Court Exhibit: 424-4

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY PILED DOC 0: DATE FILED:i 102121 20-CR-330 (AJN) MEMORANDUM OPINION & ORDER ALISON J. NATHAN, District Judge: The Defense on November 1, 2021, noticed eight expert witnesses. Def. Br., Ex. 1 ("Notice"). Two of those experts, Dr. Park Dietz and Dr. Elizabeth Loftus, are expected to offer opinions that rebut opinions of the Government's expert witness, Dr. Lisa Rocchio. The Government on November 8, 2021, filed a motion to partially preclude the testimony of Dr. Dietz and Dr. Loftus. Dkt. No. 424. The Court has already addressed that motion. On November 15, 2021, the Government moved to fully or partially preclude the testimony of the remaining six experts. The Defense filed a response on November 19, 2021. The Court addresses the motion to preclude Dr. Hall in this separate opinion. It will address the other five e

EFTA00010184

PARK DIETZ & ASSOCIATES, INC.

PARK DIETZ & ASSOCIATES, INC. Forensic Experts Administrative Offices Tel: Fax: Email: Website: www.parkdietzassociates.corn • Forensic Psychiatry • Forensic Psychology • Forensic Pathology • Forensic Neurology • Forensic Social Work • Criminology • Security CURRICULUM VITAE (July 15, 2021) Park Dietz, M.D., M.P.H., Ph.D. CURRENT POSITIONS: 1996- President, Park Dietz & Associates, Inc., Newport Beach, California, and Washington, DC (Employer ID: 33- 0690184) (PD&A is a multidisciplinary forensic firm that grew out of a forensic psychiatry practice begun in 1978.) 1990- Clinical Professor of Psychiatry and Biobehavioral Sciences, Semel Neuropsychiatric Institute, David Geffen School of Medicine, University of California, Los Angeles 1987- President, Threat Assessment Group, Inc., Newport Beach, California (Employer ID: 54-1423864) (TAG is a workplace violence prevention firm offering training, products, and consulting services to mitigate behavioral

FIADDON

FIADDON MORGAN FOREMAN November 1, 2021 VIA EMAIL 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: Haddon Morgan and Foreman, P.0 Jeffrey S. Paglitica 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com JPagliuca@hmflaw.com 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 curric

EFTA01288458

This court filing is a summary of the defense's expert disclosures in the Ghislaine Maxwell case, fe...

This court filing is a summary of the defense's expert disclosures in the Ghislaine Maxwell case, featuring testimony from Dr. Elizabeth Loftus on human memory and false memories, and Dr. Park Dietz on psychiatry and behavioral science. The experts are expected to challenge the prosecution's evidence and expert opinions.