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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
nd Justice Center. Prior to that, he was the Director of the U.S. Department of Justice, National Institute of Justice, Office of Investigative and Forensic Sciences. He has testified as an expert witness in numerous cases and has multiple professional honors in this field. His curriculum vitae is attached. Exhib
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
nd Justice Center. Prior to that, he was the Director of the U.S. Department of Justice, National Institute of Justice, Office of Investigative and Forensic Sciences. He has testified as an expert witness in numerous cases and has multiple professional honors in this field. His curriculum vitae is attached. Exhib
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
nd Justice Center. Prior to that, he was the Director of the U.S. Department of Justice, National Institute of Justice, Office of Investigative and Forensic Sciences. He has testified as an expert witness in numerous cases and has multiple professional honors in this field. His curriculum vitae is attached. Exhib
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
nd Justice Center. Prior to that, he was the Director of the U.S. Department of Justice, National Institute of Justice, Office of Investigative and Forensic Sciences. He has testified as an expert witness in numerous cases and has multiple professional honors in this field. His curriculum vitae is attached. Exhib
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
nd Justice Center. Prior to that, he was the Director of the U.S. Department of Justice, National Institute of Justice, Office of Investigative and Forensic Sciences. He has testified as an expert witness in numerous cases and has multiple professional honors in this field. His curriculum vitae is attached. Exhib
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
nd Justice Center. Prior to that, he was the Director of the U.S. Department of Justice, National Institute of Justice, Office of Investigative and Forensic Sciences. He has testified as an expert witness in numerous cases and has multiple professional honors in this field. His curriculum vitae is attached. Exhib
Entities connected to both Jeffrey Epstein and Forensic Sciences

Marc Rich
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
United States
LOCATION
Harry Reid
PERSON
Stephen Hawking
PERSONSouthern District
LOCATION
Steve Bannon
PERSON
Barry Diller
PERSON
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Bill Clinton
PERSON
Samantha Power
PERSON
Wilbur Ross
PERSON
Virginia Giuffre
PERSON
Seattle
LOCATIONEmmy Taylor
PERSON
Michael Jackson
PERSON