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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
eving that these latter behaviors are well established predictors of child sexual abuse," when they are not. Park Dietz, Grooming and Seduction, 33 J. Interpersonal Violence, 28, 31 (2018). Dr. Rocchio characterizes "grooming" as "a strategic pattern of behavior[] ... that can take a variety of forms and function to ren
5 mentions1 same-page
Page ?Same page
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
lieving that these latter behaviors are well established MIIII. predictors of child sexual abuse," when they are not. . Grooming and Seduction, 33 J. Interpersonal Violence, 28, 31 (2018). Dr. characterizes "grooming" as "a strategic pattern of behavior[] ... that can take a variety of forms and function to render the
5 mentions1 same-page
Page ?Same page
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
into believing that these latter behaviors are well established predictors of child sexual abuse," when they are not. , Grooming and Seduction, 33 J. Interpersonal Violence, 28, 31 (2018). r. characterizes "grooming" as "a strategic pattern of behavior[] ... that can take a variety of forms and function to render the
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5 mentions1 same-page
Page ?Same page
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
eving that these latter behaviors are well established predictors of child sexual abuse," when they are not. Park Dietz, Grooming and Seduction, 33 J. Interpersonal Violence, 28, 31 (2018). Dr. Rocchio characterizes "grooming" as "a strategic pattern of behavior[] ... that can take a variety of forms and function to ren
5 mentions1 same-page
Page ?Same page
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
eving that these latter behaviors are well established predictors of child sexual abuse," when they are not. Park Dietz, Grooming and Seduction, 33 J. Interpersonal Violence, 28, 31 (2018). Dr. Rocchio characterizes "grooming" as "a strategic pattern of behavior[] ... that can take a variety of forms and function to ren
5 mentions1 same-page
Page ?Same page
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
eving that these latter behaviors are well established predictors of child sexual abuse," when they are not. Park Dietz, Grooming and Seduction, 33 J. Interpersonal Violence, 28, 31 (2018). Dr. Rocchio characterizes "grooming" as "a strategic pattern of behavior[] ... that can take a variety of forms and function to ren
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Mutual Connections (116)
Entities connected to both Jeffrey Epstein and J. Interpersonal Violence
Marc Rich
PERSON22,722 w/ Jeffrey·6 w/ J.
Prince Andrew
PERSON9,960 w/ Jeffrey·5 w/ J.
Ghislaine Maxwell
PERSON8,987 w/ Jeffrey·6 w/ J.
Stephen Hawking
PERSON4,011 w/ Jeffrey·2 w/ J.
Southern District
LOCATION3,325 w/ Jeffrey·6 w/ J.
Steve Bannon
PERSON2,999 w/ Jeffrey·6 w/ J.
Department of Justice
ORGANIZATION2,961 w/ Jeffrey·6 w/ J.
Bill Clinton
PERSON2,372 w/ Jeffrey·6 w/ J.
Virginia Giuffre
PERSON1,539 w/ Jeffrey·6 w/ J.
Paul Ryan
PERSON1,229 w/ Jeffrey·4 w/ J.
Denver
LOCATION878 w/ Jeffrey·6 w/ J.
Colorado
LOCATION805 w/ Jeffrey·6 w/ J.
JP
Jeffrey Pagliuca
PERSON577 w/ Jeffrey·6 w/ J.
Jennifer Lopez
PERSON479 w/ Jeffrey·2 w/ J.
Arlington
LOCATION204 w/ Jeffrey·6 w/ J.
Foreman
PERSON199 w/ Jeffrey·6 w/ J.
Harvard Medical School
ORGANIZATION155 w/ Jeffrey·6 w/ J.
HA
Haddon
PERSON133 w/ Jeffrey·3 w/ J.
Neurology
PERSON110 w/ Jeffrey·6 w/ J.
Boulder
LOCATION100 w/ Jeffrey·6 w/ J.