(USANYS) [Contractor]
Summary
(USANYS) [Contractor] From: (USANYS) Sent: Sunda , October 24, 2021 10:16 PM To: (USANYS) (USANYS); Subject: Notes from 10/24/2021 Call with Dr. Rocchio 10/24/2021 Call with Dr. Rocchio (USANYS) • Will send articles on grooming • No definitive articles on any one topic, but articles are samples from the literature • Has not yet identified articles focused on presence of third parties as part of grooming process, but topic in some articles • Pointed to Bureau of Justice Statistics re delayed disclosure 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: 3502-009 Page I of I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00001372 EFTA00156713
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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
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. PairBoca 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 cur
(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
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
To: Lisa
From: 0 To: Lisa Lisa Rocchio <[email protected]> Cc: ' " I, ' SANYS " H Subject: Draft expert notice Date: Mon, 19 Apr 2021 16:12:24 +0000 Attachments: 2021.04.XX_Expert_Notice_DRAFT.pdf Dr. Rocchio, Attached please find a draft of the expert notice we intend to provide to defense counsel in the Maxwell case regarding your anticipated testimony. Once you have had a chance to review, please let us know when would be a good time for a quick phone call to confirm the accuracy of this notice. Thanks very much, Maurene Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 212-637-2324 EFTA00105697
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION IN LIMINE TO PRECLUDE EXPERT TESTIMONY OF DR. PARK DIETZ AND DR. ELIZABETH LOFTUS DAMIAN WILLIAMS United States Attorney for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Assistant United States Attorneys Of Counsel EFTA00070837 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 I. THE COURT SHOULD PRECLUDE CERTAIN OPINIONS FROM DR. DIETZ 1 A. Background 1 B. Legal Standard 5 C. Discussion 8 I. Response to the Opinions of Dr. Rocchio 8 2. Opinions as to Hindsight Bias 11 3. Opinions as to the "Halo Effect" 14 4. Opinions as to "Pathways to False Allegations of Sexual Assault" 17 5. Opinions Regarding the Credibility of Witnesses 21 6. Opinions Regarding Post-Traumatic Stress Symptoms 22 II. CERTAIN ASPECTS OF THE PROPOSED EX
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