Epstein Secrets

the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Response to the Government's Motion In Limine to Preclude Expert Testimony of Dr. Park Dietz and Dr. Elizabeth Loftus along with supporting documents. Pursuant to our established protocol, we are submitting the Motion and Exhibits to the Cou

Exhibits to the Court under temporary seal to allow the government to propose any redactions it deems necessary. Regards, Nicole Nicole Simmons Haddon, Morgan and Foreman, P.C. EFTA00010184

the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Response to the Government's Motion In Limine to Preclude Expert Testimony of Dr. Park Dietz and Dr. Elizabeth Loftus along with supporting documents. Pursuant to our established protocol, we are submitting the Motion and Exhibits to the Cou

Exhibits to the Court under temporary seal to allow the government to propose any redactions it deems necessary. Regards, Nicole Nicole Simmons Haddon, Morgan and Foreman P.C. EFTA00029180

in how, in a case like this one, suggestion can lead individuals to the construction of distorted memories. B. Park Dietz, M.D., M.P.H., PH.D. Dr. Park Dietz is a psychiatrist specializing in forensic psychiatry with over 40 years of experience. He has been previously qualified as an expert in psychiatry

tates Attorney's Office Southern 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 thro