Dr. Park Dietz

COHEN & GRESSER LLP December 10, 2021 BY EMAIL. United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Counsel: Pursuant to the Court's Order dated June 2, 2021 (Dkt. 297), we write to provide the government with the list of potential defense witnesses. Included on the list are three attorneys: Brad Edwards, Robert Glassman, and Jack Scarola. Pursuant to the Court's instruction, we will brief any privilege issues to the Court before offering their testimony. We would also like the opportunity to confer about stipulations concerning their testimony and the testimony of other witnesses. Finally, we reserve the right to add or substitute witnesses as we further define the defense case. 1. • 2. 3. 4. 5. 6. 7. 8. Task Force Office 9. Lucy Mary Clive 10. Dr. Park Dietz 2063779.1 EFTA00156482 December 10, 2021 Page 2 11. 12. 13. Brad Edwards (atto

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, -v- Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY PILED DOC 0: DATE FILED:i 102121 20-CR-330 (AJN) MEMORANDUM OPINION & ORDER ALISON J. NATHAN, District Judge: The Defense on November 1, 2021, noticed eight expert witnesses. Def. Br., Ex. 1 ("Notice"). Two of those experts, Dr. Park Dietz and Dr. Elizabeth Loftus, are expected to offer opinions that rebut opinions 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 the testimony of the remaining six experts. The Defense filed a response on November 19, 2021. The Court addresses the motion to preclude Dr. Hall in this separate opinion. It will address the other five e

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 government moved for reconsideration of the court's order setting a deadline for filing motions to exclude defense expert witnesses. The court granted the motion in part, extending the deadline for certain witnesses, while denying it for others, specifically Dr. Park Dietz and Dr. Elizabeth Loftus.

This court filing is a summary of the defense's expert disclosures in the Ghislaine Maxwell case, featuring testimony from Dr. Elizabeth Loftus on human memory and false memories, and Dr. Park Dietz on psychiatry and behavioral science. The experts are expected to challenge the prosecution's evidence and expert opinions.

The document is a memorandum of law filed by the United States government in the case against Ghislaine Maxwell, arguing to preclude certain expert testimonies from Dr. Park Dietz and Dr. Elizabeth Loftus based on the Daubert standard and other legal precedents. The government contests various aspects of the proposed testimonies, including opinions on hindsight bias, false memory formation, and witness credibility. The memorandum aims to exclude or limit the defense's expert witnesses' testimonies.