034-01.pdf
1.99 MB
Extraction Summary
5
People
8
Organizations
3
Locations
2
Events
3
Relationships
6
Quotes
Document Information
Type:
Legal declaration (expert witness report)
File Size:
1.99 MB
Summary
This document is a sworn declaration by Dr. Gilbert W. Kliman, a forensic psychiatrist, filed on June 8, 2009, in the case of Does v. Jeffrey Epstein. Dr. Kliman argues against the defense's motion to publicly disclose the identities of six Jane Doe plaintiffs, stating that such exposure would cause severe psychological harm, including revictimization, stigmatization, and retraumatization. He details how Epstein manipulated the victims by posing as a mentor and outlines the plaintiffs' diagnoses of PTSD and depression, concluding that anonymity is clinically necessary to prevent further injury.
People (5)
| Name | Role | Context |
|---|---|---|
| Gilbert W. Kliman, M.D. | Declarant / Medical Director / Forensic Psychiatrist |
Author of the declaration, retained by plaintiffs' counsel to evaluate the psychological harm of disclosing victims' ...
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| Jeffrey Epstein | Defendant |
Accused of sexual abuse; described as having a 'sexual lair' and posing as an 'avuncular mentor'.
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| Jane Does | Plaintiffs (6 individuals) |
Unnamed victims evaluated by Dr. Kliman; described as having PTSD, depression, and arrested development.
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| Leonid Nakhodkin | Notary Public |
Notarized the declaration in San Francisco.
|
| Martin Seligman | Psychologist (Cited) |
Cited for his work on 'learned helplessness' and 'Loss of Personal Locus of Control'.
|
Organizations (8)
| Name | Type | Context |
|---|---|---|
| The Psychological Trauma Center |
Division of Preventive Psychiatry Associates Medical Group, Inc., Dr. Kliman's organization.
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| Preventive Psychiatry Associates Medical Group, Inc. |
Parent organization of The Psychological Trauma Center.
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| Mermelstein & Horowitz |
Plaintiffs' law firm that retained Dr. Kliman.
|
|
| American Psychiatric Association |
Professional organization where Dr. Kliman is a Distinguished Life Fellow.
|
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| American Academy of Child and Adolescent Psychiatry |
Professional organization where Dr. Kliman is a Senior Fellow.
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| American College of Psychoanalysis and Psychiatry |
Awarded Dr. Kliman the Dean Brockman Award.
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| U.S. Dept. of Health |
Cited source regarding long-term effects of abuse.
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| Centers for Disease Control (CDC) |
Cited source regarding adverse life experiences.
|
Timeline (2 events)
2009-06-04
Execution and notarization of the Declaration of Gilbert Kliman, M.D.
San Francisco, California
Gilbert W. Kliman
Leonid Nakhodkin
Locations (3)
| Location | Context |
|---|---|
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Address of Dr. Kliman's office.
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Location where the declaration was executed and notarized.
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Florida Southern District (Court Docket context).
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Relationships (3)
I have been retained by plaintiffs' law firm, Mermelstein & Horowitz, to give expert testimony.
Each was lured into Mr. Epstein's sexual lair... He perverted their nascent and developing moral structures...
Gilbert W. Kliman
→
Doctor / Patient (Evaluator)
→
Jane Does (Plaintiffs)
During the evaluations with the six plaintiffs, I used generally acceptable criteria for establishing whether a DSM-IV-TR disorder occurred.
Key Quotes (6)
"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
034-01.pdf
Quote #1
"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
034-01.pdf
Quote #2
"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
034-01.pdf
Quote #3
"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
034-01.pdf
Quote #4
"The impact of shame lends to cultivating a self image of being 'spoiled goods.'"Source
034-01.pdf
Quote #5
"It is my opinion, with a reasonably high degree of medical certainty that the defense motion to allow public disclosure of the plaintiffs' identities is clinically and ethically a wrongful plan."Source
034-01.pdf
Quote #6
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