EFTA00029180.pdf

48.2 KB

Extraction Summary

7
People
3
Organizations
0
Locations
1
Events
2
Relationships
3
Quotes

Document Information

Type: Email correspondence / legal filing
File Size: 48.2 KB
Summary

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.

People (7)

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.

Organizations (3)

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.

Timeline (1 events)

2021-11-12
Submission of Maxwell's Response to Government's Motion In Limine to Preclude Expert Testimony of Dr. Park Dietz and Dr. Elizabeth Loftus under temporary seal.
NYSD (New York Southern District Court)

Relationships (2)

Nicole Simmons Professional/Colleague Jeffrey Pagliuca
Simmons sends email at the request of Pagliuca; both appear to be on defense team.
Nicole Simmons Professional/Colleague Laura Menninger
Menninger is Cc'd on Simmons' email.

Key Quotes (3)

"Hey [REDACTED] – this is the last thing for the binder. Thanks!"
Source
EFTA00029180.pdf
Quote #1
"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
EFTA00029180.pdf
Quote #2
"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
EFTA00029180.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (1,304 characters)

From: [REDACTED] <[REDACTED]>
To: [REDACTED] (USANYS) [Contractor]" [REDACTED]
Subject: FW: U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Resp to Govs Motn to Preclude Testimony of Dietz and Loftus]
Date: Sat, 13 Nov 2021 16:25:10 +0000
Attachments: 2021.11.12_Maxwell_Response_to_Gov_Motion_to_Exclude_Dietz_and_Loftus.pdf;
Ex._1.pdf; Ex._2.pdf
Inline-Images: image001.jpg
Hey [REDACTED] – this is the last thing for the binder. Thanks!
[REDACTED]
From: Nicole Simmons [REDACTED]
Sent: Friday, November 12, 2021 8:55 PM
To: 'Nathan NYSD Chambers' [REDACTED]
Cc: Jeff Pagliuca <[REDACTED]>; Laura Menninger [REDACTED]
[REDACTED]
Subject: [EXTERNAL] U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Resp to Govs Motn to Preclude Testimony of Dietz and Loftus]
Dear Judge Nathan:
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 along with supporting documents. 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.
Regards,
Nicole
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
[Logo]
[REDACTED BLOCK]
EFTA00029180

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