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Case 9:09-cv-80469-KAM Document 34-1 Entered on FLSD Docket 06/08/2009 Page 1 of 5
The Psychological Trauma Center
a division of Preventive Psychiatry Associates Medical Group, Inc.
Medical Director: Gilbe rt W. Kliman, M. D.
2 105 Divisadcro St.. San Francisco. CJ\ 94115
Phone(415)292-71 19 Fax (415) 749-2802
w1rn· experrch1/dpsvchiatrv.com
Forensic Child Psychiatric £val11alions, Life Care Plans & Teslimony
DECLARATION OF GILBERT KLIMAN, M. D.
June 4, 2009
RE: EXPECTATION OF HARM FROM DISCLOSING THE PLAINTIFFS' IDENTITIES
IN DOES V JEFFREY EPSTEIN
1. I, Gilbert W. Kliman, M.D., of2105 Divisadero Street, San Francisco, California,
CA. Physicians License 055912, 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.
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 emplo
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