DAMIAN WILLIAMS

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------x UNITED STATES OF AMERICA : -v.- : S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, : Defendant. : ---------------------------------------------------------------x THE GOVERNMENT’S SENTENCING MEMORANDUM DAMIAN WILLIAMS United States Attorney Southern District of New York Attorney for the United States of America Maurene Comey Alison Moe Lara Pomerantz Andrew Rohr

From: USANYS)" c. To: Williams, Damian (USANYS. Date: 29 Nov 2021. Subject: Re: United States v. Ghislaine Maxwell

November 8, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Pursuant to the Court’s order (Dkt. No. 409), attached is Exhibit A to Dkt. No. 406 with the proposed redactions implemented. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Maurene Comey Alison Moe Lara Pomerantz Andrew

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION IN LIMINE TO PRECLUDE EXPERT TESTIMONY OF DR. PARK DIETZ AND DR. ELIZABETH LOFTUS DAMIAN WILLIAMS United States Attorney for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Assistant United States Attorneys Of Counsel EFTA00070837 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 I. THE COURT SHOULD PRECLUDE CERTAIN OPINIONS FROM DR. DIETZ 1 A. Background 1 B. Legal Standard 5 C. Discussion 8 I. Response to the Opinions of Dr. Rocchio 8 2. Opinions as to Hindsight Bias 11 3. Opinions as to the "Halo Effect" 14 4. Opinions as to "Pathways to False Allegations of Sexual Assault" 17 5. Opinions Regarding the Credibility of Witnesses 21 6. Opinions Regarding Post-Traumatic Stress Symptoms 22 II. CERTAIN ASPECTS OF THE PROPOSED EX

The document is a court filing in a criminal case (20cr0008089) submitted by Damian Williams, United States Attorney, along with several Assistant United States Attorneys. It was filed on December 2, 2020, in the Southern District of New York. The filing was copied to defense counsel via ECF.

The United States Attorney's office submits a redacted version of Exhibit A to Dkt. No. 406 as ordered by Judge Alison J. Nathan in the case against Ghislaine Maxwell. The submission is made by Damian Williams and several Assistant United States Attorneys. The document is filed via ECF and copied to defense counsel.