EFTA00090186.txt Text dataset_9 View on DOJ

This document is a letter from Jeffrey S. Pagliuca, counsel for Ghislaine Maxwell, to the United States Attorney's Office, providing expert witness disclosures for the defense. The disclosures outline the areas of expertise and expected testimony of several experts, including those in memory, psychiatry, computer forensics, and financial analysis, in relation to the case against Maxwell.

Subject

United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)

Sender

Jeffrey S. Paglitica

Recipients

—

Document ID

20 Cr. 330 (AJN)

Date

2021-11-01

"[W]hen `grooming' is applied to such common and desirable behaviors as being kind or attentive or helpful or caring, there is considerable risk of misleading the fact finder into believing that these latter behaviors are well established predictors of child sexual abuse," when they are not.

Halo effects are a means to achieving cognitive consistency, which roughly refers to a state in which attitudes, perceptions, beliefs, predictions, and thoughts are aligned.

Not all allegations of sexual assault are true.

• Mentions media coverage and other publications (newspaper and magazine articles, news reports, television shows, documentaries, books, podcasts, websites, etc.) as sources of suggestion that can lead to distorted memories.

Context

This document is part of the legal proceedings against Ghislaine Maxwell, a case of significant public interest.

Media Worthy

Yes

Legal matters/litigationEmployment/staffingCommunications/correspondenceAllegations/complaints

Ghislaine MaxwellElizabeth LoftusPark DietzRocchioJeffrey EpsteinSteve BannonBill ClintonGerry EdelmanRyan HallBennett GershmanRobert KelsoGerald LaPorteJennifer NasoJessica EngleWilliam O'DonohueEmily R. DworkinAnna E. JaffeMichele Bedard-GilliganSkye FitzpatrickCaron ZlotnickMeredith Warshaw

Haddon Morgan ForemanUnited States Attorney's OfficeSouthern District of New YorkUniversity of California, Irvine School of LawCornell University College of Arts and SciencesJohns Hopkins University School of MedicineJohns Hopkins School of Hygiene and Public HealthUniversity of PennsylvaniaAmerican Board of Psychiatry and NeurologyUCLA School of MedicineUniversity of Virginia School of LawUniversity of Virginia School of MedicineHarvard Medical SchoolAmerican Academy of Psychiatry and the LawAmerican Psychiatric AssociationAmerican Academy of Forensic SciencesPark Dietz & Associates, Inc.Elisabeth Haub School of Law of Pace UniversityPace Law SchoolCornell Law SchoolSyracuse Law SchoolManhattan District Attorney's OfficeNew York State Anti-Corruption OfficeForensic PursuitUniversity of Colorado at BoulderUniversity of DenverJDL Services, Inc.Riley Welch LaPorte &Associates Forensic LaboratoriesFlorida International UniversityGlobal Forensic and Justice CenterU.S. Department of JusticeNational Institute of JusticeOffice of Investigative and Forensic SciencesUnited States Secret ServiceInternal Revenue ServiceCriminal InvestigationIRS-CI

New York, NYDenver, ColoradoArlington, VA

Tone

Professional

Purpose

To provide expert witness disclosures for the defense in the case of United States v. Ghislaine Maxwell.

Significance

This document outlines the expert witnesses the defense intends to call, their areas of expertise, and the topics they will address, including memory, psychiatry, computer forensics, and financial analysis.

File Name

EFTA00090186.txt

Dataset

dataset_9

Type

Text

Model

gemini-2.0-flash-001

Processed

2026-02-07T18:44:21.950141

DOJ Source

View on DOJ