EFTA00016268.pdf

"United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)"

"Defendant Ghislaine Maxwell through counsel, submit the following summary"

"Defendant Ghislaine Maxwell through counsel, submit the following summary"

"EXPERT DISCLOSURE BY THE DEFENSE... Dr. Elizabeth Loftus... will focus on the memory aspects of this case."

"Dr. Dietz will be qualified as an expert in the areas of psychiatry and behavioral science."

"Dr. Loftus is the Distinguished Professor of Psychological Science and Law at the University of California, Irvine School of Law."

"in his role as President of Park Dietz & Associates, Inc."

"VIA EMAIL United States Attorney's Office Southern District of New York Re: United States v. Ghislaine Maxwell"

"In a videotaped interview with Steve Bannon, Epstein differentiated between different kinds of power"

"Ms. Maxwell reserves the right to supplement these opinions... Very Truly Yours, Jeffrey S. Pagliuca"

"We expect Professor Gershman to provide testimony on best practices to ensure the integrity of any prosecution, focusing on investigation, witness pre"

"We anticipate that Mr. Kelso will testify about the user data associated with certain devices seized and searched by the government's team in this cas"

"It is expected that Mr. Lopez will testify about his review of certain financial records provided by the government in discovery."

"Defendant anticipates... journal pages by witness [redacted]. These documents may require analysis regarding the dates of creation, completeness, alte"

"Ms. Naso is a Forensic Document Examiner... Defendant will seek to have them analyzed and present testimony on the analysis as needed."

"Ms. Maxwell recruited and groomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy."

"Jessica Engle and William O'Donohue, Pathways to False Allegations of Sexual Assault, 12 J. Forensic Psychology Practice, 97"

"Mr. Kelso may testify in rebuttal to any testimony offered by the government through Stephen Halley."

"Ms. Maxwell recruited and groomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy."

"being seen in their company empowered him and made him look above suspicion... acknowledged that he gravitated to people of power"

"Gerry Edelman's intellectual power—and acknowledged that he gravitated to people of power"

"Peace and colleagues (2015) conducted a narrative analysis of 147 sets of allegations of sexual assault"

"Hunt and Bull (2012) reviewed signs that can be used to differentiate true allegations"

"Hunt and Bull (2012) reviewed signs that can be used to differentiate true allegations"

"Emily R. Dworkin, Risk for Mental Disorders Associated with Sexual Assault: A Meta-Analysis, 21 Trauma, Violence, & Abuse (2020)"

"Emily R. Dworkin, Anna E. Jaffe, Michele Bedard-Gilligan, and Skye Fitzpatrick, PTSD in the Year Following Sexual Assault: A Meta-Analysis of Prospect"

"Caron Zlotnick, Meredith Warshaw, et al., Chronicity in Posttraumatic Stress Disorder (PTSD) and Predictors of Course of Comorbid PTSD in Patients wit"

"American Psychiatric Association, Diagnostic and Statistical Manual of Mental Disorders, 5th Ed., Arlington, VA: American Psychiatric Association (201"

"Arlington, VA: American Psychiatric Association (2013)"