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

ng the fact finder into believing 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

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

ng the fact finder into believing 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

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

ng the fact finder into believing 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

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

ng the fact finder into believing 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