This document is an email chain from November 2021 pertaining to the case *U.S. v. Ghislaine Maxwell*, specifically concerning Ghislaine Maxwell's response to the government's motion to preclude testimony from expert witnesses Dr. Park Dietz and Dr. Elizabeth Loftus.
The email was sent to Judge Alison J. Nathan's chambers by Nicole Simmons, an attorney at Haddon, Morgan and Foreman P.C., at the request of Jeffrey Pagliuca. It includes attached documents: Maxwell's response to the government's motion and exhibits, submitted under temporary seal to allow the government to propose redactions. The attachments include legal documents related to the attempt to exclude expert testimony in the Ghislaine Maxwell case.

Perversion of Justice: The Jeffrey Epstein Story
Julie K. Brown
Investigative journalism that broke the Epstein case open

Filthy Rich: The Jeffrey Epstein Story
James Patterson
Bestselling account of Epstein's crimes and network

Relentless Pursuit: My Fight for the Victims of Jeffrey Epstein
Bradley J. Edwards
Victims' attorney's firsthand account
From• II< To: SANYS) [Contractor]" Subject: FW: U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Resp to Govs Mom to Preclude Testimony of Dietz and Loftus] Date: Sat, 13 Nov 2021 16:25:10 +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 Hey - this is the last thing for the binder. Thanks) From: Nicole Simmons Sent: Friday, November 12, 2021 8:55 PM To: 'Nathan NYSD Chambers' Cc: Jeff Pagliuca • ; Laura Mennin er 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. EFTA00029180



