Epstein Secrets

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 M

ualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Dietz is aware of no authority—no journal articles, no studies, no tests, nothing—to support a theory

isolated cells in which none had complete information about his activities. These were not his only flaws, and Dr. Dietz is also prepared to address Jeffrey Epstein's sexual behavior should it prove relevant. d. Opinions Related to the Multiple Pathways to False Sex Assault Allegations Studies concerning the ac

) Dear Counsel: Haddon Morgan and Foreman, P.0 Jeffrey S. PairBoca 150 East 10th Avenue Denver, Colora

roomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Di

-related civil litigation. His extensive experience and credentials are recited in his curriculum vitae, annexed as Exhibit G. E. Robert Kelso Mr. Kelso is CEO of Forensic Pursuit. He has over 25 years of experience in computer forensics, engineering and software technology. He holds Bachelor's and M

ualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Dietz is aware of no authority—no journal articles, no studies, no tests, nothing—to support a theory

isolated cells in which none had complete information about his activities. These were not his only flaws, and Dr. Dietz is also prepared to address Jeffrey Epstein's sexual behavior should it prove relevant. d. Opinions Related to the Multiple Pathways to False Sex Assault Allegations Studies concerning the ac

) Dear Counsel: Haddon Morgan and Foreman, P.0 Jeffrey S. Paglitica 150 East 10th Avenue Denver, Color

roomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Di

-related civil litigation. His extensive experience and credentials are recited in his curriculum vitae, annexed as Exhibit G. E. Robert Kelso Mr. Kelso is CEO of Forensic Pursuit. He has over 25 years of experience in computer forensics, engineering and software technology. He holds Bachelor's and M

ualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Dietz is aware of no authority—no journal articles, no studies, no tests, nothing—to support a theory

isolated cells in which none had complete information about his activities. These were not his only flaws, and Dr. Dietz is also prepared to address Jeffrey Epstein's sexual behavior should it prove relevant. d. Opinions Related to the Multiple Pathways to False Sex Assault Allegations Studies concerning the ac

) Dear Counsel: Haddon Morgan and Foreman, P.0 Jeffrey S. Paglluca 150 East 10th Avenue Denver, Colora

roomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Di

-related civil litigation. His extensive experience and credentials are recited in his curriculum vitae, annexed as Exhibit G. E. Robert Kelso Mr. Kelso is CEO of Forensic Pursuit. He has over 25 years of experience in computer forensics, engineering and software technology. He holds Bachelor's and M

ualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Dietz is aware of no authority—no journal articles, no studies, no tests, nothing—to support a theory

isolated cells in which none had complete information about his activities. These were not his only flaws, and Dr. Dietz is also prepared to address Jeffrey Epstein's sexual behavior should it prove relevant. d. Opinions Related to the Multiple Pathways to False Sex Assault Allegations Studies concerning the ac

Dear Counsel: Haddon, Morgan and Foreman, P.0 Jeffrey S. Pagliuca Denver, Colorado 80203 PH FX www.

roomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Di

-related civil litigation. His extensive experience and credentials are recited in his curriculum vitae, annexed as Exhibit G. E. Robert Kelso Mr. Kelso is CEO of Forensic Pursuit. He has over 25 years of experience in computer forensics, engineering and software technology. He holds Bachelor's and M

x/Madison Rr sitaiamel DelacruziMenmn Cox/Madison Beer/Harry Sanchez/Carlos Mandelson/Peter Mandelson/Peter Galistmos/Ste hane Tin litir nt Epstein/J Galistinos/Stephane Amount Balance 000 338,275.71 902 60 339,178.31 239900 341,577.31 1.050 00 342.627.31 350 00 342,977.31 580.00 3

26/1999 33684 nvolce 5/25/1999 33635 nvoice 5/20/1999 33554 nvoice 5/19/1999 33529 nvoice 5/19/1999 33546 Name Schoenlcul) Epstein/J Kelso rut. Jones/Bruce Galibert/Jean Clau... TaytertEmma CantelobreNichel MaxwelliGhislaine M II/ hislaine Eficknen/Juhan Bc.kneU/Jullan Tayler/E

nian Natural Right," Ellen Frenkel, Fred Miller, Jeffrey Paul (eds.), Natural Law and Modem Moral Philos

, 13, 190 -194. 8 Strogatz, S. (2003). Rhythms of nature, rhythms of ourselves. London: Allan Lane. 9 Tognoli, E., Lagarde, J., DeGuzman, C. D., Kelso, J. A. S. (2007). The phi complex as a neuromarker of human social coordination. PNAS, 19, 8190- 8195. 10 • Oulher, O. & Kelso, J. A. S. (2009,

inian Natural Right,” Ellen Frenkel, Fred Miller, Jeffrey Paul (eds.), Natural Law and Modern Moral Philoso

nce, 13, 190 -194. * Strogatz, S. (2003). Rhythms of nature, rhythms of ourselves. London: Allan Lane. ? Tognoli, E., Lagarde, J., DeGuzman, C. D., Kelso, J. A. S. (2007). The phi complex as a neuromarker of human social coordination. PNAS, 19, 8190- 8195. ' Oullier, O. & Kelso, J. A. S. (2009, in pre

Dear Counsel: Haddon, Morgan and Foreman, P.0 Jeffrey S. Paglitica PH Fx www.hmflaw.com Defendant G

ualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Dietz is aware of no authority—no journal articles, no studies, no tests, nothing—to support a theory

roomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Di

ace, the health and legal systems, and even for decision making and consumer choices. (p. 286) Like many people who achieve great power and wealth, Jeffery Epstein exploited the Halo effect to surround himself with people who would serve his needs. At the most primitive level, his wealth attracted those seekin

will be contradicted by statements she made to Dr. Hall. And to be clear, Minor Victim-4's expected testimony about the defendant's involvement in Epstein's scheme is not inconsistent with the fact that Minor Victim-4 did not describe those instances to Dr. Hall. "It is well settled that for two statem

nt specialists. The defendant's expert notice is not clear regarding these witness's expected testimony and the bases for that testimony. Insofar as Kelso and will testify as fact witnesses, the Government does not object to that testimony. If they are expected to testify as 21 EFTA00024976 --- PA

ncial records and explain the information contained in the financial records." (Id.). These lists of topics do not permit the Government to identify Kelso and opinions, determine whether the proffered experts are in fact expert on those subjects, and litigate the reliability and relevance of those opi