This document is an email chain between Assistant United States Attorneys and legal staff from the Southern District of New York dated November 7-8, 2021. The discussion concerns the drafting of a 'Daubert motion' specifically intended to preclude the testimony of experts 'Dietz' and 'Loftus' (likely referring to defense experts in the Ghislaine Maxwell trial). The emails detail the collaborative writing process, assigning specific sections (Dietz, Loftus, Rocchio) to different team members with a deadline to get the draft to their 'chiefs' by the following morning.
| Name | Role | Context |
|---|---|---|
| Redacted Sender (Bottom Email) | Assistant United States Attorney |
Author of the initial email regarding the Daubert motion draft; works for SDNY.
|
| Redacted Sender (Middle Email) | Legal Team Member |
Working on the Rocchio section and incorporating the Loftus section.
|
| Redacted Sender (Top Email) | Legal Team Member |
Reviewing the motion, deferring to others on facts/law.
|
| Dietz | Subject of Legal Motion |
Likely an expert witness (Park Dietz) whose testimony the prosecution is moving to preclude.
|
| Loftus | Subject of Legal Motion |
Likely an expert witness (Elizabeth Loftus) whose testimony the prosecution is moving to preclude.
|
| Rocchio | Subject of Legal Section |
Subject of a specific section of the motion being drafted.
|
| Name | Type | Context |
|---|---|---|
| USANYS |
United States Attorney New York South (SDNY), appearing in email recipient fields.
|
|
| Southern District of New York |
Office of the Assistant United States Attorney sending the email.
|
| Location | Context |
|---|---|
|
Jurisdiction of the Assistant US Attorney.
|
"The plan is to have a draft in the chiefs’ inbox when they wake up"Source
"Motion_to_preclude_Dietz_and_Loftus_v5.moe.docx"Source
"I defer to you guys on the bigger picture stuff, since you're closer to the facts and the law here."Source
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