Epstein Secrets

acteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualiz

r 1, 2021 VIA EMAIL United States Attorney's Office Southern District of New York 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

cepted theory of grooming by third parties or empirical evidence regarding the prevalence, characteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed mi

Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon

rcumstances surrounding the evaluation, disclosures made by Ms. and the fact that Ms. did not identify Ms. Maxwell as a perpetrator of any abuse. D. Bennett Gershman Professor Gershman is a Distinguished Professor of Law at the Elisabeth Haub School of Law of Pace University since its founding as the Pace Law Sc

r 1, 2021 VIA EMAIL United States Attorney's Office Southern District of New York 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. Paglitica 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364

cepted theory of grooming by third parties or empirical evidence regarding the prevalence, characteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed mi

Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon

acteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualiz

e will offer the opinions and diagnoses contained in his report. the bases for those opinions, and the significance of the diagnoses and opinions. D. Bennett Gershman Professor Gershman is a Distinguished Professor of Law at the Elisabeth Haub School of Law of Pace University since its founding as the Pace Law Sc

r 1, 2021 VIA EMAIL United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AIN) Dear Counsel: Haddon Morgan and Foreman, P.0 Jeffrey S. Paglluca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364

cepted theory of grooming by third parties or empirical evidence regarding the prevalence, characteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed mi

Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AIN) Dear Counsel: Haddon

acteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualiz

e will offer the opinions and diagnoses contained in his report, the bases for those opinions, and the significance of the diagnoses and opinions. D. Bennett Gershman Professor Gershman is a Distinguished Professor of Law at the Elisabeth Haub School of Law of Pace University since its founding as the Pace Law Sc

w York New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon,

acteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualiz

RGAN FOREMAN November 1, 2021 VIA EMAIL United States Attorney's Office Southern District of New York New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon, Morgan and Foreman, P.0 Jeffrey S. Pagliuca Denver, Colorado 80203 PH FX www.hmflaw.com JPagliuca@hmf

cepted theory of grooming by third parties or empirical evidence regarding the prevalence, characteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed mi

ify about the facts an surrounding the evaluation, disclosures made b nd the fact that did not identify Ms. Maxwell as a perpetrator o any a use. D. Bennett Gershman Professor Gershman is a Distinguished Professor of Law at the Elisabeth Haub School of Law of Pace University since its founding as the Pace Law Sc

thern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon,

H A D D O N MORGAN FOREMAN November 1, 2021 VIA EMAIL United States Attorney's Office Southern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon, Morgan and Foreman, P.0 Jeffrey S. Paglitica PH Fx www.hmflaw.com Defendant Ghislaine Maxwell through

cepted theory of grooming by third parties or empirical evidence regarding the prevalence, characteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed mi

acteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualiz

rcumstances surrounding the evaluation, disclosures made by Ms. and the fact that Ms. did not identify Ms. Maxwell as a perpetrator of any abuse. D. Bennett Gershman Professor Gershman is a Distinguished Professor of Law at the Elisabeth Haub School of Law of Pace University since its founding as the Pace Law Sc