Epstein Secrets

1500 hours • Licensure: national exam, in certain states have a state exam on laws or ethics, etc. • Reviewed draft Daubers motion for Dietz and Loftus: o LR thinks it's not necessarily right that it's hard to assess whether grooming has occurred, but it's right that it's difficult to predict wheth

ooming too. • Here, LR makes a point that DD is common, not making a specific claim about the relationship between DD and veracity • Rocchio and Loftus have another high-profile civil CSA case where they are opposing experts • Literature are examples that would be helpful, not intended to be artic

LR agrees that normal memory fades over time, can be fragmented, peripheral details can be distorted — central foundational principles of memory. o Loftus has introduced traumatic memories (e.g. dog attack) in a lab. Usually involves a trusted person, repetition, motivation. LR is not an expert on dece

uences • Third parties: mostly clinical literature, but grooming literature shows perpetrators try to use third parties to normalize situation • Duron article lays foundation for a discussion of coercive control • Delayed disclosure: o Betrayal trauma literature: abuse by a close other. Establish

it someone else. Latter exists in coercive control literature. • Does not use the term grooming by proxy, doesn't think it's a term that's used • Loftus herself teaches that inconsistencies are common in normal memory • Research shows that if there's a trusting/caregiving relationship between perpet

larification after reading our brief: o Will testify about generally well accepted principles in memory. Foundational principles, some derived from Loftus, well accepted in literature o Not an expert on memory o Key principles are in agreement o LR has gone to a training by Loftus • Very difficult

s intention, but context matters. Grooming is not a single act, it's a series of behaviors • Described articles o "Observing Coercive Control" by Duron, Johnson, et al. o 2009 study by Leclerc, et al. o "Toward a Universal Definition of Childhood Grooming" in June 2021 in Deviant Behavior by Winte

v't Exhibits A and B; defense reply (Daubert section, redacted information regarding offense conduct); defense expert notice (sections on Dietz and Loftus only) 3502-037 Page 2 of 2 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00001705 EFTA00157046

Dietz: o Whether grooming occurred, not hinging on credibility of individuals. Wide qualitative studies describing similar tactics and MOs • The Duron article talks explicitly about dynamics of coercive control across multiple types of victimization. Nothing about coercive control requires the perp