Thys, Records of Dominique Hyppolite/School District of Palm Beach County, Good Samaritan Hospital, St. Mary's Hospital, Florida Atlantic University and

SON 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 Motion for Protective O

REGARDING THE DEPOSITIONS OF SUSAN POPE AND DR. SERGE THYS THIS CAUSE is before the Court upon Plaintiff C.M

of 6 Opposition to Plaintiff, Carolyn Margaret Andriano's Motion for Protective Order Regarding Treatment Records From Parent-Child Center, Inc. Dr. Serge Thys, Records of Dominique Hyppolite/School District of Palm Beach County, Good Samaritan Hospital, St. Mary's Hospital, Florida Atlantic University and

ws: 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 be used to preclud

et 08/11/2009 Page 3 of 6 4 Affidavit of Plaintiff (D.E. #213); Plaintiff CMA’s Emergency Motion for Protective Order Regarding the Deposition of Serge Thys (D.E. #245); and, Plaintiff’s Request for Emergency Hearing on Plaintiff’s Motion for Protective Order (D.E. #250). Having reviewed the pleadings fil

na. However, on June 5, 2009, Plaintiff then filed a Motion for Protective Order Regarding Treatment Records From Parent-Child Center, Inc. and Dr. Serge Thys (DE 114). On June 17, 2009, Plaintiff filed a subsequent Motion for Protective Order Regarding Treatment Records From Palm Beach County School Dist

ition of the following records custodians (Attached hereto as Exhibit "A"): A. Dominique Hyppolite, School District of Palm Beach County; B. Dr. Serge Thys; EFTA00201401 Case 9:08-cv-80811-KAM Document 121 Entered on FLSD Docket 06/17/2009 Page 2 of 6 vs. Epstein, et al. Case No.: 08-CV-80811-CIV

f Defendant's Reasonable Expenses (D.E. 54). EPSTEIN is seeking from Plaintiff the production of certain treatment records of hers from the and Dr. Serge Thys 8. Neither the treatment records from th nor■ will have any relevance whatsoever in the event that Plaintiff pursues only those statutory damage

is case; and state as to each the date of treatment or examination and the injury or condition for which you were examined or treated. ANSWER Dr. Serge Thys (Psychiatrist) 2151 45th Street West Palm Beach, FL. 33407 Date: I do not recall the date. I would defer to the Doctor's records. Susan Pope (Co

ion 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 High school records Medical records from Florida Atlantic University Community Wellness Center 09/01/09 Telephone conference with Attorney Pi

Epstein Matter Depositions Currently Scheduled as of August 25, 2009 Plaintiff Deponent Date and Time Location Remarks Dr. Serge Thys * 8/31/09, 3:15pm Our Office Our Office 9/01/09,11:OOam Esquire Court Rep One Penn Plaza Suite 4715 New York, NY10019 Noticed by Kuvin By v

stein Matter Depositions Currently Scheduled as of September 3, 2009 Plaintiff Deponent Date and Time Location Noticed By/Court Reporter Dr. Serge Thys * (COMPLETED) 8/31/09, 3:15pm Dr. Thys' office Noticed by us . Jeffrey Epstein * By Video (COMPLETED)? 9/02/09,10:OOam Atterbury,Goldberger

Epstein Matter Depositions Currently Scheduled as of August 18, 2009 Plaintiff Deponent Date and Time Location Remarks Dr. Serge Thys * 8/31/09, 3:15pm Our Office Our Office 9/01/09,11:00am Esquire Court Rep One Penn Plaza Suite 4715 New York, NY10019 Noticed by Kuvin By v

Epstein Matter Depositions Currently Scheduled as of August 18, 2009 Plaintiff Deponent Date and Time Location Remarks Dr. Serge Thys * 8/31/09, 3:15pm Our Office Our Office 9/01/09,11:OOam Esquire Court Rep One Penn Plaza Suite 4715 New York, NY10019 Noticed by Kuvin By v

ion 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 High school records Medical records from Florida Atlantic University Community Wellness Center 09/01/09 Telephone conference with Attorney Pi