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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.expertchildpsvchiahy.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

        1. I, Gilbert W. Kliman, M.D., of2105 Divisadero Street, San Francisco, California,
        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.

        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

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