Case 9:08-cv-80380-KAM Document 143-1 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 DivisatIcro St., San Francisco, CA 94115 Phone (415)292.7119 Fax (415)749-2802 Forensic ChildPsychiatric Evaluations. Life Care Plans & Testimony DECLARATION OF GILBERT KLIMAN, M. D. June 4, 2009 RE: EXPECTATION OF HARMFROMDISCLOSING THE PLAINTIFFS' IDENTITIES IN DOES V JEFFREY EPSTEIN 1. I, Gilbert W. Kliman, M.D., of 2105 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, spouses, children, fellow students, employers and fellow employees, the media and general public. This type of exposure humiliates many victims and represents another betrayal of trust. Public exposure places the plaintiffs at further risk of stigmatization, shame and retraumatization. 4. Due to traumatization the plaintiffs are arrested in their development, and even those who are now legally adults are arrested in part to adolescent aspects of psy