EFTA00016268.pdf
1.21 MB
Extraction Summary
16
People
18
Organizations
9
Locations
1
Events
4
Relationships
5
Quotes
Document Information
Type:
Legal correspondence (expert witness disclosure)
File Size:
1.21 MB
Summary
This document is a defense expert witness disclosure letter in the case United States v. Ghislaine Maxwell, dated November 1, 2021. It details the qualifications and expected testimony of eight expert witnesses, covering topics such as false memory (Dr. Loftus), the lack of scientific basis for 'grooming-by-proxy' (Dr. Dietz), forensic psychiatry, prosecutorial misconduct, computer forensics, and document authentication. The defense strategy aims to challenge the reliability of memory, rebut government claims about grooming behaviors, and analyze financial and physical evidence.
People (16)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Submitting expert disclosures through counsel.
|
| Jeffrey S. Pagliuca | Attorney |
Counsel for Ghislaine Maxwell, signatory of the letter.
|
| Dr. Elizabeth Loftus | Expert Witness (Defense) |
Distinguished Professor of Psychological Science and Law at UC Irvine. Expert on memory, false memories, and effects ...
|
| Dr. Park Dietz | Expert Witness (Defense) |
Psychiatrist specializing in forensic psychiatry. Will testify on grooming, hindsight bias, halo effect, and personal...
|
| Dr. Rocchio | Expert Witness (Government) |
Government expert whose opinions on 'grooming' are being rebutted by Dr. Dietz.
|
| Jeffrey Epstein | Deceased Co-conspirator |
Described as a 'brilliant man who was flawed by enduring personality traits' (Cluster B). Accused of sexual contact w...
|
| Dr. Ryan Hall | Expert Witness (Defense) |
Forensic Psychiatrist. Performed independent evaluation of a redacted individual in 2009.
|
| Bennett Gershman | Expert Witness (Defense) |
Distinguished Professor of Law at Pace University. Expert on prosecutorial misconduct and best practices.
|
| Robert Kelso | Expert Witness (Defense) |
CEO of Forensic Pursuit. Expert in computer forensics, user data, and metadata.
|
| Stephen Flatley | Expert Witness (Government) |
Government expert whose testimony may be rebutted by Robert Kelso.
|
| John Lopez | Expert Witness (Defense) |
Former IRS-CI Special Agent. Expert on financial investigations and fund transfers.
|
| Gerald LaPorte | Expert Witness (Defense) |
Forensic Chemist and Document Dating Specialist. Will analyze journal pages.
|
| Jennifer Naso | Expert Witness (Defense) |
Forensic Document Examiner. Will analyze authorship and authentication of documents (journals).
|
| Steve Bannon | Interviewer |
Conducted a videotaped interview with Jeffrey Epstein.
|
| Bill Clinton | Mentioned Person |
Mentioned by Epstein in the context of 'political power'.
|
| Gerry Edelman | Mentioned Person |
Mentioned by Epstein in the context of 'intellectual power'.
|
Organizations (18)
Timeline (1 events)
2009
Dr. Ryan Hall performed an independent medical and psychiatric evaluation of a redacted individual.
Unknown
Dr. Ryan Hall
[Redacted Individual]
Relationships (4)
Document discusses defense against accusations that Maxwell 'recruited and groomed minors to provide sexualized massages for Mr. Epstein'.
Dietz is providing rebuttal testimony to Rocchio's opinions on grooming.
Kelso may testify in rebuttal to any testimony offered by the government through Stephen Flatley.
Reference to videotaped interview [CONFIDENTIAL] SDNY_GM_SUPP_00219000.mov.
Key Quotes (5)
"Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy."Source
EFTA00016268.pdf
Quote #1
"Dr. Dietz is aware of no authority—no journal articles, no studies, no tests, nothing—to support a theory of grooming-by-proxy."Source
EFTA00016268.pdf
Quote #2
"The materials reviewed reflect that Jeffrey Epstein was a brilliant man who was flawed by enduring personality traits familiar to psychiatrists as 'Cluster B personality traits,' found among those with antisocial, narcissistic, borderline, and histrionic personality disorders."Source
EFTA00016268.pdf
Quote #3
"This vague opinion about 'grooming' carries the risk of imputing motive and intent to the Defendant... Moreover, this opinion carries the risk of implying that innocuous and even desirable behaviors are associated with nefarious or criminal conduct."Source
EFTA00016268.pdf
Quote #4
"In a videotaped interview with Steve Bannon, Epstein differentiated between different kinds of power—such as Bill Clinton's political power, wrestlers' and weight lifters' physical power, and Gerry Edelman's intellectual power—and acknowledged that he gravitated to people of power."Source
EFTA00016268.pdf
Quote #5
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