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pert witnesses and will promptly provide notice if the Government elects to do so. I. Disclosure by the Government Dr. is the President-Elect of the Division of Trauma Psychology of the American Psychological Association ("APA"). Dr. has practiced psychology since earning her Ph.D. in 1995, and she is currently a clinical i
U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One saint Andrew's Plaza New York, New York 10007 April 23, 2021 BY ELECTRONIC MAIL Christian Everdell
ARGUMENT I. The Court Should Admit the Testimony of Dr. The Government intends to call Dr. •as an expert witness. Dr. Ms the President-Elect of the Division of Trauma Psychology at the American Psychological Association. She is currently a clinical instructor at the Alpert Medical School of Brown University, and she has pra
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 PRELI
al expert witnesses and will promptly provide notice if the Government elects to do so. I. Disclosure by the Government is the President-Elect of the Division of Trauma Psychology of the American Psychological Association ("APA"). Dr. has practiced psychology since earning her Ph.D. in 1995, and she is currently a clinical i
U.S. Department of Justice United States Attorney Southern District of New York BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Hadd
Entities connected to both the Division of Trauma Psychology and Southern District

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATIONJeffrey Pagliuca
PERSON
Michael Cohen
PERSONLaura Menninger
PERSON
Julie K. Brown
PERSONBates
PERSON
Christian Everdell
PERSON
Foreman
PERSONCohen & Gresser LLP
ORGANIZATIONHaddon
PERSONMark Cohen
PERSONBobbi Stemheim
PERSONRocchio
PERSON
Brown University
ORGANIZATIONthe Alpert Medical School of Brown University
ORGANIZATIONthe Alpert Medical School
ORGANIZATIONthe APA Ethics Committee
ORGANIZATION