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(USANYS) [Contractor]

(USANYS) [Contractor] From: (USANYS) Sent: Tuesda . November 2, 2021 5:39 PM To: (USANYS); (USANYS) Subject: Notes - November 2, 2021 Call with Dr. Rocchio November 2, 2021 Call with Dr. Rocchio • Discussed timing of Daubert hearing/logistics • LR mentioned she has continued to review literature relating to third parties and body of relevant literature related to predation behaviors • LR noted that Dal SMART defines grooming on its website and definition of grooming is same as LR's definition and consistent across fields Assistant United States Attorney United States Attorney's Office Southern District of New York One St. Andrew's Plaza New York, New York 10007 Tel: 3502-03 I Page 1 of I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00001654 EFTA00156995

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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

Ghislaine Maxwell's defense team moves to exclude the expert testimony of Dr. Lisa M. Rocchio, argui...

Ghislaine Maxwell's defense team moves to exclude the expert testimony of Dr. Lisa M. Rocchio, arguing that her opinions on grooming and victim behavior are unreliable and prejudicial. The motion cites Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharmaceuticals, and requests a Daubert hearing to assess the admissibility of Dr. Rocchio's testimony.

November 8, 2021 WebEx with Dr. Rocchio

November 8, 2021 WebEx with Dr. Rocchio TFO • In order to apply for internship at Yale, needed 450 hours of practice • In order to get licensed, need 2 years of full time practice, I needs to be pre-doctoral, each year has to be 1500 hours • Licensure: national exam, in certain states have a state exam on laws or ethics, etc. • Reviewed draft Daubers motion for Dietz and Loftus: o LR thinks it's not necessarily right that it's hard to assess whether grooming has occurred, but it's right that it's difficult to predict whether grooming will occur (prospectively) o Hindsight bias: many grooming articles point out that they operate in hindsight o Halo effect may be an argument about how offenders compartmentalize/hide from others. That's well-known offender behavior, they hold themselves out as pillars of community. o LR won't argue that false allegations are impossible, but they are rare o LR agrees that normal memory fades over time, can be fragmented, peripheral deta