American Psychiatric Association

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034-01.pdf

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.

Legal declaration (expert witness report)
2025-12-26

044-01.pdf

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.

Legal declaration / expert witness report
2025-12-26

EFTA00016268.pdf

This document is a defense expert witness disclosure letter in the case United States v. Ghislaine Maxwell, dated November 1, 2021. It details the qualifications and expected testimony of eight expert witnesses, covering topics such as false memory (Dr. Loftus), the lack of scientific basis for 'grooming-by-proxy' (Dr. Dietz), forensic psychiatry, prosecutorial misconduct, computer forensics, and document authentication. The defense strategy aims to challenge the reliability of memory, rebut government claims about grooming behaviors, and analyze financial and physical evidence.

Legal correspondence (expert witness disclosure)
2025-12-25

DOJ-OGR-00010522.jpg

This document is a page from a forensic-psychiatric report for Ghislaine Maxwell, filed on June 15, 2022. The report details that Maxwell, at her attorney's request, is being evaluated for her mental state and flight risk, and it discusses her complaints of unfair treatment and sleep deprivation in custody. The report cites academic research to argue that these conditions can lead to significant psychological distress, loss of cognitive flexibility, and diminished emotional intelligence.

Legal document (forensic-psychiatric report)
2025-11-20

HOUSE_OVERSIGHT_029403.jpg

This document is a 'Harvard Medical School In the News' email digest dated March 22, 2017, summarizing media appearances by HMS faculty members Richard Frank, Rebecca Brendel, Alex Keuroghlian, and Chung-Kang Peng. The email concludes with the signature block of Dr. Rudolph E. Tanzi, a Professor of Neurology, suggesting this document was retrieved from his files during the House Oversight investigation. The document bears the Bates stamp HOUSE_OVERSIGHT_029403.

Email newsletter / news digest
2025-11-19
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