EFTA00025553

EFTA01658773

FIADDON

FIADDON MORGAN FOREMAN November 1, 2021 VIA EMAIL United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon Morgan and Foreman, P.0 Jeffrey S. Paglitica 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com [email protected] Defendant Ghislaine Maxwell through counsel, submit the following summary pursuant to Fed. R. Crim. P. 16(b)(1)(C). I. EXPERT DISCLOSURE BY THE DEFENSE A. Dr. Elizabeth Loftus Dr. Loftus is the Distinguished Professor of Psychological Science and Law at the University of California, Irvine School of Law. Dr. Loftus is one of the nation's leading experts on the science of memory. In addition to her experience as an academic and clinical researcher, she has been an expert witness or consultant in hundreds of cases. Her extensive experience and credentials are recited in her curric

EFTA Document EFTA01656066

EFTA Document EFTA01658773

H A D D O N

H A D D O N MORGAN FOREMAN November 1, 2021 VIA EMAIL United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon, Morgan and Foreman, P.0 Jeffrey S. Pagliuca 150 East lOth Avenue Denver, Colorado 80203 www.hrnflaw.com Defendant Ghislaine Maxwell through counsel, submit the following summary pursuant to Fed. R. Crim. P. 16(b)(1)(C). I. EXPERT DISCLOSURE BY THE DEFENSE A. Dr. Elizabeth Loftus Dr. Loftus is the Distinguished Professor of Psychological Science and Law at the University of California, Irvine School of Law. Dr. Loftus is one of the nation's leading experts on the science of memory. In addition to her experience as an academic and clinical researcher, she has been an expert witness or consultant in hundreds of cases. Her extensive experience and credentials are recited in her curriculum vitae. Exhibit A. It is expected that Dr. Lof

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From: " Cc Subject: SDNY News Clips Tuesday, June 25, 2019 Date: Tue, 25 Jun 2019 21:33:24 +0000 Importance: Normal Attachments: 2019 6-25.pdf SDNY News Clips Tuesday, June 25, 2019 EFTA00067645 Contents ivil NYCHA Complex Frauds and Cybercrime Pierce Kromah White Plains Parmar Henning Securities and Commodities Fraud Ceglia Public Corruption Calk Epstein Matters of Interest `Polite F-U Letters': DOJ Says Emails Show `Brazen' Illegal Coordination Among Drug Makers Civil NYCHA A Look at What NYCHA's New Chairperson Has Done with Minneapolis Public Housing New York 1 By Courtney Gross 6/24/19 Gregory Russ has only served as the head of the Minneapolis Public Housing Authority for a little more than two years. But come mid-August, he will be the new leader of New York City's sprawling public housing system — its lead paint, mold, and scandals included. Gross: Have you ever been in a NYCHA [New York City Housing Authority] apartment? Russ: I have walked