te as follows: See Exhibit “A” (Declaration of Gilbert Kliman, M.D.) (See also DE 144, Jane Does’ 2-7 Response

te as follows: See Exhibit “A” (Declaration of Gilbert Kliman, M.D.) (See also DE 144, Jane Does’ 2-7 Response

on about Jane Doe #4 without the investigators even mentioning Jane 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 Exhibi

er boyfriend's name, Mr. Vinyard, to her expert, Gilbert Kliman, M.D. In fact, she stated in the interview with D

4. In addition, Jane Doe #6 informed her expert, Gilbert Kliman, M.D that she doesn't drive, is afraid to drive

4. In addition, Jane Doe #2 informed her expert, Gilbert Kliman, M.D that she has always been a "nervous person.

oe has suffered and will continue to suffer severe mental anguish and pain." !s;L, at ,i,i 25-27. 4. In addition, Jane Doe #3 informed her expert, Gilbert Kliman, M.D that she comes from a broken family and had an abusive, alcoholic father. She further states that she has been depressed for a long time, has

oe has suffered and will continue to suffer severe mental anguish and pain." lg_,_ at ,r,r 25-27. 4. In addition, Jane Doe #5 informed her expert, Gilbert Kliman, M.D. that she is a "very depressed person inside" and is always "on edge." She indicates that as a child while in school, girls wanted and/or atte

ceived the video interviews of Plaintiffs by Dr. Gilbert Kliman, and is thus armed with a wealth of information a

she came to see Plaintiffs’ forensic expert, Dr. Gilbert Kliman, who has been retained in this case by Plaintiffs

13 of Deposition of De. sition Transcripts (ALL) November 9, 2016 Deposition of Bernard Jansen with Errata Sheet November 17, 2016 Deposition of Gilbert Kliman with Errata Sheet November 21, 2016 Deposition of Terry Coonan with Errata Sheet November 22, 2016 Deposition of with Errata Sheet November 29,

position of Expert De . sition Transcripts (ALL) November 9, 2016 Deposition of Bernard Jansen with Errata Sheet November 17, 2016 Deposition of Gilbert Kliman with Errata Sheet November 21, 2016 Deposition of Terry Coonan with Errata Sheet November 22, 2016 Deposition of Chris Anderson with Errata Sheet

13 of Deposition of Deposition Transcripts (ALL) November 9, 2016 Deposition of Bernard Jansen with Errata Sheet November 17, 2016 Deposition of Gilbert Kliman with Errata Sheet November 21, 2016 Deposition of Terry Coonan with Errata Sheet November 22, 2016 Deposition of Chris Anderson with Errata Sheet

d that public disclosure of their real names would create a substantial risk to them of further psychological harm. See Exhibit "A", Declaration of Gilbert Kliman, M.D. 4. Dr. Kliman opines as follows: Releasing names of the plaintiffs to the public will reenact experiences of powerlessness and helplessness

e, International Literary Prize including an award of one thousand dollars, for "World's Best Book Concerning the Well-Being of Children"—Awarded to Gilbert Kliman, M.D. and Albert Rosenfeld, co-authors of Responsible Parenthood published by Holt, Rinehart and Winston, New York, 1980 PUBLISHED PAPERS AND BOOK

n Please make check payable to: Richard C. W. Hall, M.D., P.A. Taxpayer ID #: Drs. Hall's time: Jane Doe #2 Records reviewed: Correspondence of Gilbert Kliman, MD Transcript of John Doe #2 v. Rabbi Yehuda Kolko et al Palm Beach Police Department Probable Cause Affidavit Billing records of Gilbert Kliman,

n Please make check payable to: Richard C. W. Hall, M.D., P.A. Taxpayer ID #: Drs. Hall's time: Jane Doe #2 Records reviewed: Correspondence of Gilbert Kliman, MD Transcript of John Doe #2 v. Rabbi Ychuda Kolko et al Palm Beach Police Department Probable Cause Affidavit Billing records of Gilbert Kliman,

d that public disclosure of their real names would create a substantial risk to them of further psychological harm. See Exhibit "A", Declaration of Gilbert Kliman, M.D. 4. Dr. Kliman opines as follows: Releasing names of the plaintiffs to the public will reenact experiences of powerlessness and helplessness