044-01.pdf

356 KB
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Extraction Summary

3
People
6
Organizations
2
Locations
2
Events
2
Relationships
5
Quotes

Document Information

Type: Legal declaration / expert witness report
File Size: 356 KB
Summary

A declaration by Dr. Gilbert Kliman, a forensic psychiatrist, arguing against the public disclosure of the identities of six plaintiffs suing Jeffrey Epstein. Kliman asserts that revealing their names would cause severe psychological harm, revictimization, and retraumatization, exacerbating their existing PTSD and depression resulting from Epstein's sexual abuse. He describes Epstein's manipulation of the victims as posing as a 'generous, avuncular mentor' to exploit their adolescent insecurities.

People (3)

Name Role Context
Gilbert W. Kliman, M.D. Author/Medical Director
Medical Director of The Psychological Trauma Center; retained as expert witness by plaintiffs to evaluate psychologic...
Jeffrey Epstein Defendant
Defendant in 'Does v Jeffrey Epstein'; described as 'perpetrator' who sexually controlled and manipulated the plainti...
Leonid Nakhodkin Notary Public
Notarized the declaration in San Francisco.

Organizations (6)

Name Type Context
The Psychological Trauma Center
Division of Preventive Psychiatry Associates Medical Group, Inc., headed by Dr. Kliman.
Preventive Psychiatry Associates Medical Group, Inc.
Parent organization of The Psychological Trauma Center.
Mermelstein & Horowitz
Plaintiffs' law firm that retained Dr. Kliman.
American Psychiatric Association
Organization where Kliman is a Distinguished Life Fellow.
American Academy of Child and Adolescent Psychiatry
Organization where Kliman is a Senior Fellow.
American College of Psychoanalysis and Psychiatry
Organization that bestowed the Dean Brockman Award on Kliman.

Timeline (2 events)

2009-06-04
Declaration executed and notarized.
San Francisco, California
Gilbert W. Kliman Leonid Nakhodkin
Prior to 2009-06-04
Psychiatric evaluations of six plaintiffs (Jane Does).
Not specified
Gilbert W. Kliman Six Plaintiffs (Jane Does)

Locations (2)

Location Context
Address of The Psychological Trauma Center and Dr. Kliman.
Location where the declaration was executed and notarized.

Relationships (2)

Gilbert W. Kliman Professional/Retained Expert Mermelstein & Horowitz
I have been retained by plaintiffs’ law firm, Mermelstein & Horowitz, to give expert testimony.
Jeffrey Epstein Abuser/Victim Plaintiffs (Jane Does)
The plaintiffs do not hold their heads high with pride for having been sexually controlled by Mr. Epstein.

Key Quotes (5)

"Each was lured into Mr. Epstein’s sexual lair with the promise of overcoming bodily and sexual shame by earning money and bettering their lot in life."
Source
044-01.pdf
Quote #1
"He perverted their nascent and developing moral structures by posing as a generous, avuncular mentor who could coach them about their bodies, sex and love."
Source
044-01.pdf
Quote #2
"The plaintiffs do not hold their heads high with pride for having been sexually controlled by Mr. Epstein. They hold their heads low with shame."
Source
044-01.pdf
Quote #3
"It is my opinion that involuntary public disclosure will result in the plaintiffs experiencing revictimization, albeit by a justice system that is designed to protect them."
Source
044-01.pdf
Quote #4
"The defendant who wishes to make their identities public is one whom the criminal justice system has already determined is a person who has already committed a crime of child molestation."
Source
044-01.pdf
Quote #5

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