Epstein Secrets

K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S OMNIBUS MEMORANDUM

K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S OMNIBUS ME

exual abuse but not a necessary consequence of sexual abuse, jurors have no means to determine whether a Minor Victim is lying or telling the truth GM 7 The defendant also argues that Dr. is not an expert in "the human brain or memory generally." (Def. Mot. 3 at 17). The overnment agrees. But Dr.

m-3's allegations "may reflect conduct 43 EFTA00088845 undertaken in furtherance of the charged conspiracy or be relevant to prove facts such as Maxwell's state of mind." (id. at 26-27). B. Applicable Law It is axiomatic that the Government may offer proof of acts included within the indictment. Th

The defendant does not contest that Dr. IM is a qualified expert. Nor could she: Dr. =is a leader in her field, teaching others as a professor at Brown University, and she has approximately twenty-five years of clinical experience. She is testifying in general about core concepts in her field, based on her "e

ninger, Esq. Jeffrey Pagliuca, Esq. Haddon. Morgan and Foreman, P.C. Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Pursuant to Rule 16(a)(1)(G) of the Federal Rules of Criminal Procedure, the Government hereby provides notice that

obbi C. Stemheim Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Pursuant to Rule

fices of Bobbi C. Stemheim Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Pursuant

t it may call as an expert witness at trial Dr. Lisa Rocchio, a clinical instructor of psychiatry and human behavior at the Alpert Medical School of Brown University. The Government reserves the right to call additional expert witnesses and will promptly provide notice if the Government elects to do so. I. Dis

927, In the 151st Judicial District Court of Harris County, Texas Law Firm: Arnold & Itkin LLP 2016 Deposition Report Plaintiff Plaintiff, v. GHISLAINE MAXWELL, Defendant. Case #: I :15-cv-07433 United States District Court Southern District of New York Law Firms: Boies Schiller & Flexner LLP and

16 Deposition Report Plaintiff Plaintiff, v. GHISLAINE MAXWELL, Defendant. Case #: I :15-cv-07433 United States

tion Report Plaintiff Plaintiff, v. GHISLAINE MAXWELL, Defendant. Case #: I :15-cv-07433 United States

Other Undergraduate Research Student Degree Major University Role Arielle Amchin BS Marketing Penn State Research Mentor Arun Das BS CS Brown University Research Mentor Manisha Dareddy BS MIS Carnegie Mellon Qatar Research Mentor Satyajit Narayanan BS CS Bharati Vidyapeeth University Res

nue Denver, CO 80203 Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Pursuant to Rule 16(a)(1)(G) of the Federal Rules of Criminal Procedure, the Government hereby provides notice that

w York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Pursuant to Rule

th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Pursuant

("APA"). Dr. has practiced psychology since earning her Ph.D. in 1995, and she is currently a clinical instructor at the Alpert Medical School of Brown University, where she trains psychiatric residents in treating trauma survivors. Since she entered private practice in 1998, Dr. has specialized in treating p

ffrey Pagliuca, Esq. Haddon. Morgan and Foreman, P.C. Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim April 23, 2021 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Pursuant to Rule 16(a)(1)(G) of the Federal Rules of Criminal Procedure, the Government hereby provides notice that

April 23, 2021 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Pursuant to Rule

. Stemheim April 23, 2021 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Pursuant

("APA"). Dr. has practiced psychology since earning her Ph.D. in 1995, and she is currently a clinical instructor at the Alpert Medical School of Brown University, where she trains psychiatric residents in treating trauma survivors. Since she entered private practice in 1998, Dr. has specialized in treating p

On Apr 19, 2021, at 12:12 PM, wrote: Dr. Rocchio, Attached please find a draft of the expert notice we intend to provide to defense counsel in the Maxwell case regarding your anticipated testimony. Once you have had a chance to review, please let us know when would be a good time for a quick phone cal

notice we intend to provide to defense counsel in the Maxwell case regarding your anticipated testimony. Once

RI 02919 www.drilsarocchio.com www.rocchioassociates.com Clinical Instructor Department of Psychiatry and Human Behavior Alpert Medical School, Brown University Lisa M. Rocchio, Ph.D. Clinical and Forensic Psychologist Lisa M. Rocchio, Ph.D. & Associates, Inc. 1524 Atwood Avenue, Suite 222 Johnston, RI 0

ios (07/30, Walker), New York Times (07/30, Gold), Politico (07/30, Carney), and The Hill (07/30, Weaver). Grand Jury Witnesses Against Epstein and Maxwell Were All Investigators The New York Times (07/30, Weiser) reported that the DOJ has revealed that the witnesses who testified before federal grand

ealed that the witnesses who testified before federal grand juries in New York investigating sex-trafficking allegations against Jeffrey Epstein and Ghislaine Maxwell were all members of law enforcement, including an FBI agent and a New York City police detective who was part of the FBI's child exploitati

als • U.S. Repatriates a Child From Sprawling Camp in Northeastern Syria Holding Families of ISIS Fighters • Trump Administration Strikes Deal With Brown University to Restore Funding WASHINGTON SCHEDULE IN THE NEWS FBI To Establish Base In New Zealand, After Director Patel Visit Reuters (07/30, Craymer) repo

ed May 31. 2007. to Financial Trust Company, Inc. Financial Trust Company, Inc. Corporate Directors/Board Members: Jeffrey Epstein, Cecile DeJongh, Ghislaine Maxwell Shareholders: Jeffrey Epstein FTC0001 EFTA00233115 ipciuN4T STAPLE OR FOLD • ma Contratpungrer 33333 I For Official hoe Only Pr

2007. to Financial Trust Company, Inc. Financial Trust Company, Inc. Corporate Directors/Board Members: Jeffrey Epstein, Cecile DeJongh, Ghislaine Maxwell Shareholders: Jeffrey Epstein FTC0001 EFTA00233115 ipciuN4T STAPLE OR FOLD • ma Contratpungrer 33333 I For Official hoe Only Pr OMB No.13

Z. Dershowitz AV P_eer Review Rated Victoria B. Eiger, (Member) born Suffern, New York, 1951; admitted to bar, 1977, New. 1981, New York. Education: Brown University (A.B., 1973); Rutgers University (J.D., 19; Practice Areas: Criminal Appeals; Civil Litigation; Complex Litigation; Post-Conviction Eh Email: Victo

ennium Management does not assume any responsibility or liabikty for the information presented about UBS or the AlphaKeys Millennium Funds. --- 1837-MAXWELL (SUBS Private and confidential 2 CONFIDENTIAL UBSTERFtAMAR00001170 EFTA00236816 AlphaKeys Millennium Funds its capital in Millennium Partne

for Municipal Derivatives before transitioning to Head of Fixed Income Derivatives Marketing for Financial Institutions. Mr. Nagpal has a B.A. from Brown University and a Masters in public policy from the John F. Kennedy School of Government at Harvard University. Simon Lorne Vice Chairman - Chief Legal Office

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 11/11/21 20-CR-330 (MN) OPINION & ORDER ALISON J. NATHAN, District Ju

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTR

ns to express opinions on these subjects. Dr. Rocchio has a PhD in clinical psychology and is a clinical instructor at the Alpert Medical School of Brown University. She has more than two decades of experience treating hundreds of victims of trauma, many of which were minor victims of sexual abuse. She has publ

mental state when performing the behaviors. Second, the Court finds that Dr. Rocchio's opinions are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as the Second Circuit has explained, expert testimony cannot "constitute evaluations of witness credi

ns are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as