Case 1:20-cr-00330-PAE Document 418-1 Filed 11/08/21 Page1of14
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
Ny 150 East 10th Avenue
Denver, Colorado 80203
HADDON PH 303.831.7364
MORGAN FX 303.832.2628
FOREMAN www.hmflaw.com
[email protected]
November 1, 2021
VIA EMAIL
Maurene Comey
Alison Moe
Lara Pomerantz
Andrew Rohrbach
United States Attorney’s Office
Southern District of New York
1 St. Andrew’s Plaza
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Defendant Ghislaine Maxwell through counsel, submit the following summary pursuant
to Fed. R. Crim. P. 16(b)(1)(C).
I. EXPERT DISCLOSURE BY THE DEFENSE
A. Dr. Elizabeth Loftus
Dr. Loftus is the Distinguished Professor of Psychological Science and Law at the
University of California, Irvine School of Law. Dr. Loftus is one of the nation’s leading experts
on the science of memory. In addition to her experience as an academic and clinical researcher,
she has been an expert witness or consultant in hundreds of cases. Her extensive experience and
credentials are recited in her curriculum vitae. Exhibit A.
It is expected that Dr. Loftus, a psychologist who specializes in the study of memory, will
focus on the memory aspects of this case. Based on her education, training, experience, and
research, her testimony will concern the workings of human memory, the effects of suggestion
on memory, the mechanism of creation of false memories, the characteristics of false memories,
how memory fades and weakens over time, and how memory becomes more vulnerable to
contamination. She will describe scientific research showing that false memories can be
DOJ-OGR-00006181