reexisting. = THE COURT: And why do you have it in your expert's report? MS. SCHULTZ: Well, our expert is -- I'm assuming you're referring to Dr. Kliman, who is a physician. He's a medical doctor. He took a full -- THE COURT: There's a whole thing about it. Are you going to withdraw the -- MS. SCHUL

A”, Declaration of Gilbert Kliman, M.D. 4. Dr. Kliman opines as follows: Releasing names of the plaint

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

from Plaintiff’s forensic psychiatric expert, Dr. Kliman, including videotaped interviews of Plaintiffs,

they assert against Jeffrey Epstein in their respective Complaints.(DE 226) Plaintiff's Motion for Protective Order attached the Affidavits of Dr. Kliman - Ex. "A," the Declaration of Jane Doe 4 - Ex. "B," and the Declaration of Jane Doe 6 - Ex. "C". Case 9:08-cv-80119-KAM Document 277 Entered

e 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 Exhibit "A". In addition, on 9/20/04, a battery report was filed

he Plaintiffs are fragile young adults who have been traumatized as a result of one or more sexual assaults by Jeffrey Epstein. See Affidavit of Dr. Kliman (attached as Exhibit “A” to D.E. 226). Since the filing of this lawsuit, Jeffrey Epstein has continued to harass and intimidate the Plaintiffs th

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

th a message of any sort from you, is that clear? 1 Jane Doe’s 2-8 have filed an affidavit of Dr. Kliman attesting to the psychological harm that they will suffer if Epstein is allowed to intimidate them by attending their deposition. Jane Doe is prep

1 Jane Doe’s 2-8 have filed an affidavit of Dr. Kliman attesting to the psychological harm that they wi

D. In fact, she stated in the interview with Dr. Kliman that Mr. Vinyard was not a good influence on her

interview with attorney's handpicked expert, Dr. Kliman, by her own comments, her significant emotional

2 Protective Order as to Jeffrey Epstein’s Attendance at Deposition of Plaintiffs, and Incorporated Memorandum of Law (D.E. 292); Affidavit of Dr. Kliman (D.E. 223, Exh. A). 2. On September 16, 2009, Jeffrey Epstein’s conduct reached a new low when he recklessly violated (i) this Court’s No-Contact

k. In fact, she stated in the interview with Dr. Kliman that her mother was severely injured and the air

." In fact, she stated in her interview with Dr. Kliman that her parents divorced when she was three (3)

t age eleven and at age fifteen (15) she was reped by her best friend's boyfriend's brother. See Exhibit "B" At age twelve, Jane Doe #3 informed Dr. Kliman that she was molested at a friend's house by Kevin Hoebee. This incident was also reported to the Royal Palm Beach Police Department. See Exhibit

ent with the police. See Supra. 6. Now after obtaining a lawyer and in an attempt to recover millions of dollars, Jane Doe #7 told her expert, Dr. Kliman that during her second visit to Epstein's, she took off her shirt and gave him a massage in her bra. She then tells Dr. Kliman that either on the l

ected to past sexual history (whether consensual or by force such as molestation or rape), although Jane Does 2 through 7's psychiatrist expert Dr. Kliman, had Jane Does 2 through 7 complete detailed questionnaires including past sexual history and then interviewed them on tape about their past sexual

ected to past sexual history (whether consensual or by force such as molestation or rape), although Jane Does 2 through 7's psychiatrist expert Dr. Kliman, had Jane Does 2 through 7 complete detailed questionnaires including past sexual history and then interviewed them on tape about their past sexual

t had to do with Epstein." See Exhibit "B" 5. Prior to any contact with Epstein, Jane Doe #5, while in her young teens, admits to her expert, Dr. Kliman, that her mother told her that she (the mother) was molested by an uncle, raped twice, and caught her father (Jane Doe #5's grandfather) having sex