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Case 9:08-cv-80119-KAM Document 305-3 Entered on FLSD Docket 09/17/2009 Page 6 of 11 Case 9:08-cv-80119-KAM Document296 Entered on FLSD Docket 09/11/2009 Page 6 of 33 Page 6 depositions and those materials and “filter them” to defense counsel. That motion was denied, and the court tailored a method such that the Defendant could obtain the records directly. B. Plaintiffs’ counsels sought to limit the psychological psychiatric examination in C.M.A. v. Jeffrey Epstein and Sarah Kellen (Case No. 08- CIV-80811), as to time, subject matter and scope. However, Magistrate Johnson entered an order denying the requested restrictions. Cc. Other Plaintiffs’ attorneys have said that they object to requested psychological exam of their client(s), thus motions for such exams will now need to be filed; yet all seek millions of dollars in damages for alleged psychological and emotional trauma. D. Many Plaintiffs’ object to discovery regarding current and past employment (although they are seeking loss of income, both in past and future). E. All Plaintiffs object to prior sexual history, consensual and forced as being irrelevant, although in many of the medical records that are now being obtained, as well as the psychiatric exams done by Dr. Kliman, there is reference to rape, molestation, abusive relationships (both physical and verbal), prior abortions, illegal drugs and alcohol abuse. 45. Clearly, Plaintiffs wish to make allegations; however, they forget that they must meet their burden by proving same. Meeting that burden and disproving those allegations is not possible if this court allows Plaintiffs to stifle and/or control the discovery process. 16. Specifically, with regard to Jane Doe No. 4, which is the deposition set for next week, September 16, 2009, the plaintiff has in her past (see affidavit of Richard C.W. Hall, MD., an expert psychiatrist retained by Defendant to conduct exams on various claimants.) See Exhibit “5” A Sought counseling due to a dysfunctional home situation, specifically with regard to her father. She described herself as being angry, bitter, depressed and having body image problems; B. Had an ex-boyfriend, Preston Vinyard, who was, on information and belief, a drug dealer who she lived with; Cc. Had drug and alcohol problems herself; and 03956-10999