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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
e has been board certified in psychiatry by the American Board of Psychiatry and Neurology since 1979. He is a Clinical Professor of Psychiatry and Biobehavioral Sciences at the UCLA School of Medicine. From 1986 to 1989, he was a Professor of Law at the University of Virginia School of Law and a Professor of Behavio
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
e has been board certified in psychiatry by the American Board of Psychiatry and Neurology since 1979. He is a Clinical Professor of Psychiatry and Biobehavioral Sciences at the UCLA School of Medicine. From 1986 to 1989, he was a Professor of Law at the University of Virginia School of Law and a Professor of Behavio
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
e has been board certified in psychiatry by the American Board of Psychiatry and Neurology since 1979. He is a Clinical Professor of Psychiatry and Biobehavioral Sciences at the UCLA School of Medicine. From 1986 to 1989, he was a Professor of Law at the University of Virginia School of Law and a Professor of Behavio
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
e has been board certified in psychiatry by the American Board of Psychiatry and Neurology since 1979. He is a Clinical Professor of Psychiatry and Biobehavioral Sciences at the UCLA School of Medicine. From 1986 to 1989, he was a Professor of Law at the University of Virginia School of Law and a Professor of Behavio
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
e has been board certified in psychiatry by the American Board of Psychiatry and Neurology since 1979. He is a Clinical Professor of Psychiatry and Biobehavioral Sciences at the UCLA School of Medicine. From 1986 to 1989, he was a Professor of Law at the University of Virginia School of Law and a Professor of Behavio
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
e has been board certified in psychiatry by the American Board of Psychiatry and Neurology since 1979. He is a Clinical Professor of Psychiatry and Biobehavioral Sciences at the UCLA School of Medicine. From 1986 to 1989, he was a Professor of Law at the University of Virginia School of Law and a Professor of Behavio
da, October 16, 1987. 24. Kalt JP, Dietz PE, Cox JE Jr.: Economics and the Environment: New Challeng
torney, Milwaukee County, Wisconsin, in State v. Jeffrey L. Dahmer (serial murders of men) Consultant to
&A is a multidisciplinary forensic firm that grew out of a forensic psychiatry practice begun in 1978.) 1990- Clinical Professor of Psychiatry and Biobehavioral Sciences, Semel Neuropsychiatric Institute, David Geffen School of Medicine, University of California, Los Angeles 1987- President, Threat Assessment Grou
Entities connected to both Jeffrey Epstein and Biobehavioral Sciences

Marc Rich
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Stephen Hawking
PERSONSouthern District
LOCATION
Steve Bannon
PERSON
Department of Justice
ORGANIZATION
Bill Clinton
PERSON
Virginia Giuffre
PERSON
Paul Ryan
PERSON
Denver
LOCATION
Colorado
LOCATIONJeffrey Pagliuca
PERSON
Jennifer Lopez
PERSON
Arlington
LOCATION
Foreman
PERSON
Harvard Medical School
ORGANIZATIONHaddon
PERSON
Neurology
PERSON
Boulder
LOCATION