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

ARGUMENT I. The Court Should Admit the Testimony of Dr. The Government intends to call Dr. •as an expert witness. Dr. Ms the President-Elect of the Division of Trauma Psychology at the American Psychological Association. She is currently a clinical instructor at the Alpert Medical School of Brown University, and she has pra

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

es and will promptly provide notice if the Government elects to do so. I. Disclosure by the Government Dr. Lisa Rocchio is the President-Elect of the Division of Trauma Psychology of the American Psychological Association ("APA"). Dr. Rocchio has practiced psychology since earning her Ph.D. in 1995, and she is currently a cli

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

pert witnesses and will promptly provide notice if the Government elects to do so. I. Disclosure by the Government Dr. is the President-Elect of the Division of Trauma Psychology of the American Psychological Association ("APA"). Dr. has practiced psychology since earning her Ph.D. in 1995, and she is currently a clinical i

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

al expert witnesses and will promptly provide notice if the Government elects to do so. I. Disclosure by the Government is the President-Elect of the Division of Trauma Psychology of the American Psychological Association ("APA"). Dr. has practiced psychology since earning her Ph.D. in 1995, and she is currently a clinical i