(USANYS) [Contractor]
Summary
(USANYS) [Contractor] From: (USANYS) Sent: Monda , October 25, 2021 5:55 PM To: (USANYS); (USANYS); (USANYS) Subject: Call with Dr. Rocchio - 10/25/21 Call with Dr. Rocchio • Looked for a few hours and didn't any articles that had sections focused on third party presence • Has seen grooming the environment in forensic and clinical practice. Have provided treatment to adult men who were abused as children as part of boy scouts. Often they described a troop leader who was primary perpetrator, but often there was another adult/senior boy, who was also a victim but also used (or coerced) to procure or befriend other kids. • Does not specifically use the term "grooming the environment," but this is part of her views in general about grooming. • Perpetrators put themselves in positions where they have ready access. Locate themselves where there's a lower barrier for contact and reduce natural hesitancy because the perpetrator belongs there 3502-025 Page I of I SUBJ
Persons Referenced (2)
“...where there's a lower barrier for contact and reduce natural hesitancy because the perpetrator belongs there 3502-025 Page I of I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EF...”
Dr. Rocchio“...ober 25, 2021 5:55 PM To: (USANYS); (USANYS); (USANYS) Subject: Call with Dr. Rocchio - 10/25/21 Call with Dr. Rocchio • Looked for a few hours and didn't any articles that had sections focus...”
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EFTA DisclosureRelated Documents (6)
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
November 7, 2021 Call with Dr. Rocchio
November 7, 2021 Call with Dr. Rocchio AUSA • People who are sexually assaulted have higher likelihood of having PTSD • PTSD is an acute disorder — some of the symptoms involve distress when encounter reminders + efforts to avoid • Leap: it's highly unlikely they would engage in ongoing relationship/wear clothing/recreate sexual assault event (re Dietz's portion of defense expert notice) o No evidence to support that leap. That conclusion is not in the article o What is a sexual assault survivor "unnecessarily recreating a sexual assault event" — they aren't the ones recreating the events. Not clear what that means. Sexual assault is not created by the victim. o Ignores an entire body of literature regarding sexual assault in the context of an ongoing relationship, which is the vast majority of CSA cases. ■ Whether adult-child or adult-adult, b/c of the attachment, not at all unusual to maintain a relationship ■ Both of those relationships also involve elements of c
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
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
April 21, 2021 Call with Dr. Lisa Rocchio
April 21, 2021 Call with Dr. Lisa Rocchio • Dr. Rocchio's training is over the course of her career, not just in graduate school. The topics included traumatic stress (the effects of trauma), and clinical as well as forensic psychology. • Dr. Rocchio has written about, presented, and conducted numerous trainings on the assessment and treatment of trauma. • Dr. Rocchio also trains psychiatric residents at Brown in treating trauma survivors. • Dr. Rocchio's testimony is based on her education as well as her training, experience, and research. • Saying that victims are "susceptible" puts the onus on victims. It is more accurate to say that individuals or victims are "targeted." • Sexual abuse of minors frequently occurs through the use of manipulation or coercion in the context of an established relationship that is developed over time rather than through the use of forcible rape. • It's not fair to say that the presence of women can "especially" facilitate the sexual
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 OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S MOTIONS IN LIMINE 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 EFTA00088802 Table of Contents PRELIMINARY STATEMENT 1 ARGUMENT 4 I. The Court Should Admit the Testimony of Dr. 4 A. Applicable Law 5 B. Discussion 9 1. Dr. )pinions on Coercion and Attachment are Admissible 10 2. Dr. Opinion on the Relationship Between Trust and Victim Awareness of Their Abuse is Admissible 22 3. Dr. MINtDpinion on the Long-Term Consequences of Abuse is Admissible 23 4. Dr. Opinion About the Significance of the Presence of Third Parties is Admissible 25 5. Dr. Opinion on Delayed Disclosure is Admissible 27 II. The Evidence Contained in
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