DOJ Letter: Southern D.New, April 23, 2021, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN (EFTA00092510)

U.S. Department of Justice United States Attorney Southern District of New York BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon. Morgan and Foreman, P.C. Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim April 23, 2021 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Pursuant to Rule 16(a)(1)(G) of the Federal Rules of Criminal Procedure, the Government hereby provides notice that it may call as an expert witness at trial Dr. a clinical instructor of psychiatry and human behavior at the Alpert Medical School of Brown University. The Government reserves the right to call additional expert witnesses and will promptly provide notice if the Government elects to do so. I. Disclosure by the Government is the President-Elect of the Division of Trauma Psychology of the American Psychological Association ("APA"). Dr. has practiced psychology since earning her