EFTA Document EFTA01653661

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Sihlo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 14, 2021 BY EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The parties respectfully submit this joint letter to provide the Court with a list of names, places, and relevant entities, for purposes of examining prospective jurors during voir dire. This letter is respectfully requested to be filed under seal to protect the privacy of witnesses and third parties. I. List of Names The following is a list of names that jurors may hear at trial: • Juan Alessi • Maria Alessi • • Janusz Banasiak • • Daniel Besselsen • • • • Michael Buscemi EFTA00040231 Page 2 • • Tracy Chappell • • Dr. Park Dietz

EFTA01659105

The letter from the U.S. Attorney's Office to defense counsel outlines the expected testimony of Com...

The letter from the U.S. Attorney's Office to defense counsel outlines the expected testimony of Computer Forensic Examiner Stephen Flatley regarding his analysis of digital devices and metadata. Flatley's testimony is expected to cover the forensic examination of devices, the process of creating 'clones' of digital media, and the analysis of metadata associated with certain files. The government asserts that Flatley's testimony is based on his first-hand knowledge and does not require expert testimony under Rule 702 of the Federal Rules of Evidence.

EFTA Document EFTA01659105

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

Court Filing: 715

The defense is objecting to the government's late disclosure of expert opinion testimony by Stephen Flatley, arguing that it was untimely and should be precluded. The government had previously claimed Flatley would only offer fact testimony, but the defense argues that the November 26, December 3, and December 5 disclosures reveal expert opinion testimony.