EFTA00028211.pdf

45.4 KB

Extraction Summary

6
People
2
Organizations
1
Locations
1
Events
1
Relationships
3
Quotes

Document Information

Type: Email chain / legal correspondence
File Size: 45.4 KB
Summary

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.

People (6)

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.

Organizations (2)

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.

Timeline (1 events)

2021-11-08
Preparation of Daubert Motion to Preclude Dietz and Loftus
New York
SDNY Legal Team

Locations (1)

Location Context
Jurisdiction of the Assistant US Attorney.

Relationships (1)

Dietz Co-Subjects of Motion Loftus
Mentioned together in attachment filename: Motion_to_preclude_Dietz_and_Loftus_v5.moe.docx

Key Quotes (3)

"The plan is to have a draft in the chiefs’ inbox when they wake up"
Source
EFTA00028211.pdf
Quote #1
"Motion_to_preclude_Dietz_and_Loftus_v5.moe.docx"
Source
EFTA00028211.pdf
Quote #2
"I defer to you guys on the bigger picture stuff, since you're closer to the facts and the law here."
Source
EFTA00028211.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (1,606 characters)

From: [Redacted] <[Redacted]>
To: [Redacted] <[Redacted]>, "[Redacted] (USANYS)" <[Redacted]>, [Redacted] <[Redacted]>
Subject: RE: Daubert motion
Date: Mon, 08 Nov 2021 04:20:10 +0000
Attachments: Motion_to_preclude_Dietz_and_Loftus_v5.moe.docx
Here are one or two very small things. This looks great to me, and I defer to you guys on the bigger picture stuff, since you're closer to the facts and the law here. Thanks so much for everyone's excellent work on this—really impressive stuff.
From: [Redacted] <[Redacted]>
Sent: Sunday, November 7, 2021 10:04 PM
To: [Redacted] (USANYS) <[Redacted]>; [Redacted] <[Redacted]>; [Redacted] <[Redacted]>
Subject: RE: Daubert motion
Hi all,
Here's a version that incorporates the Loftus section. The plan is to have a draft in the chiefs' inbox when they wake up, so if folks are still up, would love comments as you can.
I'm going to write the Rocchio section now, so that will come later...
Thanks,
[Redacted]
From: [Redacted]
Sent: Sunday, November 7, 2021 8:00 PM
To: [Redacted] <[Redacted]>; [Redacted] <[Redacted]>; [Redacted] <[Redacted]>
Subject: Daubert motion
Hi team,
In the interest of expediency, here is the Daubert motion for your comments. I still need to write my section, and I'm doing some significant revisions to the Loftus section, but the Dietz section is done — [Redacted] crushed it. That's the bulk of the motion, so feel free to read that over, and I'll send you the rest in a second round later.
Thanks,
[Redacted]
Assistant United States Attorney
Southern District of New York
[Redacted]
[Redacted]
[Redacted]
EFTA00028211

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