EFTA00016268.pdf

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Source set: data-set-8

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H A D D O N
MORGAN
FOREMAN
November 1, 2021
VIA EMAIL
United States Attorney's Office
Southern District of New York
Re:
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Haddon, Morgan and Foreman, P.0
Jeffrey S. Paglitica
PH
Fx
www.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 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
EFTA00016268

November 1, 2021
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described with confidence, detail, and emotion, just like true memories. This can occur when
people come to believe in these experiences and are not deliberately lying. Dr. Loftus would
identify some of the suggestive activities that occurred in the current case.
Suggestive activities can explain how it is that a person might go from having no memory
of sexual abuse, and even denying sexual abuse, to later having "memories" for numerous
abusive acts, if the memories are false. She will explain the mechanism …

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