Case 1:20-cr-00330-AJN Document 547 Filed 12/15/21 Page 1 of 2
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December 15, 2021
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell
S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
The government’s limitation on Dr. Loftus’s testimony is a desperate attempt to restrict relevant
testimony. Accusers were asked suggestive questions during interviews and prep sessions with the
government. We anticipate that Agent Young will be testifying about the form of questions asked
during such interviews and prep sessions. A review of the 3500 material and Jane's testimony exemplify
the type of questioning the government posited during their investigation.
By way of example, during cross examination, Jane was asked about the government’s repeated
questioning regarding whether sexual abuse occurred in New Mexico, during two separate interviews
and, during one of those interviews, three separate times. TR 512-516. Also, the government challenged
Jane’s recollection that she had seen The Lion King on Broadway during her first trip to New York at
age 14, outright suggesting that she saw the movie instead. When Jane’s counsel confirmed that she had
seen the Broadway show, not the movie, AUSA Rossmiller told her lawyer that the government would
just “assume” that The Lion King trip was not her first trip to New York, even though that is what Jane
had reported to them. TR. 503-511; see 3509-010. True to form, at her very next call with the
government a few weeks later, she followed their lead and “remembered” that the Lion King trip had not
been her first trip to New York. See 3509-011.
DOJ-OGR-00008385