This document is a defense expert witness disclosure letter in the case United States v. Ghislaine Maxwell, dated November 1, 2021. It details the qualifications and expected testimony of eight expert witnesses, covering topics such as false memory (Dr. Loftus), the lack of scientific basis for 'grooming-by-proxy' (Dr. Dietz), forensic psychiatry, prosecutorial misconduct, computer forensics, and document authentication. The defense strategy aims to challenge the reliability of memory, rebut government claims about grooming behaviors, and analyze financial and physical evidence.
This document is a court exhibit filed on October 29, 2021, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It consists of a page from the *Journal of Interpersonal Violence* containing a bibliography of academic papers regarding child sexual abuse, incest, and pedophilia, followed by an author biography for Dr. Park Dietz. Dr. Dietz is identified as a forensic psychiatrist and president of Park Dietz & Associates, specializing in child sexual abuse litigation and misconduct prevention.
This document is a page from a 2018 Minnesota Law Review article by Darryl K. Brown titled 'Criminal Enforcement Redundancy: Oversight of Decisions Not to Prosecute.' The text discusses the legal theory behind underenforcement of criminal law, specifically citing failures to prosecute sexual assaults and racially motivated crimes. While the text does not mention Epstein, the document bears the footer 'DAVID SCHOEN' (an attorney associated with Epstein) and a Bates stamp 'HOUSE_OVERSIGHT_016510', indicating it was part of an evidentiary production to the House Oversight Committee, likely as legal research regarding the controversial non-prosecution agreement Epstein received.
This document is a technical exhibit labeled 'Figure S2' from a House Oversight Committee production (Bates HOUSE_OVERSIGHT_017041). It displays a side-by-side comparison of a 1911 'Canadian Medical Association Journal' title page to demonstrate the results of image scanning and processing (before and after). The content appears to be used to validate or illustrate document digitization methods rather than providing substantive evidence regarding Epstein's activities.
This document is a page from an academic paper (Page 298) discussing moral psychology, specifically 'Attention to Motives' and 'Altruism Without Prospect of Reciprocation.' It cites various studies, including a 2014 paper by 'Rand & Epstein,' which is likely the reason for its inclusion in the House Oversight investigation files (Bates stamp HOUSE_OVERSIGHT_015510). The text uses the heroic death of Professor Liviu Librescu at Virginia Tech as an example of altruistic behavior.
An email chain from April 2017 between Jonathan Farkas and 'jeevacation' (Jeffrey Epstein). Farkas recounts meeting author John Connolly at a theater opening and discusses being excluded from a book. Epstein replies suggesting a book about 'false accusations,' drawing parallels between the University of Virginia case, a hockey team, Donald Trump's rape accusations, and his own situation ('mine is ripe with same').
This document is an email chain from April 7, 2017, between Jeffrey Epstein and Jonathan Farkas. They discuss arranging a meeting for Epstein with author John Connolly, who Farkas says was going to include him in a book because he was on Epstein's 'visitors list'. Epstein responds by suggesting the 'real money making book' would be about the 'truth of the claims' and lists several examples of what he considers unpunished false accusations.
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