From: "Biasc, Nicholas (USANYS)"

EFTA00016268

DIGITALLY RECORDED

1 DIGITALLY RECORDED 2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: SWORN STATEMENT OF MARK EPSTEIN OTHER APPEARANCES: OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL SEPTEMBER 22, 2021 RESOLUTE DOCUMENTATION SERVICES Phone: 3 4 1 MR. The recorder has started. 1 2 MR. : This is Special Agent 2 MS. .• 3 with the Department of Justice, Office 3 4 of Inspector General. Today is Wednesday, 4 MR. EPSTEIN: And when you stated, my name 5 September 22, 2021. The time is 10:29 a.m. We 5 Mark is M-A-R-K. Not with a C., a K. 6 are here at the New York Field Office, at 6 MR. : Thank you for taking the time 7 Office of Inspector General. Present is Mr. 7 to talk to us today. 8 Mark Epstein, Attorney DO] 8 MR. EPSTEIN: Yeah. 9 Senior Special Agent , and 9 MR. : lust for the record, you are 10 myself. We are conducting an interview with 10 , Mr. Jeffrey Epstein's brother. 11 Mr. Mark Epstein in rega

H A D D O N

H A D D O N 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. PairBoca 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 cur

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION IN LIMINE TO PRECLUDE EXPERT TESTIMONY OF DR. PARK DIETZ AND DR. ELIZABETH LOFTUS DAMIAN WILLIAMS United States Attorney for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Assistant United States Attorneys Of Counsel EFTA00070837 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 I. THE COURT SHOULD PRECLUDE CERTAIN OPINIONS FROM DR. DIETZ 1 A. Background 1 B. Legal Standard 5 C. Discussion 8 I. Response to the Opinions of Dr. Rocchio 8 2. Opinions as to Hindsight Bias 11 3. Opinions as to the "Halo Effect" 14 4. Opinions as to "Pathways to False Allegations of Sexual Assault" 17 5. Opinions Regarding the Credibility of Witnesses 21 6. Opinions Regarding Post-Traumatic Stress Symptoms 22 II. CERTAIN ASPECTS OF THE PROPOSED EX

FD-302(Itev.541-I0)

DIGITALLY RECORDED

1 DIGITALLY RECORDED SWORN STATEMENT OF MARK EPSTEIN OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL SEPTEMBER 22, 2021 RESOLUTE DOCUMENTATION SERVICES EFTA00113482 2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: MARK EPSTEIN OTHER APPEARANCES: STACEY RICHMAN EFTA00113483 3 1 : The recorder has started. 2 : This is Special Agent 3 with the Department of Justice, Office 4 of the Inspector General. Today is Wednesday, 5 September 22, 2021. The time is 10:29 a.m. We 6 are here at the New York Field Office, in 7 Office of Inspector General. Present is Mr. 8 Mark Epstein. Attorney Stacey Richman. DOJ 9 Senior Special Agent And 10 myself. We are conducting an interview with 11 Mr. Mark Epstein in regards to Jeffrey 12 Epstein's investigation, of his death. I'm 13 going to introduce myself for the recording, 14 and I'm going to state my last name, also spell 15 it out. My name is Special Agent 16 17 : Se