Epstein Secrets

testimony Ms. Maxwell reserves the right to identify and rebut this testimony after the close of the government's case in chief. Very Truly Yours, Jeffrey S. Pagliuca Enclosures EFTA00075805

t's case in chief. Very Truly Yours, Jeffrey S. Pagliuca Enclosures EFTA00075805

Exhibit C is a list of material reviewed by Dr. Dietz. His testimony may include, but will not be limited to, the following: a. Opinions about Dr. Rocchio's Disclosed Opinions The first use of the word "grooming" to refer to strategies that sometimes enable nonforceful, nonthreatening, and nonviolent

sel: Haddon, Morgan and Foreman, P.0 Jeffrey S. Pagliuca 150 East lOth Avenue Denver, Colorado 80203 ww

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 t

legations of abuse have en verified by confession, witnesses, physical evidence, or other means. Other opinions put forth in the disclosure of Dr. Rocchio's proposed testimony also rest on assertions that are untestable, cannot be reproduced, and have no known error rate. b. Opinions About Hindsight B

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 th

t's case in chief. Very Truly Yours, Jeffrey S. Pagliuca Enclosures EFTA00090199

Exhibit C is a list of material reviewed by Dr. Dietz. His testimony may include, but will not be limited to, the following: a. Opinions about Dr. Rocchio's Disclosed Opinions The first use of the word "grooming" to refer to strategies that sometimes enable nonforceful, nonthreatening, and nonviolent

1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AIN) Dear Counsel: Haddon Morgan and Foreman, P.0 Jeffrey S. Paglluca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmllciw.COM [email protected] Defendant Ghislaine Maxwell t

t's case in chief. Very Truly Yours, Jeffrey S. Pagliuca Enclosures EFTA00090143

Exhibit C is a list of material reviewed by Dr. Dietz. His testimony may include, but will not be limited to, the following: a. Opinions about Dr. Rocchio's Disclosed Opinions The first use of the word "grooming" to refer to strategies that sometimes enable nonforceful, nonthreatening, and nonviolent

Daubert opinion on Rocchio, in case it's of interest. Thanks again! From: Nathan NYSD Chambers ‹ > Sent: Thursday, November 11, 2021 5:10 PM To: Jeff Pagliuca Laura Menninger Subject: 20cr330, US v. Maxwell Counsel: Attached please find an opinion and order issued by Judge Nathan. It will be docketed to

nt: Thursday, November 11, 2021 5:10 PM To: Jeff Pagliuca Laura Menninger Subject: 20cr330, US v. Maxwell

torney Southern District of New York One St. Andrew's Plaza New York. NY 10007 On Nov 11, 2021, at 5:17 PM, a alMIN> wrote: Daubert opinion on Rocchio, in case it's of interest. Thanks again! From: Nathan NYSD Chambers ‹ > Sent: Thursday, November 11, 2021 5:10 PM To: Jeff Pagliuca Laura Menning

District of New York 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 Denver, Colorado 80203 PH FX www.hmflaw.com [email protected] Defendant Ghislaine Maxwell through counsel, submit the following summary purs

sel: Haddon, Morgan and Foreman, P.0 Jeffrey S. Pagliuca Denver, Colorado 80203 PH FX www.hmflaw.com

Exhibit C is a list of material reviewed by Dr. Dietz. His testimony may include, but will not be limited to, the following: a. Opinions about Dr. Rocchio's Disclosed Opinions The first use of the word "grooming" to refer to strategies that sometimes enable nonforceful, nonthreatening, and nonviolent

New York, New York 10007 April 23, 2021 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon. Morgan and Foreman, P.C. Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim Re: United States v. Ghislaine Maxwell, 20 Cr. 330

the Government Dr. Lisa Rocchio is the President-Elect of the Division of Trauma Psychology of the American Psychological Association ("APA"). Dr. Rocchio has practiced psychology since earning her Ph.D. in 1995, and she is currently a clinical instructor at the Alpert Medical School of Brown Universi