EFTA00070837.txt

"GHISLAINE MAXWELL, Defendant. S2 20 Cr. 330 (AJN)"

"DAMIAN WILLIAMS United States Attorney for the Southern District of New York"

"Dr. Dietz has reached his conclusions based solely on one interview of Epstein with Steve Bannon"

"DAMIAN WILLIAMS United States Attorney for the Southern District of New York... GHISLAINE MAXWELL, Defendant. S2 20 Cr. 330 (AJN)"

"the defense offers the opinions of Dr. Dietz, an expert psychiatrist"

"the defendant proposes to have Dr. Dietz and Dr. Loftus testify"

"the Government's expert Dr. Lisa Rocchio"

"she recruited and grooming minors to provide sexualized massages for Mr. Epstein"

"she recruited and grooming minors to provide sexualized massages for Mr. Epstein"

"the defense has clearly not to date carried the burden of establishing that the methods that led Dr. Dietz to offer this uncited and implausible opini"

"the defense has not carried its burden of establishing its reliability. See Fed. R. Evid. 702, 703; Daubert"

"Dated: November 8, 2021... Respectfully submitted, DAMIAN WILLIAMS"

"recruited and grooming minors to provide sexualized massages for Mr. Epstein"

"not from Dr. Dietz summarizing Dr. Loftus's research"

"The defense's offer of Dr. Dietz's opinions regarding the existence of false allegations of sexual assault"

"the defendant's appraisal of Jeffrey Epstein's character or whether the defendant did or did not view him in the manner suggested by the Halo effect"

"A number of Dr. Loftus's opinions were tested and rejected in United States v. Libby"

"Elizabeth F. Loftus, UCI School of Social Ecology, https://faculty.sites.uci.edu/eloftus/"