Email Chain / Legal Correspondence - EFTA00010184

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Extraction Summary

7

People

3

Organizations

1

Locations

1

Events

3

Relationships

1

Quotes

Document Information

Type: Email chain / legal correspondence

File Size: 49.5 KB

Summary

This document is an email chain from November 2021 related to the U.S. v. Maxwell trial (Case No. 20 Cr. 330). Defense attorney Nicole Simmons forwards a response to the government's motion to preclude the testimony of expert witnesses Dr. Park Dietz and Dr. Elizabeth Loftus to Judge Nathan's chambers. The documents were submitted under temporary seal to allow the government to review for necessary redactions.

People (7)

Name	Role	Context
Nicole Simmons	Attorney	Sender of the email to Judge Nathan; Attorney at Haddon, Morgan and Foreman, P.C.
Alison J. Nathan	Judge	Addressed as 'Dear Judge Nathan'; presiding over Case No. 20 Cr. 330
Jeff Pagliuca	Attorney	Cc'd on email; requested the submission of the response
Laura Menninger	Attorney	Cc'd on email
Ghislaine Maxwell	Defendant	Subject of the case (U.S. v. Maxwell); referred to as 'Ms. Maxwell'
Dr. Park Dietz	Expert Witness	Mentioned in the subject regarding preclusion of testimony
Dr. Elizabeth Loftus	Expert Witness	Mentioned in the subject regarding preclusion of testimony

Organizations (3)

Name	Type	Context
USANYS		U.S. Attorney's Office for the Southern District of New York (Sender/Receiver of top email)
Haddon, Morgan and Foreman, P.C.		Law firm representing Maxwell (Nicole Simmons' firm)
NYSD Chambers		New York Southern District Court Chambers

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 Court

Nicole Simmons Jeff Pagliuca Judge Nathan

View

Locations (1)

Location	Context
NYSD	Southern District of New York (Court location)

Relationships (3)

Nicole Simmons → Colleagues → Jeff Pagliuca

Both work on Maxwell defense; Simmons writes 'At the request of Jeffrey Pagliuca'

Ghislaine Maxwell → Defendant/Expert Witness → Dr. Park Dietz

Motion regarding expert testimony of Dr. Park Dietz for Maxwell's defense

Ghislaine Maxwell → Defendant/Expert Witness → Dr. Elizabeth Loftus

Motion regarding expert testimony of Dr. Elizabeth Loftus for Maxwell's defense

Key Quotes (1)

"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

EFTA00010184.pdf

Quote #1

Full Extracted Text

Complete text extracted from the document (1,280 characters)

From: [REDACTED](USANYS)" <[REDACTED]>
To: [REDACTED](USANYS)" <[REDACTED]>
Cc: [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 01:59:59 +0000
Attachments: 2021.11.12_Maxwell_Response_to_Gov_Motion_to_Exclude_Dietz_and_Loflus.pdf;
Ex._1.pdf; Ex._2.pdf
Inline-Images: image001.jpg

[REDACTED] – thought you would want to review. thanks again for your help

From: Nicole Simmons [REDACTED]
Sent: Friday, November 12, 2021 8:55 PM
To: 'Nathan NYSD Chambers' <[REDACTED]>
Cc: Jeff Pagliuca [REDACTED]; Laura Menninger [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.

EFTA00010184

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