Case Document Entered on FLSD Docket Page of Aug o,Qan;e4:J5 iB-cv-8fD lcl HclcMIJment Entered on FLSD rn9ll fol3 Pagg of medical degree from the University of Florida College of Medicine Gainesville Florida I served as a Lieutenant Commander in the United States Navy where I researched and evaluated biological and neurochemical factors associated with the onset of psychiatric disorders and served as a representative to the Joint Services Task Force planning Operation Homecoming the return of POWs from Vietnam I have previously served as an assistant clinical professor at the University of South Florida College of Medicine direct.ed one of the ten model mental health centers in the United States and served as a medical consultant to the Kennedy Space Center I am a former member of the academic faculty at the University of Texas in Houston Texas where I served as Assistant Professor and then Associate Professor of Psychiatry and Intern.al Medicine Director of Clinical Research Director of Residency Training Chief of the Consultation/Liaison Service and Chief Psychiatrist at the M.D Anderson Cancer Hospital in Houston I also have served as a Professor of Internal Medicine and Psychiatry at the Medical College of Wisconsin where I was appointed Chief of Psychiatry at the Milwaukee County and Froedtert Hospitals In addition I have served as a Professor of Psychiatry and Internal Medicine and Associate Dean at the University of Tennessee College of Medicine Memphis The amended complaint filed by Jane Doe against Jeffrey Epstein makes Case Document Entered on FLSD Docket Page of Aug ei4J MltrK HdID.mlOlment Entered on FLSD Pag of sensitive allegations of sexual assault and abuse upon a minor and seek damages in excess of million Jane Doe alleges confusion shame humiliation embarrassment and severe psychological and emotional injuries It is further alleged that she suffered and will continue to suffer severe and permanent traumatic injuries including mental psychological and emotional damages She alleges the intentional infliction of emotional distress and that Mr Epsteins conduct caused severe emotional distress severe mental anguish and pain She further alleges that she has suffered personal injury including mental psychological and emotional damage Plaintiffs counsel has retained an expert witness Dr I liman of the Psychological Trauma Center a division of Preventive Psychiatry Associates Medical Group Inc of San Francisco California of which Gilbert Kliman MD fa the medical director Dr Kilman initial records indicate the following concerning Jane Doe Plainti reports a history of alcohol use and an ex-boyfriend who drank alcohol and used pills that were a form of oxycodine sicJ a form of heroine sic Page tape Plaintiff reports obtaining a restraining order against her ex-boyfriend stating that he would spit in her face push her and was abusive Page tape Plaintiff reports talking with two psychiatrists at age or due to family Case Document Entered on FLSD Docket Page of Aug cv-81:libtl,!iM AM-talO MJl.iment Entered on FLSD l!i 260ffie?ilm Page64 of issues and boyfriend issues Pages and tape In the tapes she makes no mention of telling the psychiatrists of her alleged encounters with Epstein Moreover while Plaintiff denies recruiting other girls on page of the Palm Beach Police Report Plaintiff said she left a note for Epstein that indicated for a good time call Plaintiff and friend and left the girls phone numbers Plaintiff noted that while in high school a friend Chris died in a motor vehicle accident that she was in shock from his death and that she got overit after aboutl to years but that it still bothers her Page GK Contemp notes Plaintiff noted that a close friend Jen died in a motor vehicle accident and that she was in shock for two months Page GK Contemp notes Plaintiff reported I probably went there over times Page tape Plaintiff was arrested at age for DUI on Police Offense Report On fight occurred between plaintiff and Preston in back of cab Plaintiff age had been drinking Police were called for theft of cab fare Upon arriving at residence police found plaintiff in home with no shirt on Plaintiff refused to cooperate with police and threatened to kill herself as arrested for violation of protective order Police Offense Report On plaintiff was charged with shoplifting bras from Burdines and was issued a juvenile referral form Police Offense Report Case Document Entered on FLSD Docket Page of Aug o!Coo;eH9JCM,l-cv-80JU al!JlcMCiment Entered on FLSD Page2s of 2S On a protective order was filed against Preston after an incident on in which he accused her of cheating on hlm He then began choking her threw her against a wall and yelled at plaintiff He dumped beer on her threw cigarettes in her face and slammed her into the ground On a previous incident in August plaintiff reported they agued and Mr grabbed her by her arms and threw her to the ground outside her house Plaintiff noted she was in fear because he has a violent history and has verbally threatened her friends family and herself Petition for Injunction for Protection All of ihe above show that this plaintiff crone from an unstable and disturbed home had been subject to previous physical and sexual abuse was fearful isolated and had had suicidal ideation prior to meeting Mr Epstein For further elaboration of her history and background access to all available records is crucial if one is to fully understand the impact of any of these events on her subsequent behavior and proportion the impact of specific events if any or her current and future level of function In Dr Kliman initial replenishment retainer agreement and fee schedule date in a heading entitled Regarding Full Disclosure Dr Kilman notes that prior to deposition counsel will make every effort necessary to provide experts with information requested by the experts including a list of all depositions statements declarations and motions in the case a copy of any requested items and most Case Document Entered on FLSD Docket Page of Aug OOJ!l cv-8 c1!ilfl A:f AHq ddQment Entered on FLSD d8c PagElt of importantly ill of all medical clinical school fil1d work records known to the attorney in the case Dr Kliman notes on page of his contract opinion formation that he will not form opinions give reports or testify in certain circumstances These include circumstances where he has reason to believe a retaining attorney has available im1;2ortant and relevant documents which are being deliberately withheld from lliJ We define such as documents in possession of retaining attorney which we have requested or that we have stated would ordinarily b.sl 12.atl of medical opinion formation on the topics concerning which our input is requested We request t.h same It is critical for an IME exammer to be able to make a cogent assessment of any plaintiff and to understand their medical social academic psychological and psychiatric condition/state prior to any act of alleged victimization There are a number of variables that combine to determine the effects of such alleged victimization including the type and character of the alleged assault and key victim variables such as demographics psychological reactions at the time of the trauma previous psychiatric or psychological history history of previous vicl:imi7..ation current or previous psychological difficulties general personality dynamics and coping style sociocultural factors such as drug use/abuse poverty socialinequity and/or inadequate social support any previous history of abuse within or outside the family whether individuals were abused by strangers Case Document Entered on FLSD Docket Page of Aug li1 tll-cv-80 fflx 256cMQment Entered on FLSD 9cRl Pagif7 of acquaintances or family members and whether there was any history of indiscriminate behavior that may have placed them at increased risk I tis important to know if there had been previous sexual conduct contact with police or welfare agencies alcohol or dtug use/abuse voluntary sexual activity contraceptive use genital infections or apparent indifference to previous abuse It is also essential to understand the plaintiffs level of emotional support whether any significant psychiatric illnesses were pre ent whether they were taking any medications prescribed or non-prescribed whether there had been previous suicide attempts thoughts plans etc Knowledge of plaintiffs relationships to her family and familial factors including social disadvantage family instability impaired parent/child relationship and parental adjustment difficulties is also critical tis therefore crucial that the independent medical examiner has available to him a full and complete record that includes medical previous legal social criminal academic psychological and psychiatric reco:i:ds/data psychological tests laboratory tests and clinical hospital physician records These in essence are the same or similar records that plaintiffs expert witness Dr Kliman feels are essential him to do an appropriate evaluation To obtain the necessary information it will be necessary to identify the plaintiff by name Such Case Document Entered on FLSD Docket Page of Aug Dtffi B-cv-8di"rnIRAMH1Jo ment a ere on FLSD DocRet PagKl:l of identification will not humiliate the plamtiff since all we are requesting is pertinent information as noted above relative to their past medical and psychiatric histories and conduct We would concur and request of the court that the same and/or similar information be made available to us to conduct our examination Respectfully submitted Sz a Courtesy Oinical Professor of Psychiatry University of Florida College of Medicine Affiliate Professor Department of Psychiatry and Behavioral Medicine University of South Florida Prowssor of Psychiatry Department of Medical Education University of Central Florida O:,llege of Medicine STATE OF FLORIDA COUNTY OF SEMINOLE BEFORE ME the undersigned authority personally appeared RICHARD HALL M.D who is personally known to me or who has produced as identification and who did take an oath deposes and says that the attached Affidavit is true and correct to the best of his knowledge and belief dayof A"v.,r ti IHHf!M MARCIA.I.CHAPMAN COlnnllf i E,cplioo Florfda Notary Assn lni 225unu 225unhnhu,1 No-ryPublic Printed Name Mt.t IA 4.fi i lV My Commission Expires
