t), and Gov't Exhibits A and B; defense reply (Daubert section, redacted information regarding offense conduct); defense expert notice (sections on Dietz and Loftus only) 3502-037 Page 2 of 2 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00001705 EFTA00157046

eminders + efforts to avoid • Leap: it's highly unlikely they would engage in ongoing relationship/wear clothing/recreate sexual assault event (re Dietz's portion of defense expert notice) o No evidence to support that leap. That conclusion is not in the article o What is a sexual assault survivor "

Dallas Child Sexual Exploitation Seminar(1987. September 21-23). Sponsored by the Dallas. Texas Police Department, at the Dallas PD. Dallas. Texas. Dietz. P. E. (1983). Scx offenses: Behavioral aspects. In S. H. Kadish (Eds.). Encyclopedia of crime and Justice (pp. 1485-1493). New York. NY: Free Pres

gery. and paraphiliacs selectively gravitate to these activities as witnessed by the periodic scandals about pedo- philes working with youngsters- (Dietz, 1983, p. 1490). In January 1984, the FBI Law Enforcement Bulletin published a special issue about "Pedophilia." In this issue, two articles specif

evidence to suggest this is necessarily applicable. • Her point doesn't contradict anything. Memory can be impacted by later events. • The study Dietz focuses on relating to core details — based on a study for written narratives. • There are scientific studies that look for pediatric populations w

ng memory. Difficulties with memory is a symptom of PTSD and dissociative disorders. Absolutely trained and expert in memory. • Neither Loftus nor Dietz treat patients • Loftus: an expert on memory, but her area is proving that you can get people to believe things that didn't happen and misremember

immoral purposes. Police "attempted to question Dietz in September 2018, but Dietz stole a vehicle and left the area." The FBI offered a reward for Dietz and he was located this month. Pennsylvania Woman Sentenced For Sex Trafficking. The LNP Media (PA) (4/23, 77K) reports Melissa Madera of Reading,

ears in prison for second degree sex crimes against a child" and two counts of accosting a child for immoral purposes. Police "attempted to question Dietz in September 2018, but Dietz stole a vehicle and left the area." The FBI offered a reward for Dietz and he was located this month. Pennsylvania Wo

and used instead descriptive terms. After developing the basic categories, I consulted with Dr. Park Dietz, a forensic psychiatrist. Similarly Dr. Dietz advised that in his work he sometimes divided sex offenders into the two broad categories of situational and preferential (Dietz, 1983). His concept

ist. Similarly Dr. Dietz advised that in his work he sometimes divided sex offenders into the two broad categories of situational and preferential (Dietz, 1983). His concept was totally consistent with my new typology. With his permission I then incorporated the use of these descriptive terms into my

e 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 —Mil 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.

w, in a case like this one, suggestion can lead individuals to the construction of distorted memories. B. Park Dietz, M.D., M.P.H., PH.D. Dr. Park Dietz is a psychiatrist specializing in forensic psychiatry with over 40 years of experience. He has been previously qualified as an expert in psychiatry

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.pd

e 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. EFT

e 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. Th

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.pd

of the Government's expert witness, Dr. Lisa Rocchio. The Government on November 8, 2021, filed a motion to partially preclude the testimony of Dr. Dietz and Dr. Loftus. Dkt. No. 424. The Court has already addressed that motion. On November 15, 2021, the Government moved to fully or partially preclude

g in forensic psychiatry with over 40 years of experience. He has been previously qualified as an expert in psychiatry and forensic psychiatry. Dr. Dietz received a bachelor's degree in psychology and biology from the Cornell University College of Arts and Sciences (1970), an M.D. degree from the John

+0000 Hey Chris, I think all that's left is your response on Witness-3, and then the Court's order. We'll circulate our proposed redactions to the Dietz/Loftus briefing tomorrow after the conference. Thanks From: Christian Everdell <[email protected]> Sent: Monday, November 22, 2021 2:47 P

of the Government's expert witness, Dr. Lisa Rocchio. The Government on November 8, 2021, filed a motion to partially preclude the testimony of Dr. Dietz and Dr. Loftus. Dkt. No. 424. The Court has already addressed that motion. On November 15, 2021, the Government moved to fully or partially preclude

of the Government's expert witness, Dr. Lisa Rocchio. The Government on November 8, 2021, filed a motion to partially preclude the testimony of Dr. Dietz and Dr. Loftus. Dkt. No. 424. The Court has already addressed that motion. On November 15, 2021, the Government moved to fully or partially preclude

of the Government's expert witness, Dr. Lisa Rocchio. The Government on November 8, 2021, filed a motion to partially preclude the testimony of Dr. Dietz and Dr. Loftus. Dkt. No. 424. The Court has already addressed that motion. On November 15, 2021, the Government moved to fully or partially preclude

From: To: Cc: Subject: Motion to preclude Dietz and Loftus Date: Tue, 09 Nov 2021 04:54:24 +0000 Attachments: Motion_to_precluden ECF.pdf Here's the motion as to Dietz and Loftus. Assistant U.S

CA. USA Corresponding Author: Park Dim. Park Dieu & Associates, Newport Beach. CA 92663. USA. Emelt [email protected] EFTA00088780 Dietz 29 Keywords grooming, seduction, child sexual abuse, acquaintance molestation, litigation Grooming and Seduction In the development of knowledge

otion Hey Chris, I think all that's left is your response on Witness-3, and then the Court's order. We'll circulate our proposed redactions to the Dietz/Loftus briefing tomorrow after the conference. Thanks, From: Christian Everdell Sent: Monday, November 22, 2021 2:47 PM To: Subject: [EXTERNAL]