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This is an internal email thread among federal prosecutors at the U.S. Attorney's Office for the Southern District of New York, dated November 7-8, 2021, discussing revisions to a Daubert motion to preclude defense expert witnesses Dr. Park Dietz and Dr. Elizabeth Loftus from testifying in the Ghislaine Maxwell trial.
This document reveals behind-the-scenes coordination among SDNY prosecutors preparing for the high-profile Ghislaine Maxwell sex trafficking trial. The emails show attorneys working late into the night (after 10 PM) on a Sunday, racing to finalize a legal motion challenging the admissibility of two prominent defense expert witnesses. Dr. Elizabeth Loftus is a renowned 'false memory' expert who has testified in major cases including O.J. Simpson and Harvey Weinstein trials, while Dr. Park Dietz is a forensic psychiatrist who testified in the John Hinckley Jr. case. The document also references Dr. Rocchio, a prosecution expert on 'grooming' behavior. This motion was part of the pre-trial Daubert proceedings that determined which expert testimony would be allowed before the jury.
Key Highlights
- •Prosecutors worked through the night to prepare a motion challenging Maxwell's defense experts
- •The motion targeted Dr. Elizabeth Loftus, a famous 'false memory' researcher, and Dr. Park Dietz, a forensic psychiatrist
- •Document shows the urgency of trial preparation—team wanted the draft ready 'when the chiefs wake up'
- •The Daubert motion was part of legal battles over whether victims' memories could be questioned at trial
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Filthy Rich: The Jeffrey Epstein Story
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Bestselling account of Epstein's crimes and network
Federal Rules of Civil Procedure 2025: Scannable Outlines & Real-World Samples for Motions, Discovery, Jury Trials
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EFTA00028212 - EFTA00028213
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From: To: • )" (USAIN I MIIME> Subject: RE: Daubert motion Date: Mon, 08 Nov 2021 04:25:54 +0000 Attachments: Motion_to_preclude_Dietz_and_Loflus_v5_-pm.docx For whatever reason I convinced myself that version control would be easier if I put my comments in comment form instead of in tracked changes, so here are a few nits (mostly catching my own errors). I will have the bandwidth to help finalize tomorrow; will start by proofing and cite-checking the version that goes to the chiefs and then can help incorporate any of their comments/do other revisions/etc. From: I Sent: Sunday, November 7, 202111:20 PM To: ) >; (USANYS) Subject: RE: Daubert motion > Here are one or two very small things. This looks great to me, and I defer to you guys on the bigger picture stuff, since you're closer to the facts and the law here. Thanks so much for everyone's excellent work on this—really impressive stuff. From: Sent: Sunday, November 7, 2021 10:04 PM To: (USANYS) Subject: RE: Daubert motion Hi all, Here's a version that incorporates the Loftus section. The plan is to have a draft in the chiefs' inbox when they wake up, so if folks are still up, would love comments as you can. I'm going to write the Rocchio section now, so that will come later... Thanks' From: Sent: Sunday, November 7, 2021 8:00 PM To: Subject: Daubert motion Hi team, In the interest of expediency, here is the Daubert motion for your comments. I still need to write my section, and I'm doing some significant revisions to the Loftus section, but the Dietz section is done crushed it. That's the bulk of the motion, so feel free to read that over, and I'll send you the rest in a second round later. EFTA00028212
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Thanks, Assistant United States Attorney Southern District of New York EFTA00028213
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