EFTA02725395.pdf

Aug 04 09 04:58p Richard C. Hall, MD 407-322-8169 p.22 Jane Doe #6 v. Jeffrey Epstein AFFIDAVIT OF RICHARD C.W. HALL M.D. STATE OF FLORIDA COUNTY OF SEMINOLE On this day personally appeared before me, the undersigned authority, Richard C.W. Hall, M.D., who, being by me first duly sworn under oath deposes and says: 1. My name is Richard C.W. Hall, M.D. I am over the age of majority, and make this affidavit and declaration upon the basis of personal knowledge of the factual matters contained herein. 2. 1 have maintained a private practice in psychiatry and forensic psychiatry since 1996. 3. I, also, currently serve as a Courtesy Clinical Professor of Psychiatry at the University of Florida, College of Medicine, Gainesville, Florida; Affiliate Professor, Dept of Psychiatry and Behavioral Medicine, University of South Florida; and Professor of Psychiatry, Department of Medical Education, University of Central Florida College Medicine. 4. I received my undergraduate degree from the Johns Hopkins University and 1 EFTA_R1_02212881 EFTA02725395 Aug 04 09 04:58p Richard C. Hall, MD 407-322-8169 P.23 medical degree from the University of Florida College of Medicine, Gainesville, Florida. 5. I served as a Lieutenant Commander in the United States Navy, where I researched and evaluated biological and neurochemical factors associated with the onset of psychiatric disorders and served as a representative to the Joint Services Task Force planning Operation Homecoming, the return of POW's from Vietnam. 6. I have previously served as an assistant clinical professor at the University of South Florida College of Medicine, directed one of the ten model mental health centers in the United States, and served as a medical consultant to the Kennedy Space Center. 7. I am a former member of the academic faculty at the University of Texas, in Houston, Texas where I served as Assistant Professor and then Associate Professor of Psychiatry and Internal Medicine, Director of Clinical Research, Director of Residency Training, Chief of the Consultation/Liaison Service, and Chief Psychiatrist at the M.D. Anderson Cancer Hospital in Houston. 8. I, also, have served as a Professor of Internal Medicine and Psychiatry at the e Medical College of Wisconsin where I was appointed Chief of Psychiatry at the Milwauke County and Froedtert Hospitals. 9. In addition, I have served as a Professor of Psychiatry and Internal Medicine and Associate Dean at the University of Tennessee College of Medicine, Memphis. 10. The amended complaint filed by Jane Doe #6 against Jeffrey Epstein makes 2 EFTA R1 02212882 EFTA02725396  Richard C. Hall, MD 407-322-8169 p.24 Aug 04 09 04:58p sensitive allegations of sexual assault and abuse upon a minor and seek damages in excess of $50 million. Jane Doe #6 alleges confusion, shame, humiliation, embarrassment, and severe psychological and emotional injuries. It is further alleged that she suffered, and will continue to suffer, severe and permanent traumatic injuries, including mental, psychological, and emotional damages. 11. She alleges the intentional infliction of emotional distress and that Mr. Epstein's conduct caused severe emotional distress, severe mental anguish and pain. 12. She further alleges that she has suffered personal injury including mental, psychological and emotional damage. 13. Plaintiff's counsel has retained an expert witness, Dr. Kliman of the Psychological Trauma Center, a division of Preventive Psychiatry Associates Medical Group, Inc., of San Francisco, California, of which Gilbert W. Kliman, MD, is the medical director. Dr. Kliman's initial records indicate the following concerning Jane Doe #6. 14. Plaintiff's interrogatories note a diagnosis of PTSD following an auto accident in 2003. (Pre-Epstein) (Page 5, Plaintiff's Answers to Defendant's First Interrogatories) 15. Plaintiff noted "nervous about driving here. Hit by a semi June 2003.1 wasn't hurt but Mom was." (Page 1, GK Contemp notes, Interview Part 1) 16. "Seroquel. . . for bad dreams after the car accident . . longest therapy six months court ordered. I am on probation for stupid stuff I did 2-3 years ago. . . really 3 EFTA R1 02212883 EFTA02725397 Aug 04 09 04:59p Richard C. Hall, MD 407-322-8169 p.25 notes) dumb, I got in trouble, arrested." (Page 2, GK Contemp Abuse, dated July 19, 17. A Petition for Involuntary Assessment for Substance e with "threats to several family 2006, noted a domestic disturbance at plaintiff's hom under the influence of Zanax [sic) members as well as threats of suicide... appeared to be s ago, may have pushed her over the bars... She found her grandmother dead three week for Substance Abuse, Circuit Court of edge." (Page 1, Petition for Involuntary Assessment ty, Florida). On January 31, 2007, the 15th Judicial Circuit in and for Palm Beach Coun sentenced to a 30-day substance Plaintiff pled guilty to grand theft and burglary, and was 2 years probation. On February 25, abuse program, 9 months community control, and her residence violating probation. 2007, Plaintiff cutoff her monitoring bracelet and fled and was ordered to undergo a mental She was arrested on March 9, 2007 and April 2, 2007 ssion of drug health evaluation. On August 8, 2007, she was arrested for posse was in jail for a period of 30 days until paraphernalia and violated her probation again. She violation of probation and sentenced September 6, 2007 when she was found guilty of the then outpatient treatment as well as to remain in jail for evaluation and. treatment and parenting classes. plaintiff being charged 1.8. A Notice of Related Case reports an incident of the November 2004. (Page 2, Notice of with possession of a weapon on school property in it in and for Palm Beach County, Related Case, Circuit Court of the 15th Judicial Circu 4 EFTA RI f)921951fid EFTA02725398 Florida) 19. On 4/13/06, in response to a call of child abuse, an officer received a report from DCF noting that "since the age of 13, Plaintiff has been smoking marijuana with her father every other day. .. Mom is aware of (blacked out) smoking marijuana with dad... She placed her daughter in Growing Together Treatment Center on 3/10/06. Then Baker Acted her on 4/ 7/06 to (blacked out)." (Police Offense Report) 20. On 4/12/05, police responded to a domestic violence call, which involved plaintiff and her brother kicking and hitting each other at their residence. (Police Offense Report) 21. A police report of 5/24/04 notes that police responded to a delayed battery charge, in which the plaintiff was involved in a verbal argument with a friend who then punched the plaintiff with a closed fist to the forehead area. (Police Offense Report) 22. A police report of 11/22/03 noted a physical altercation involving the plaintiff and another individual, which resulted in the plaintiff being struck in her left eye with a closed fist. (Police Offense Report) 23. On 3/02/03, police responded to a call of a suspicious person at the plaintiff's residence. The plaintiff reported that when she entered her shed to do her laundry, she came in contact with an unknown male, who had some of her underwear inside his mouth. She reported that the male took the underwear out of his mouth, put them in the dryer, and 5 EFTA_R1_02212885 EFTA02725399  407-322-8169 p.27 Aug 04 09 04:59p Richard C. Hall, MD then ran away. (Police Offense Report) ed /02 in which plaintiff was follow 24. A police report notes an incident of 8/27 sequent to a ged ly battered by two of the girls sub home from school by four girls and alle e Report) verbal conflict at school. (Police Offens ...I s between repeating sixth grade. 25. "I met Mr. Jeffrey August 2004.. . I wa go to was not yet 14. an. came to my house to get me to go and we called a cab to ause I wouldn't get him a different age, 16 or over bec Jeffrey's. She told me I had to tell paid." (Page 1, GK notes) .I I might have had sex with one person 26. Plaintiff reported, "I wasn't a virgin. friend." (Page 2, virginity with a little kid, a childhood was around 13 or 14 that I lost my GK notes) ax... drank a little but not into it"(Page 27. "I smoked some weed during the Xan 2, V Alvarez wi GK III, 12/6/08) the way it made me feel and I'd fall 28. Plaintiff reported "Cause I don't like 6. I e bit after I got into that car accident that's 200 asleep on it and yea .. . that's a littl ted getting y star ted taking me to therapists and I star started getting bad dreams and the ever seen and bad... that's the longest therapist I've like anxiety attacks in the car .. It was e 1) d." "I went to her like six months." (Page 9, Tap that was because it was court ordere ur irritable since this happened to yo 29. Question: "Have you been more 6 FFT6 P1 nOO1OOOC EFTA02725400  407-322-8169 p.28 Aug 04 09 04:59p Richard C. Hall, MD age 12, Tape 3). Plaintiff response, "I don't Icnow."(P a that on Apri110, 2005 she witnessed 30. Plaintiff failed to report to Dr. /Groan h her then- ber 22, 2006, Plaintiff got into a fight wit friend get electrocuted. On Decem ht, and the boy friend went out in the street in front of boyfriend, who had been out all nig and killed himself. their house and put a gun to his head ed f came from an unstable and disturb 31. All of the above show that this plaintif physical and sexual abuse, was fearful, isolated, and home, had been subject to previous of her eting Mr . Epstein. For further elaboration had had suicidal ideation prior to me one is to fully all available records is crucial if history and background, access to or and proportion se events on her subsequent behavi understand the impact of any of the n. her current and future level of functio the impact of specific events, if any, or le retainer agreement and fee schedu 32. In Dr. Klimart's initial replenishment "Regarding Ful l Disclosure," Dr. Klirnan notes that (date 7/18/08), in a heading entitled with ke every effort necessary to provide experts prior to deposition, counsel will ma s, statements, erts including: 1) a list of all deposition information requested by the exp case, 2) a copy of any requested items, and 3) most declarations, and motions in the y importantly, ads ic t a medical, clinical, school mcl work records known to the attorne in the case. tract opinion formation that he will not 33. Dr. Kiirnan notes on page 8 of his con 7 EFTA Di nnni nap-, EFTA02725401 Aug 04 09 05:00p Richard C. Hall, MD 407-322-8169 p.31 form opinions, give reports, or testify in certain circumstances. These include circumstances where he has reason to believe a retaining attorney has "available important and relevant documents which are lawg deliberately withheld from us." "We define such as documents in possession of retaining attorney, which we have requested or that we have stated would ordinarily be part of medical opinion formation on topics conceminv, which our input is requested." We request the same. 34. It is critical for an 'ME examiner to be able to make a cogent assessment of any plaintiff and to understand their medical, social, academic, psychological and psychiatric condition/state prior to any act of alleged victimization. There are a number of variables that combine to determine the effects of such alleged victimization, including the type and character of the alleged assault, and key victim variables such as demographics, psychological reactions at the time of the trauma, previous psychiatric or psychological history, previous victimization history, current or previous psychological difficulties, and general personality dynamics and coping style, as well as sociocultural factors such as drug use/abuse; poverty; social inequity and/or inadequate social support; any previous history of abuse within or outside the family; whether individuals were abused by strangers, acquaintances or family members; and whether there was any history of indiscriminate behavior that may have placed them at increased risk. It is important to know if there had been previous sexual conduct, contact with police or welfare agencies, alcohol or drug 8 EFTA R1 02212888 EFTA02725402  use, genital infections, or apparent use/abuse, voluntary sexual activity, contraceptive indifference to previous abuse. of emotional support, 35. It is also essential to understand the plaintiff's level nt, whether they were taking any whether any significant psychiatric illnesses were prese had been previous suicide medications (prescribed or non-prescdbed), whether there attempts, thoughts, plans, etc. EFTA RI 112919QQn EFTA02725403 Aug 04 09 05:00p Richard C. Hall, MD 407-322-8169 P30 Respectfully submitted, fra-A cjicbildAkso Richard C. W. Hall, Flori da, College of Medicine Courtesy Clinical Professor of Psychiatry, University of l Medicine, University of South Affiliate Professor, Department of Psychiatry and Behaviora Florida , University of Central Florida Professor of Psychiatry, Department of Medical Education College of Medicine STATE OF FLORIDA COUNTY OF SEMINOLE appeared RICHARD C.W. BEFORE ME, the, undersigned authority, personally me or ( ) who has produced HALL, M.D., who is (V) personally known to says that as identification, and who did take an oath, deposes and knowledge and belief. the attached Affidavit is true and correct to the best of his day of la.,90 SWORN TO AND SUBSCRIBED before me on this LW` 2009. ".....erfArEaltallAt4 iocks 1 Elvin 6P6/2010 Not4ry Public Printed Name: MihrCC t, C—AlsAf n - an Meal Wanly Ann- Inc My Commission Expires: 10 EFTA R1 02217Rcin EFTA02725404