EFTA02725858.pdf

Aug 18 09 11:17a Richard C. Hall, MD 407-322-8169 p.2 Saga v. Jeffrey Epstein AFFIDAVIT OF RYAN C.W, HALL, M.D. STATE OF FLORIDA COUNTY OF SEMINOLE rsigned authority, Ryan C.W. On this day personally appeared before me, the unde r oath deposes and says: Hall, M.D., who, being by me first duly sworn unde of majority, and make 1. My name is Ryan C.W. Hall, M.D. I am over the age nal knowledge of the this affidavit and declaration upon the basis of perso factual matters contained herein. forensic psychiatry 2. I have maintained a private practice in psychiatry and since 2008. uctor of the Department of 3. I, also, currently serve as an Affiliate Instr ersity of South Florida, Psychiatry and Behavioral Medicine at the Univ y in the Department of Tampa, Florida, and Assistant Professor of Psychiatr da College of Medicine. Medical Education at the University of Central Flori s Hopkins University and 4. I received my undergraduate degree from John medical degree from Georgetown University. legal proceeding. 5. No opinion of mine has ever been disqualified in a 1 II EFTA RI (12912n7 EFTA02725858 Aug 18 09 11:17a Richard C. Hall, MD 407-322-8169 p.3 hiatry and the 6. I was a Rappeport Fellow of the American Academy of Psyc Law in 2007. in Forensic Psychiatry 7. I completed an additional year of training fellowship at Case Western Reserve in 2007-2008. d of Psychiatry and 8. I am Board Certified in Psychiatry by the American Boar hiatry. Neurology, with additional qualifications in Forensic Psyc st Jeffrey Epstein makes 9. The amended complaint filed by CMA again a minor and seek sensitive allegations of sexual assault and abuse upon t complaint in which damages in excess of $75,000. CMA has filed a 31-coun n, embarrassment, she alleges confusion, loss of innocence, shame, humiliatio further alleged that she and severe psychological and emotional injuries. It is permanent traumatic suffered, and will continue to suffer, severe and ional damages. injuries, including mental, psychological, and emot distress and that Mt 10. She alleges the intentional infliction of emotional severe mental anguish Epstein's conduct caused severe emotional distress, and pain. injury including mental, 11. She further alleges that she has suffered personal psychological and emotional damage. ble and disturbed home. 12. Police records show that CMA came from an unsta 2 EFTA R1 0221S49R EFTA02725859 Aug 18 09 11:18a Richard C. Hall, MD 407-322-8169 p.4 from school, In 2001, prior to meeting Mr. Epstein, she was noted to be truant described by was on probation for an incident of domestic violence, and was been subject to her mother as being completely out of control. She had sexually active previous physical abuse, was fearful, isolated, and had been of her history and prior to meeting Mr. Epstein. For further elaboration n and access to all background, a thorough psychiatric interview/examinatio d the impact of any of available records is crucial if one is to fully understan n the impact of these events on her subsequent behavior and proportio function. specific events, if any, or her current and future level of a cogent assessment of 13. It is critical for an IME examiner to be able to make mic, psychological any Plaintiff and to understand their medical, social, acade alleged victimization. and psychiatric condition/state prior to any act of the effects of such There are a number of variables that combine to determine of the alleged assault, alleged victimization, including the type and character ological reactions at and key victim variables such as demographics, psych or psychological history, the time of the trauma, previous psychiatric ological difficulties, previous victimization history, current or previous psych as well as sociocultural and general personality dynamics and coping style, ity and/or inadequate factors such as drug use/abuse; poverty; social inequ 3 EFTA R1 11991%,flo EFTA02725860 Aug 18 09 11:18a Richard C. Hall, MD 407-322-8169 P-5 de the family; social support; any previous history of abuse within or outsi aintances or family whether individuals were abused by strangers, acqu nate behavior that members; and whether there was any history of indiscrimi to know if there had may have placed them at increacod risk. It is important or welfare agencies, been previous sexual conduct, contact with police contraceptive use, alcohol or drug use/abuse, voluntary sexual activity, abuse. genital infections, or apparent indifference to previous emotional support, 14. It is also essential to understand the Plaintiffs level of whether they were whether any significant psychiatric illnesses were present, whether there had taking any medications (prescribed or non-prescribed), been previous suicide attempts, thoughts, plans, etc. and familial factors, 15. Knowledge of Plaintiffs relationships to her family to toxic substances such including social disadvantage, intrauterine exposure onship, and parental as cocaine, family instability, impaired parent/child relati adjustment difficulties is also critical. examiner has available to 16. It is, therefore, crucial that the independent medical previous legal, social, him a full and complete record that includes medical, ta; psychological criminal, academic, psychological and psychiatric records/da ds and that they tests; laboratory tests; and clinical, hospital, physician recor 4 EFTA Ri 0221Adiri EFTA02725861 Aug 18 09 11:18a Richard C. Hall, MD 407-322-8169 p.6 Medical Examination. have time to conduct a full and complete Independent r Plaintiff's full medical and 17. The Independent Medical Examination will cove history of present illness, psychiatric history, including: chief complaint, history, past psychiatric specific complaints of symptoms or injury, medical childhood history, school history, family history, abuse history, birth history, legal history, relationship history, occupational history, violence history, of systems, activities of history, substance use history, sexual history, review using DSM-IV axes, and daily living, mental status examination, diagnoses discussion of case findings and opinions. ession Scale, Zung Anxiety 18. Psychological tests and questionnaires: Zung Depr , MMPI -2 with forensic Scale, Mini Mental State Examination, MCMI-111 sic Questionnaire. implications, Life History Questionnaire, and Foren have been put at issue, the 19. Because Plaintiff's emotional and mental states her physical, emotional undersigned must ask question of Plaintiff regarding nt, in order to form an and mental problems, in the past and in the prese seven hours with the Plaintiff. expert opinion. Such examination will require tiff and the examiner. Other The IME requires the presence of only the Plain individuals present will invalidate the process. er and have been asked to 20. I have been retained as an expert in this matt 5 EFTA Ri 02213411 EFTA02725862 Aug 18 09 11:18a Richard C. Hall, MD 407-322-8169 p.7 perform an independent medical evaluation of Plaintiff INS a videographer, court 21. I strenuously object to allowing the presence of during my examination of reporter and/or attorney being present in the room Plaintiff and/or attorney in the 22. The presence of a videographer, court reporter independent medical examination room during my performance of an nt, distractions, and would examination would create an artificial environme ination. A video camera in compromise the integrity of my psychiatric exam de the room would be the room connected to a monitor by cable outsi acceptable. grapher, court reporter and/or 23. Furthermore, enabling the presence of a video rmance of an independent attorney in the examination room during my perfo normal standards imposed medical examination is a dear departure from the n. within the psychiatric field for such an examinatio cal examination, I require 24. As part of the performance of an independent medi aire" and a "Forensic that examinees complete a "Patient Questionn n about the examinee, Questionnaire" designed to elicit historical informatio examination and gives the which assists in my performance of the clinical 6 EFTA Ri 1)791ZA19 EFTA02725863 Aug 18 09 11:18a Richard C. Hall, MD 407-322.8169 p.8 n appropriate examinee opportunity to review records obtained and obtai data prior to the examination. tionn aire seeking the 25. Requiring that a patient/examinee complete a ques proto col of the clinical provision of historical information is a standard examination. independent medical 26. My ability to provide a complete and thorough ision of the historical examination is compromised without the prov and "Forensic information sought in my "Patient Questionnaire" Questionnaire." ination consists of a 27. Additionally, part of the independent medical exam history and background consultation with the examinee, in which us written standardized information is obtained, and administration of vario and scales goes to the tests and scales. The administration of such tests essence of such examinations. n of Plaintiff 28. I have been asked to perform a psychiatric examinatio an independent pursuant to a request in the above-styled cause for medical examination. to videotape the 29. I understand that Plaintiff's counsel has requested or both present in the room examination and have counsel, a court reporter, 7 EFTA Ri 02213411 EFTA02725864 Aug 18 09 11:19a Richard C. Hall, MD 407-322-8169 p.9 during the examination. 30. The presence of third-party observers, meaning persons other than the examiner and examinee, in the examining room is inconsistent with standardized administration of the tests and changes the testing environment considerably by introducing extraneous variables that may distract the examinee and alter the results of the IME. 31. A psychiatric examination, which consists of, but is not limited to, interview, mental status examination, and tests of intelligence, memory, attention, concentration, problem solving, sensory-perceptual functioning, motor functioning, psychomotor problem solving ability, is properly conducted in the absence of third parties from the examination site (i.e., court reporter, attorney, videographer). The presence of third parties often affects the examinee's responses to examination items and may alter or distract their stream of thought. 32. For the above reasons, I oppose having third parties present in the examination room during an examination. I may choose not to perform the standard examination in the presence of third parties (court reporter, attorney, videographer) except under Court order and with the caveat that the test results may be invalid. 8 EFTA R1 02213434 EFTA02725865 Aug 18 09 11:19a Richard C. Hall, MD 407-322-8169 p.10 e with the ethical 33. The examination of Plaintiff will be conducted in complianc psychiatrist. Plaintiff principles and code to which I am bound as a licensed relax, eat, drink, and visit will be allowed to take breaks, as she may need, to the restroom. an attorney present, but 34. In the event that I must conduct an examination with be no interruption in the outside the examination room, I request that there disrupt the examination examination. Interruptions will distract the Plaintiff, nt, the attorney should not and skew the validity of the examination. If prese g breaks or otherwise. coach the examinee during the examination or durin that will be necessary for 35. It is not possible to predict the exact amount of time Plaintiff an appropriate psychiatric examination of nt of information that will be because of unknown variables such as the amou pace at which Plaintiff will covered in the consultation segment and the perform the standardized tests. Such examinations generally take any break time), with approximately six to seven hours (excluding face-to-face consultation approximately four to six hours used for the for the testing segment. segment and approximately two to three hours used tiff to take approximately However, in this case, I anticipate the IME of Plain time. Additional time may be between five and eight hours, excluding break 9 EFTA R1 02213435 EFTA02725866 Aug 18 09 11:19a Richard C. Hall, MD 407-322-8169 p.11 her own, which most necessary for Ms. Andriano to complete testing on Ms. Andriano has not patients complete in 30 minutes to one hour. If "Forensic Questionnaire" completed the "Patient Questionnaire" and the her attorney prior to the before the examination, which was provided to n pertinent historical examination, additional time will be needed to obtai information. Respectfully submitted, $ r '- on AD Ryan C. W. Hall, MD Behavioral Medicine, University of Affiliate Instructor, Department of Psychiatry and South Florida Medical Education, University of Central Assistant Professor of Psychiatry, Department of Florida College of Medicine STATE OF FLORIDA COUNTY OF SEMINOLE appeared RYAN C.W. HAIL, BEFORE ME, the undersigned authority, personally has produced M.D., who iWf-personally known to me or ( ) who ses and says that the attached Affidavit is as identification, and who did take an oath, depo f. true and correct to the best of his knowledge and belie 10 EFTA RI r19911AIP EFTA02725867 Aug 18 09 11:19a Richard C. Hall, MD 407-322-8169 p.12 SWORN TO AND SUBSCRIBED before me on this liti\ day of 1;rt /e jl 2009. C.A-C31. / Sctnnt. C N 14 Note Public Printed Name: tApar ttek.-S nk-n-env61O My Commission Expires takirani-Vigrl C73581004 C.^^ -'t 6/8/2010 1 FICti...) *AM Asn•tj 11 EFTA_R1_02213437 EFTA02725868