Document EFTA00010217 is an email from Nicole Simmons to Judge Alison J. Nathan regarding Ghislaine Maxwell's response to a motion to preclude expert testimony in the case U.S. v. Maxwell.
The email, dated November 13, 2021, transmits Ghislaine Maxwell's legal response to the government's attempt to exclude the expert testimony of Dr. Park Dietz and Dr. Elizabeth Loftus. The email indicates that the documents are being submitted under temporary seal to allow the government to propose redactions. The attachments include Maxwell's response and supporting exhibits.

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From: Nicole Simmons 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 Moth to Preclude Testimony of Dietz and Loftus] Date: Sat, 13 Nov 2021 01:54:30 +0000 Attachments: 2021.11.12_Maxwell_Response_to_Gov_Motion_to_Exclude_Dietz_and_Loftus.pdf; Ex._1.pdf; Ex._2.pdf Inline-Images: image001.jpg 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. EFTA00010217



