044-01.pdf
356 KB
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...
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| Jeffrey Epstein | Defendant |
Defendant in 'Does v Jeffrey Epstein'; described as 'perpetrator' who sexually controlled and manipulated the plainti...
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| Leonid Nakhodkin | Notary Public |
Notarized the declaration in San Francisco.
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Organizations (6)
| Name | Type | Context |
|---|---|---|
| The Psychological Trauma Center |
Division of Preventive Psychiatry Associates Medical Group, Inc., headed by Dr. Kliman.
|
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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.
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| American Psychiatric Association |
Organization where Kliman is a Distinguished Life Fellow.
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| American Academy of Child and Adolescent Psychiatry |
Organization where Kliman is a Senior Fellow.
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| American College of Psychoanalysis and Psychiatry |
Organization that bestowed the Dean Brockman Award on Kliman.
|
Timeline (2 events)
2009-06-04
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.
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Location where the declaration was executed and notarized.
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Relationships (2)
I have been retained by plaintiffs’ law firm, Mermelstein & Horowitz, to give expert testimony.
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
Full Extracted Text
Complete text extracted from the document (13,962 characters)
Case 9:09-cv-80656-KAM Document 44-1 Entered on FLSD Docket 07/29/2009 Page 1 of 5
The Psychological Trauma Center
a division of Preventive Psychiatry Associates Medical Group, Inc.
Medical Director: Gilbert W. Kliman, M. D.
2105 Divisadero St., San Francisco, CA 94115
Phone (415)292-7119 Fax (415) 749-2802
www.expertchildpsychiatry.com
a division of Preventive Psychiatry Associates Medical Group, Inc.
Medical Director: Gilbert W. Kliman, M. D.
2105 Divisadero St., San Francisco, CA 94115
Phone (415)292-7119 Fax (415) 749-2802
www.expertchildpsychiatry.com
Forensic Child Psychiatric Evaluations, Life Care Plans & Testimony
DECLARATION OF GILBERT KLIMAN, M. D.
June 4, 2009
RE: EXPECTATION OF HARM FROM DISCLOSING THE PLAINTIFFS’ IDENTITIES
IN DOES V JEFFREY EPSTEIN
IN DOES V JEFFREY EPSTEIN
1. I, Gilbert W. Kliman, M.D., of 2105 Divisadero Street, San Francisco, California,
CA. Physicians License G55912, declare the following under penalty of perjury:
CA. Physicians License G55912, declare the following under penalty of perjury:
2. I have been retained by plaintiffs’ law firm, Mermelstein & Horowitz, to give expert
testimony. If called as a witness, I would testify truthfully and competently concerning
my psychiatric findings about each of the plaintiffs’ alleged experiences of sexual abuse,
and the enduring effects that I find each of the young women have suffered as a direct
result of the sexual acts perpetrated by the defendant.
testimony. If called as a witness, I would testify truthfully and competently concerning
my psychiatric findings about each of the plaintiffs’ alleged experiences of sexual abuse,
and the enduring effects that I find each of the young women have suffered as a direct
result of the sexual acts perpetrated by the defendant.
3. I have been asked to respond to the Defense motion, which requests that some of the
plaintiffs, who are now adults, should be publicly named. 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. If their identities are released,
the victims will be at-risk of having their personal lives scrutinized by friends, extended
family, spouses, children, fellow students, employers and fellow employees, the media
and general public. This type of exposure humiliates many victims and represents another
betrayal of trust. Public exposure places the plaintiffs at further risk of stigmatization,
shame and retraumatization.
plaintiffs, who are now adults, should be publicly named. 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. If their identities are released,
the victims will be at-risk of having their personal lives scrutinized by friends, extended
family, spouses, children, fellow students, employers and fellow employees, the media
and general public. This type of exposure humiliates many victims and represents another
betrayal of trust. Public exposure places the plaintiffs at further risk of stigmatization,
shame and retraumatization.
4. Due to traumatization the plaintiffs are arrested in their development, and even those
who are now legally adults are arrested in part to adolescent aspects of psychology.
who are now legally adults are arrested in part to adolescent aspects of psychology.
5. 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. The internal life of a
typical adolescent, into late adolescence and early adult years in the best of
circumstances, usually involves generous proportions of self-consciousness, shame, self-
absorption and self-doubt and self-blame about sexual acts.
controlled by Mr. Epstein. They hold their heads low with shame. The internal life of a
typical adolescent, into late adolescence and early adult years in the best of
circumstances, usually involves generous proportions of self-consciousness, shame, self-
absorption and self-doubt and self-blame about sexual acts.
EXHIBIT A
1
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Case 9:09-cv-80656-KAM Document 44-1 Entered on FLSD Docket 07/29/2009 Page 2 of 5
6. Clinically harmful levels of shame, self-consciousness, self-doubt and self-blame are
even more prominent among victims of molestations than among the general population.
even more prominent among victims of molestations than among the general population.
7. Molested teenagers are particularly vulnerable to wrongful manipulations and special
clinical harms from the experiences of shame and humiliation. In fact, shame and efforts
to cope with it played an underlying role in the harm to each plaintiff. 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. The defendant capitalized on their sexual
naiveté, insecurities and effort to better themselves, and he worked hard to overcome
their shame at his enlistment of them in his selfish gratifications.
clinical harms from the experiences of shame and humiliation. In fact, shame and efforts
to cope with it played an underlying role in the harm to each plaintiff. 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. The defendant capitalized on their sexual
naiveté, insecurities and effort to better themselves, and he worked hard to overcome
their shame at his enlistment of them in his selfish gratifications.
8. 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. That surely means he has already exploited and manipulated the girls’
state of adolescent sexuality, including their embarrassment, awkwardness and bodily
self-consciousness. 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.
justice system has already determined is a person who has already committed a crime of
child molestation. That surely means he has already exploited and manipulated the girls’
state of adolescent sexuality, including their embarrassment, awkwardness and bodily
self-consciousness. 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.
The exploitation of adolescent bodies, sex and love is – from a psychoanalytic point of
view – an influence on the developing moral conscience of the children, as well as on
their sexual urges. Now the ravaging of their internal and private moral conscience is
intended by the perpetrator to be made a public ravaging.
view – an influence on the developing moral conscience of the children, as well as on
their sexual urges. Now the ravaging of their internal and private moral conscience is
intended by the perpetrator to be made a public ravaging.
9. Among sexual trauma victims, the insidious and destructive persistence of shame,
humiliation and associated self-blame is well-documented (Finkelhor and Brown, 1985).
Stigmatization, as experienced by a sexual trauma victim, has especially painful and
pathologic consequences. Shame lingers and becomes integrated within the adolescent
victim’s malleable emerging identity, character structure and self image. Moral clarity is
distorted. Perceptions of self-blame and guilt are magnified. The impact of shame lends
to cultivating a self image of being “spoiled goods.”
humiliation and associated self-blame is well-documented (Finkelhor and Brown, 1985).
Stigmatization, as experienced by a sexual trauma victim, has especially painful and
pathologic consequences. Shame lingers and becomes integrated within the adolescent
victim’s malleable emerging identity, character structure and self image. Moral clarity is
distorted. Perceptions of self-blame and guilt are magnified. The impact of shame lends
to cultivating a self image of being “spoiled goods.”
10. Stigmatization following sexual trauma results in long-term risks that can negatively
shape multiple facets of adult development: sexual, emotional, interpersonal and
vocational. Stigmatization, which is generally to be avoided among psychiatric patients,
increases risks among those – as in our plaintiffs as a group – who experience clinical
depression and self-destructive behaviors: drug use, criminal activity, even prostitution.
shape multiple facets of adult development: sexual, emotional, interpersonal and
vocational. Stigmatization, which is generally to be avoided among psychiatric patients,
increases risks among those – as in our plaintiffs as a group – who experience clinical
depression and self-destructive behaviors: drug use, criminal activity, even prostitution.
Stigmatization following abuse is associated with delinquency due to increased anger
and affiliation with deviant peers (Feiring et al., 2007).
and affiliation with deviant peers (Feiring et al., 2007).
11. Shame and guilt are important dimensions of both complex and single event,
posttraumatic stress disorder (PTSD). Symptoms of shame are associated with feelings of
helplessness and powerlessness, which each of the plaintiffs endorsed experiencing in
relation to Mr. Epstein.
posttraumatic stress disorder (PTSD). Symptoms of shame are associated with feelings of
helplessness and powerlessness, which each of the plaintiffs endorsed experiencing in
relation to Mr. Epstein.
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Case 9:09-cv-80656-KAM Document 44-1 Entered on FLSD Docket 07/29/2009 Page 3 of 5
12. The DSM-IV-TR recognizes both powerlessness and helplessness as requisite parts of
the traumatic experience in Criterion A for the diagnosis of posttraumatic stress disorder
trauma (Martin Seligman, recent Past President of the American Psychological
Association, coined relevant terms of “learned helplessness and “Loss of Personal Locus
of Control.” See Seligman, M.P. 1975: Helplessness, Depression, Development and
Death. W. H. Freeman, San Francisco). The teenaged girls suffered the loss of personal
locus of control to a much more experienced, sexually aggressive, powerful and
dominant, manipulative perpetrator.
the traumatic experience in Criterion A for the diagnosis of posttraumatic stress disorder
trauma (Martin Seligman, recent Past President of the American Psychological
Association, coined relevant terms of “learned helplessness and “Loss of Personal Locus
of Control.” See Seligman, M.P. 1975: Helplessness, Depression, Development and
Death. W. H. Freeman, San Francisco). The teenaged girls suffered the loss of personal
locus of control to a much more experienced, sexually aggressive, powerful and
dominant, manipulative perpetrator.
13. Releasing names of the plaintiffs to the public will reenact experiences of
powerlessness and helplessness in the face of a boundary violation. Repetition and
reenactment represent central features of Criterion B in the DSM-IV-TR diagnosis of
posttraumatic stress disorder trauma. In effect, release of their identity and public
intrusion into their personal life represents a reenactment of the shame of sexual
traumatization. Repetition and reenactment are central pathologies that afflict sexual
trauma survivors.
powerlessness and helplessness in the face of a boundary violation. Repetition and
reenactment represent central features of Criterion B in the DSM-IV-TR diagnosis of
posttraumatic stress disorder trauma. In effect, release of their identity and public
intrusion into their personal life represents a reenactment of the shame of sexual
traumatization. Repetition and reenactment are central pathologies that afflict sexual
trauma survivors.
14. Victims of sexual abuse often rely upon some form of dissociation, splitting or denial,
as a defensive means to manage overwhelming affects associated with the sexual trauma.
Each of the plaintiff girls has employed some variation of this defense, both during the
massages and then subsequently following disclosure of the abuse. Primitive,
maladaptive responses of this nature will become additionally reinforced as a result of
public disclosure.
as a defensive means to manage overwhelming affects associated with the sexual trauma.
Each of the plaintiff girls has employed some variation of this defense, both during the
massages and then subsequently following disclosure of the abuse. Primitive,
maladaptive responses of this nature will become additionally reinforced as a result of
public disclosure.
15. Another aspect of the plaintiffs’ experience, which is recognized by DSM-IV-TR, is
that the trauma was associated with human design factors (such as cruel intention to do
harm, rape, torture). Trauma of this origin has a tendency to produce more “severe or
long lasting” posttraumatic stress disorder than natural events (DSM IV TR p. 464). A
policy of deliberate revelation of the names of the victims would reinforce the sense of
design, pattern and policy of human intentions.
that the trauma was associated with human design factors (such as cruel intention to do
harm, rape, torture). Trauma of this origin has a tendency to produce more “severe or
long lasting” posttraumatic stress disorder than natural events (DSM IV TR p. 464). A
policy of deliberate revelation of the names of the victims would reinforce the sense of
design, pattern and policy of human intentions.
16. Negative expectations about significant activities are noted in DSM-IV-TR, as part of
Criterion C. Symptoms of foreshortened future are characteristic of a traumatized
individual’s clinical course (C4). They expect revictimization. They expect bad outcomes
(C7) in their social, educational, vocational, relational plans. They are hypervigilant
(Criterion D4) for further trauma, and this affects lifestyle choices and future planning.
Hypervigilance is part of the arousal set of criteria. Public disclosure of the victims’
identity will aggravate existing symptoms of hypervigilance.
Criterion C. Symptoms of foreshortened future are characteristic of a traumatized
individual’s clinical course (C4). They expect revictimization. They expect bad outcomes
(C7) in their social, educational, vocational, relational plans. They are hypervigilant
(Criterion D4) for further trauma, and this affects lifestyle choices and future planning.
Hypervigilance is part of the arousal set of criteria. Public disclosure of the victims’
identity will aggravate existing symptoms of hypervigilance.
17. The DSM-IV-TR diagnostic category of “chronic” is justified for each of the
plaintiffs. Scientific literature shows that the prognostic consequences of PTSD and
residual effects may last for decades (U.S. Dept. of Health, 2005; Issues in Child Abuse
Prevention Number 9 Autumn 1998: Long-term Effects of Child Sexual Abuse, Paul E
Mullen and Jillian Fleming). The lasting impact upon character, identity and moral
development will probably affect long-term influences upon adult development. It is
more probable than not that stigmatization associated with public disclosure of the
plaintiffs. Scientific literature shows that the prognostic consequences of PTSD and
residual effects may last for decades (U.S. Dept. of Health, 2005; Issues in Child Abuse
Prevention Number 9 Autumn 1998: Long-term Effects of Child Sexual Abuse, Paul E
Mullen and Jillian Fleming). The lasting impact upon character, identity and moral
development will probably affect long-term influences upon adult development. It is
more probable than not that stigmatization associated with public disclosure of the
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Case 9:09-cv-80656-KAM Document 44-1 Entered on FLSD Docket 07/29/2009 Page 4 of 5
plaintiffs’ identities will intensify the scope, nature and severity of the chronic symptom
course.
course.
18. In addition to PTSD, shame and humiliation themselves have also been associated
with causing clinical depression. Coexisting PTSD and clinical depression places the
plaintiff’s at increased risk for re-victimization and high risk sexual behaviors (e.g.,
sexually transmitted disease, premature pregnancy, rape) (Nelson, 2002), and at greater
risk to victimize others (Filipas and Ullman, 2006; Desai, Centers for Disease Control,
2002) who are in their control. Studies have also shown that chronic symptoms of PTSD,
in association with a single episode of Major Depressive Disorder, can produce lifetime
adjustment difficulties, which include suicidality (Oquendo et al, 2005; Dube et al, CDC,
2001; Rohde, J. Am. Acad. Child and Adolescent Psychiatry 2005). The plaintiffs will be
additionally vulnerable to these clinical outcomes, if they suffer the stigmatization and
humiliation associated with public disclosure of their identities.
with causing clinical depression. Coexisting PTSD and clinical depression places the
plaintiff’s at increased risk for re-victimization and high risk sexual behaviors (e.g.,
sexually transmitted disease, premature pregnancy, rape) (Nelson, 2002), and at greater
risk to victimize others (Filipas and Ullman, 2006; Desai, Centers for Disease Control,
2002) who are in their control. Studies have also shown that chronic symptoms of PTSD,
in association with a single episode of Major Depressive Disorder, can produce lifetime
adjustment difficulties, which include suicidality (Oquendo et al, 2005; Dube et al, CDC,
2001; Rohde, J. Am. Acad. Child and Adolescent Psychiatry 2005). The plaintiffs will be
additionally vulnerable to these clinical outcomes, if they suffer the stigmatization and
humiliation associated with public disclosure of their identities.
19. Alternative hypothesis: I have applied the evidence shown from examination and
testing of the plaintiffs and relevant observations and information from other
professionals while testing an alternative hypothesis: that no harm would result from
public disclosure of the plaintiffs’ identities. During the evaluations with the six
plaintiffs, I used generally acceptable criteria for establishing whether a DSM-IV-TR
disorder occurred. I established that there were provable and diagnosable injuries,
primarily posttraumatic stress disorder and comorbid depression. Based upon these
diagnostic signs, it is more probable than not, that exposing the plaintiff’s identity to the
public is not a trivial concern or one without substantial clinical repercussions. I believe
that most child, adolescent and adult psychiatrists would share the opinion that additional
psychiatric injury will result from such exposure.
testing of the plaintiffs and relevant observations and information from other
professionals while testing an alternative hypothesis: that no harm would result from
public disclosure of the plaintiffs’ identities. During the evaluations with the six
plaintiffs, I used generally acceptable criteria for establishing whether a DSM-IV-TR
disorder occurred. I established that there were provable and diagnosable injuries,
primarily posttraumatic stress disorder and comorbid depression. Based upon these
diagnostic signs, it is more probable than not, that exposing the plaintiff’s identity to the
public is not a trivial concern or one without substantial clinical repercussions. I believe
that most child, adolescent and adult psychiatrists would share the opinion that additional
psychiatric injury will result from such exposure.
20. However, consider for the sake of argument, that my diagnostic conclusions are
incorrect, notwithstanding having fulfilled standard psychiatric evaluation procedures of
taking a history from multiple sources, videotaping and transcribing my initial interview,
and reviewing available medical and legal documents. Even if this was the case, and my
diagnostic conclusions were faulty, I believe that multiple experts, even those who may
now propose publication of the victims’ names, would still come to a conclusion that the
plaintiff’s suffered sexual abuse, and in some cases, multiple acts of ongoing abuse, at the
hands of Jeffery Epstein. Even without developing a subsequent disorder, there is much
clinical evidence and scientific literature showing likelihood of substantial psychiatric
harm to these sexually abused plaintiffs.
incorrect, notwithstanding having fulfilled standard psychiatric evaluation procedures of
taking a history from multiple sources, videotaping and transcribing my initial interview,
and reviewing available medical and legal documents. Even if this was the case, and my
diagnostic conclusions were faulty, I believe that multiple experts, even those who may
now propose publication of the victims’ names, would still come to a conclusion that the
plaintiff’s suffered sexual abuse, and in some cases, multiple acts of ongoing abuse, at the
hands of Jeffery Epstein. Even without developing a subsequent disorder, there is much
clinical evidence and scientific literature showing likelihood of substantial psychiatric
harm to these sexually abused plaintiffs.
21. To form these conclusions, I have used my extensive experience in forming these
opinions. That experience is both as a treating child psychiatrist and separately as a
forensic psychiatrist. I have treated hundreds of minor patients, as well as additionally
evaluated hundreds of children and adolescents who have suffered sexual abuse. I have
made long term followups of many of the children and have treated many adults who
have been molested as adolescents. 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. The act of revealing their identities
against their wishes places the plaintiffs at risk, in the best of circumstances, of suffering
opinions. That experience is both as a treating child psychiatrist and separately as a
forensic psychiatrist. I have treated hundreds of minor patients, as well as additionally
evaluated hundreds of children and adolescents who have suffered sexual abuse. I have
made long term followups of many of the children and have treated many adults who
have been molested as adolescents. 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. The act of revealing their identities
against their wishes places the plaintiffs at risk, in the best of circumstances, of suffering
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Case 9:09-cv-80656-KAM Document 44-1 Entered on FLSD Docket 07/29/2009 Page 5 of 5
an aggravation of existing diagnostic concerns. It is more probable than not that releasing
personal identities will foster an exacerbation and magnification of symptoms lending to
increased risk of revictimization and retraumatization.
personal identities will foster an exacerbation and magnification of symptoms lending to
increased risk of revictimization and retraumatization.
I declare under penalty of perjury under the laws of the State of California that the
foregoing statements are true and correct, and that this declaration was executed at San
Francisco, California on June 4, 2009.
foregoing statements are true and correct, and that this declaration was executed at San
Francisco, California on June 4, 2009.
Sincerely,
[Signature of Gilbert Kliman]
Gilbert Kliman, M.D.
Distinguished Life Fellow, American Psychiatric Association
Senior Fellow, American Academy of Child and Adolescent Psychiatry
Dean Brockman Award Holder, for Distinguished Lifetime Contributions to
Psychoanalysis and Psychiatry, bestowed by the American College of Psychoanalysis and
Psychiatry
[Signature of Gilbert Kliman]
Gilbert Kliman, M.D.
Distinguished Life Fellow, American Psychiatric Association
Senior Fellow, American Academy of Child and Adolescent Psychiatry
Dean Brockman Award Holder, for Distinguished Lifetime Contributions to
Psychoanalysis and Psychiatry, bestowed by the American College of Psychoanalysis and
Psychiatry
[Notary Stamp]
LEONID NAKHODKIN
COMM. # 1791115
NOTARY PUBLIC - CALIFORNIA
CITY & COUNTY OF SAN FRANCISCO
MY COMM. EXP. FEB. 27, 2012
LEONID NAKHODKIN
COMM. # 1791115
NOTARY PUBLIC - CALIFORNIA
CITY & COUNTY OF SAN FRANCISCO
MY COMM. EXP. FEB. 27, 2012
State of California, City & County of San Francisco
Subscribed and sworn to (or affirmed) before me on this
4th day of June 2009, by Gilbert Kliman
proved to me on the basis of satisfactory evidence
to be the person(s) who appeared before me.
[Signature of Leonid Nakhodkin]
Leonid Nakhodkin
Subscribed and sworn to (or affirmed) before me on this
4th day of June 2009, by Gilbert Kliman
proved to me on the basis of satisfactory evidence
to be the person(s) who appeared before me.
[Signature of Leonid Nakhodkin]
Leonid Nakhodkin
5
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