What is document EFTA00010184?

It is an email exchange related to the legal case *U.S. v. Ghislaine Maxwell*. It concerns Maxwell's response to the government's motion to prevent expert testimony from Dr. Park Dietz and Dr. Elizabeth Loftus, who were expected to testify about the reliability of memories.

Who is mentioned in this document?

Key individuals mentioned include Ghislaine Maxwell, Judge Alison J. Nathan, Dr. Park Dietz, Dr. Elizabeth Loftus, Jeffrey Pagliuca, and Nicole Simmons. The law firm Haddon, Morgan and Foreman, P.C. is also mentioned.

What does this document reveal?

This document reveals the legal strategies employed by Ghislaine Maxwell's defense team. It shows their efforts to introduce expert testimony, specifically from Dr. Dietz and Dr. Loftus, to challenge the reliability of the alleged victims' memories. The government was attempting to preclude this testimony.

What is document EFTA00010184?

It is an email exchange related to the legal case *U.S. v. Ghislaine Maxwell*. It concerns Maxwell's response to the government's motion to prevent expert testimony from Dr. Park Dietz and Dr. Elizabeth Loftus, who were expected to testify about the reliability of memories.

Who is mentioned in this document?

Key individuals mentioned include Ghislaine Maxwell, Judge Alison J. Nathan, Dr. Park Dietz, Dr. Elizabeth Loftus, Jeffrey Pagliuca, and Nicole Simmons. The law firm Haddon, Morgan and Foreman, P.C. is also mentioned.

What does this document reveal?

This document reveals the legal strategies employed by Ghislaine Maxwell's defense team. It shows their efforts to introduce expert testimony, specifically from Dr. Dietz and Dr. Loftus, to challenge the reliability of the alleged victims' memories. The government was attempting to preclude this testimony.

EFTA00010184

Document EFTA00010184 is an email chain concerning the case *U.S. v. Ghislaine Maxwell, Case No. 20 Cr. 330 (AJN)*, specifically regarding Ghislaine Maxwell's response to the government's motion to preclude the testimony of expert witnesses Dr. Park Dietz and Dr. Elizabeth Loftus.

The email, dated November 12, 2021, includes attachments of Maxwell's response to the government's motion and supporting documents. The documents were submitted to the court under temporary seal at the request of Jeffrey Pagliuca, to allow the government to propose any necessary redactions. The email was sent to Judge Alison J. Nathan. This document highlights the legal strategies employed by Maxwell's defense team, specifically their reliance on expert testimony related to memory and potential manipulation or distortion of memories.

Key Highlights

•Ghislaine Maxwell's legal team responded to the government's attempt to exclude expert testimony from Dr. Park Dietz and Dr. Elizabeth Loftus.
•The response was submitted to Judge Alison J. Nathan under temporary seal.
•The defense sought to use expert testimony on memory and potential false memories.

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EFTA00010184

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Page 1 - EFTA00010184

From• SANYS)" To: USANYSI" Cc: Subject: FW: U.S. v. Maxwell, Case No. 20 Cr. 330 (AN) [Maxwell's Resp to Govs Motn to Preclude Testimony of Dietz and Loftus] Date: Sat, 13 Nov 2021 01:59:59 +0000 Attachments: 2021.11.12_Maxwell_Response_to_Gov_Motion_to_Exclude_Dietz_and_Loflus.pdf; Ex._1.pdf; Ex._2.pdf ['dine-Images: unage001.jpg ■— thought you would want to review. thanks again for your help From: Nicole Simmon Sent: Friday, November 12, 2021 8:55 PM To: 'Nathan NYSD Chambers' Cc: Jeff Pagliuca .; Laura Menninger Subject: [EXTERNAL] U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Resp to Govs Motn to Preclude Testimony of Dietz and Loftus] Dear Judge Nathan: At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Response to the Government's Motion In Limine to Preclude Expert Testimony of Dr. Park Dietz and Dr. Elizabeth Loftus along with supporting documents. Pursuant to our established protocol, we are submitting the Motion and Exhibits to the Court under temporary seal to allow the government to propose any redactions it deems necessary. Regards, Nicole Nicole Simmons Haddon, Morgan and Foreman, P.C. EFTA00010184