📧 Communication

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.