Page 1 of 6
_ Case 1:20-cr-00330-PAE Document 406 Filed 11/02/21 Page 1 of 6
aN U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
November 2, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
Pursuant to the Court’s order dated October 31, 2021, the parties write regarding the date
for the hearing on the defendant’s Rule 412 motion and the defendant’s motion to exclude the
testimony of Dr. Lisa Rocchio pursuant to Federal Rule of Evidence 702 and Daubert v. Merrell
Down Pharmaceuticals, Inc., 509 U.S. 579 (1993).
Government’s Position
Last night, defense counsel emailed the Government expert notice for eight individuals.
See Ex. A.' One of the individuals, Dr. Park Dietz, appears to offer opinions in direct response to
Dr. Rocchio’s, and another, Dr. Elizabeth Loftus, appears to offer opinions that relate to Dr.
Rocchio’s.
' The Government is submitting Exhibit A temporarily under seal with proposed redactions to give
the defense an opportunity to seek any additional redactions. The Government’s proposed
redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v.
Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter and its attached
exhibit are judicial documents subject to the common law presumption of access, the proposed
redactions are narrowly tailored to protect the privacy interests of victims (including victims who
have not identified themselves on the record in this case and who have not publicly identified
themselves as victims referenced in the Indictment in this case).
DOJ-OGR-00006043