Case Document Entered on FLSD Docket Page of Page and that an IME is required Despite that fact and the fact that discovery has been consolidated Defendant is required to file a Rule Motion seeking an IME Thus the undersigned believes that an Omnibus Order is required relative to all Plaintiffs IMEs in that each claim similar damages and raise similar claims Such an order would conserve judicial resources and require that the attorneys only negotiate dates and times for said IMEs Nonetheless this particular Motion pursuant to Rule only addresses the IME of Jane Doe Plaintiff has alleged in her action that Defendant sexually battered her and as a result Plaintiff seeks millions of dollars in personal injury damages for among other things confusion shame humiliation embarrassment and severe psychological and emotional injuries See Second Amended Complaint DE Plaintiff Jane Doe also claims Epstein intentionally inflicted harmful or offensive contact on the person of Jane Doe creating reasonable fear of imminent peril and as a proximate result of Epsteins assault on Jane Doe she has suffered and will continue to suffer severe and permanent traumatic injuries including mental psychological and emotional damages s;L at Jane Doe further alleges that she suffered mental or sexual injury that caused or were likely to cause Jane Does mental or emotional health to be significantly impaired and Jane Doe has suffered and will continue to suffer severe mental anguish and pain s;L at i,i In addition Jane Doe 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 been in therapy with various doctors Case Document Entered on FLSD Docket Page of Page and has tried to commit suicide several times the first time occurring when she tried to cut her wrists at age eleven and at age fifteen she was reped by her best friends boyfriends brother See Exhibit At age twelve Jane Doe informed Dr Kliman that she was molested at a friends house by Kevin Hoebee This incident was also reported to the Royal Palm Beach Police Department See Exhibit all pre Epstein See Supra In addition on March Jane Doe was confronted by a male while riding her bike with friends and the male exposed and fondled himself in front of her and the others See Exhibit On June Jane Doe contacted police in reference to unknown males making obscene comments to her at her booth at the Wellington Mall See Exhibit According to the notes of Dr Korroum one of Jane Doe 3s many doctors she reports cutting herself at the age of ten or eleven being molested at age thirteen raped at age fifteen using cannabis daily using ecstasy taking Zoloft Xanax and Lexapro breaking up with her boyfriend and her parents divorce However not once does she mention the alleged abuse by Epstein as described in her complaint See Exhibit Furthermore it is important for this court to review the detailed Affidavit of Dr Hall attached hereto in that it delineates for the Court several experiences visited upon Jane Doe which may have caused the physical emotional and psychological trauma she claims occurred at the hands of Epstein See Affidavit of Dr Hall Attached hereto as Exhibit Case Document Entered on FLSD Docket Page of Page4 Based upon the foregoing it is clear that Jane Doe has placed her physical emotional medical and psychological conditions at issue Therefore an IME is warranted Without an IME Epstein would be severely prejudiced The Affidavit of Dr Hall clearly sets out the ME and scope of the examination that must be conducted See also the curriculum vitae of Dr Ryan See Exhibit The examination is set to occur at the undersigned office on November or whichever is more convenient for Plaintiff or whichever date the court so orders Plaintiff has not provided dates for the ME however out of abundance of caution and to comply with the applicable rule Defendant has on a unilateral basis set same pending the outcome of this Motion Obviously if the date noticed is not sufficient or agreeable the undersigned will renotice same for one of the four dates suggested however this Court must order same to occur As this court is well aware Plaintiff and Defendant are required to complete discovery under the Courts trial schedule It is not the undersigneds intention to require the court additional work however it is imperative that discovery be timely scheduled and completed The courts assistance is needed in this instance as to the ME Based upon the foregoing an ME of Plaintiff must occur in order to address her claims and the damages she seeks to recover The ME is expected to last between hours and the scope of same is set forth in the Affidavit of Dr Hall Pursuant to Rule Fed.R.Civ.Pro a party may move for an examination by a qualified examiner if the Plaintiffs mental/emotional and/or psychological status is at issue in a case Case Document Entered on FLSD Docket Page of Page Defendant would be severely prejudiced unless he is able to have an examination conducted by a qualified examiner separate and apart from any psychologist/psychiatrist or similar behavioral health provider who may have or may ultimately see the Plaintiff and testify in court Defendants counsel has retained the services of Richard Hall M.D and Ryan Hall M.D of C.W Hall M.D P.A located at West Lake Mary Blvd Lake Mary FL Ryan Hall M.D will be performing the examination Dr Ryan Halls specialties include forensic psychiatry general psychiatry and medical psychiatry See Exhibit attached outlining Ryan Hall M.D.s qualifications and the scope of the examination which he intends and is required to conduct in order to render a report See also Affidavit of Ryan C.W Hall M.D outlining the scope of examination and other Rule requirements Accordingly this motion comports with Rule The applicable notice has been filed simultaneously Defendant will arrange for a videotape of the examination The undersigned is requesting the courts assistance with regard to compelling the IME of Plaintiff along with dates for same to occur Rule A Certification of Pre-Filing Conference Counsel for Defendant conferred with Counsel for Plaintiff by telephone and bye mail however an agreement has not been reached WHEREFORE Defendant requests that this Court enter an Order a providing a date and time for Plaintiffs IME to occur on November or Case Document Entered on FLSD Docket Page of Page providing that the independent medical examination take place at a.m on a date to be determined by the court at the law firm of Burman Critton Luttier and Coleman LLP located at Banyan Boulevard Ste WPB Fl under the protocol set forth by Dr Hall in his affidavit by videotape and for such other and further relief as this court deems just and proper Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this day of Res itted By ROBERT CRITTON JR ESQ Florida Bar No rcrit bclclaw.com MICHAEL PIKE ESQ Florida Bar mpike bclclaw.com BURMAN CRITTON LUTTIER COLEMAN Flagler Drive Suite West Palm Beach FL Phone Fax Counsel for Defendant Jeffrey Epstein Certificate of Service Jane Doe No Jeffrey Epstein Case No 08-CV-80119-MARRA/JOHNSON Stuart Mermelstein Esq Adam Horowitz Esq Mermelstein Horowitz P.A Biscayne Boulevard Suite Brad Edwards Esq Rothstein Rosenfeldt Adler East Las Olas Boulevard Suite Fort Lauderdale FL Xx??o??V O?yN d:q s?rLJg en z?qMô I բ?x X?Px ԭΈ?9?R e?Ehu:??T?C?y yN Ӕ_ ܕlC?Vh E??E?o 8?Tζ x?A?E p?E6?t8H WM 0w s?q S?ΰ V?n/x w?u Vo ToT??J o??ya??vc c?p8 s?W R?Sv?E7 NxC r??oh?P n?1?Xn se Ӷ8R?S??uNt:P?9 x?c?tT??M uǡκn?v?K wN t9p s?F Ye C?/u Gn P?c?tT v?C R?l?K9?yC rq?Y?HM w?t9?wN?y:i N??p?S?Z i T?ﮝ?S 5Ȓi tBڹ S?u ԅL t9 M0 M5 n?v n?C ȶ??P u)ʞ r?f mis tbO R3bW5 w??lJ?i ckM Qc t9me?8 TTc nxV i t?g?P??q ҝ?E ZS i j"?J J-i?u i WE??V t8 vdz P?d Ut q?c?ǎ?Q NQiRˮ YV b?M mE 1n U?m1?z?pA ӔZS Uա pK X?ΰq?S OWk ˮ?s K?տ n?c y.p hJ V?K OP?wNˮ?e9E ߩR?p b?X adz?C?v_ vc??Vqx??8 Z?W h?Ӿ?wSճ??e ePc g?K 1?Z?ǃz eU??G?Ї _Y s?v RC?x Z?v t?uÇ Z?n?ճ?;??Ε?N㳛BO s,RXa-?Z η??ǂ Gy IbQ i?P J!HRX q? Eq?eL?A??u??ӻ yN?v wN Sۅ q?d n?C 쫱Ϲ C?U D9?P tGK 0?Pv;v RB uԢ t??e SzP?x?v eo?et??EKZ?WUu ʖYQ??w ޥ?G?UN x7 a?UV BH WN?a?ZԲz s?iac hOM?J M?v wӾ Z9 n?iR??u UR wS 2ʡb BBf Gn?79?sp E?N Xa?q vx?7t ﲺu?q QN?o?i?S?yd Gr 1?QV nn Jf J?w Wi I et 4y t?9p mbf a J?ҝ wIc KKݹ?c?t Ꭾ?q Z?dž8 H??T v?wd?އ s?O pK?s??iN?vX?i 뽇L p?G a x??C?eaj?h jFm pJt?iq??vc v?t8 o0?b UL?C??h 6G r?W s??M z?wvS?ʸ??K w4t?m om qP ڴ?(k J?C?t?rAN I??g?G 5u uJ?y Fb9??c i Xט my Z?hh!?G7 E?S??q?k Z?Q h??W 羶?q?n Kz NW uI EJ wWe B?N ZF r?z?m H?e?S??q թè?U a?8?ypc??t RD2 xi q?u a Ԭ?C T??G9?Hj G7 vyN?N HR g?Swct G?tz ȉC?WN?ˈ t?Tנ Case Document Entered on FLSD Docket Page of Page Miami FL Fax ssm sexabuseattorney.com ahorowitz sexabuseattorney.com Counsel for Plaintiffs In related Cases Nos Richard Horace Willits Esq Richard Willits P.A th Avenue North Suite Lake Worth FL Fax Counsel for Plaintiff in Related Case No reelrhw hotmail.com Jack Scarola Esq Jack Hill Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL Fax jsx searcylaw.com jph searcylaw.com Counsel for Plaintiff M.A Bruce Reinhart Esq Bruce Reinhart P.A Australian Avenue Suite West Palm Beach FL Fax ecf brucereinhartlaw.com Counsel for Defendant Sarah Kellen Phone Fax bedwards rra-law.com Counsel for Plaintiff in Related Case No Paul Cassell Esq Pro Hae Vice South Room Salt Lake City UT Fax cassellp law.utah.edu Co-counsel for Plaintiff Jane Doe Isidro Garcia Esq Garcia Law Firm P.A Datura Street Suite West Palm Beach FL isidrogarcia bellsouth.net Counsel for Plaintiff in Related Case No Robert Josefsberg Esq Katherine Ezell Esq Podhurst Orseck P.A West Flagler Street Suite Miami FL Fax rjosefsberg podhurst.com kezell podhurst.com Counsel for Plaintiffs in Related Cases Nos and Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Fax Case Document Entered on FLSD Docket Page of Page jagesq bellsouth.net Counsel for Defendant Jeffrey Epstein cc Dr Ryan Hall
