This document is an email chain from November 2021 regarding the legal case U.S. v. Maxwell. Attorney Nicole Simmons submits Ghislaine Maxwell's response to the government's motion to preclude the expert testimony of Dr. Park Dietz and Dr. Elizabeth Loftus to Judge Nathan's chambers. The documents were submitted under temporary seal to allow for government redaction proposals.
| Name | Role | Context |
|---|---|---|
| Nicole Simmons | Attorney |
Sender of the original email; attorney at Haddon, Morgan and Foreman, P.C.
|
| Alison Nathan | Judge |
Addressed as 'Dear Judge Nathan'; recipient of the email via 'Nathan NYSD Chambers'.
|
| Jeffrey Pagliuca | Attorney |
Cc'd on the email; requested the submission of the response.
|
| Laura Menninger | Attorney |
Cc'd on the email.
|
| Ghislaine Maxwell | Defendant |
Subject of the case (U.S. v. Maxwell) and the response being filed.
|
| Dr. Park Dietz | Expert Witness |
Subject of the Government's Motion In Limine to preclude testimony.
|
| Dr. Elizabeth Loftus | Expert Witness |
Subject of the Government's Motion In Limine to preclude testimony.
|
| Name | Type | Context |
|---|---|---|
| Haddon, Morgan and Foreman, P.C. |
Law firm representing the defense (Nicole Simmons).
|
|
| USANYS |
United States Attorney for the Southern District of New York (recipient of the forwarded email).
|
|
| Nathan NYSD Chambers |
Chambers of Judge Alison Nathan, Southern District of New York.
|
"Hey [REDACTED] – this is the last thing for the binder. Thanks!"Source
"At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Response to the Government’s Motion In Limine to Preclude Expert Testimony of Dr. Park Dietz and Dr. Elizabeth Loftus"Source
"Pursuant to our established protocol, we are submitting the Motion and Exhibits to the Court under temporary seal to allow the government to propose any redactions it deems necessary."Source
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