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

er, (g) histrionic personality disorder, (h) delirium, (i) psychotic disorders, (j) dissociation, and (k) intellectual disability. Jessica Engle and William O'Donohue, Pathways to False Allegations of Sexual Assault, 12 J. Forensic Psychology Practice, 97. These pathways originate in the psychological proclivitie

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

efinition, and concerns have been raised that "there is no valid method to assess whether grooming has occurred or is occurring." Natalie Bennett & William O'Donohue, The Construct of Grooming in Child Sexual Abuse, 23 J. Child Sexual Abuse 957, 974 (2014). In any particular population of alleged victims, patien

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

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. is aware of no authority—no journal articles, no studies, no tests, nothing—to support a theory of g

into isolated cells in which none had complete information about his activities. These were not his only flaws, and Dr. 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

0 Cr. 330 (AJN) Haddon, Morgan and Foreman, P.0 Jeffrey S. Pagliuca 150 East lOth Avenue Denver, Colora

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

er, (g) histrionic personality disorder, (h) delirium, (i) psychotic disorders, (j) dissociation, and (k) intellectual disability. Jessica Engle and William O'Donohue, Pathways to False Allegations of Sexual Assault, 12 J. Forensic Psychology Practice, 97. These pathways originate in the psychological proclivitie

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

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.Mis aware of no authority—no journal articles, no studies, no tests, nothing—to support a theory of gr

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 150 East lOth Avenue Denver, Colora

er, (g) histrionic personality disorder, (h) delirium, (i) psychotic disorders, (j) dissociation, and (k) intellectual disability. Jessica Engle and William O'Donohue, Pathways to False Allegations of Sexual Assault, 12 J. Forensic Psychology Practice, 97. These pathways originate in the psychological proclivitie

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

er, (g) histrionic personality disorder, (h) delirium, (i) psychotic disorders, (j) dissociation, and (k) intellectual disability. Jessica Engle and William O'Donohue, Pathways to False Allegations of Sexual Assault, 12 J. Forensic Psychology Practice, 97. These pathways originate in the psychological proclivitie

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

er, (g) histrionic personality disorder, (h) delirium, (i) psychotic disorders, (j) dissociation, and (k) intellectual disability. Jessica Engle and William O'Donohue, Pathways to False Allegations of Sexual Assault, 12 J. Forensic Psychology Practice, 97. These pathways originate in the psychological proclivitie

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

er, (g) histrionic personality disorder, (h) delirium, (i) psychotic disorders, (j) dissociation, and (k) intellectual disability. Jessica Engle and William O'Donohue, Pathways to False Allegations of Sexual Assault, 12 J. Forensic Psychology Practice, 97. These pathways originate in the psychological proclivitie

tends represent "direct evidence" of a conspiracy (to recruit, groom, and sexually abuse minor females or to entice, transport or traffic them for Jeffrey Epstein's sexual pleasure) that Resp. at 36. 2 The proffered evidence is found at GX 401-404, 409-410 and 413 7 EFTA00090733 The government contends that

government clearly intends to rely on how open the alleged abuse was, the relevance of evidence that even the people who claim they were abused by Epstein during the same time frame but without any knowledge or participation by Ms. Maxwell becomes highly relevant to rebut such testimony. 12 EFTA00090

ELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN &

use. Exhibit A (literally) to the government's response is a journal article describing "grooming" as a "construct." Resp, Ex. A, Natalie Bennett & William O'Donohue, The Construct of Grooming in Child Sexual Abuse, 23 J. Child Sexual Abuse 957, 974 (2014). (In fact, Ms. Maxwell cited this article in her motion.