EFTA00016949.pdf

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pdf

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data-set-8

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EXHIBIT 1 
EFTA00016949


U.S. Department of Justice 
United States Attorney 
Southern District of New York 
The Silvio J. Mello Building 
One Saint Andrew's Plaza 
New York, New York 10007 
April 23, 2021 
BY ELECTRONIC MAIL 
Christian Everdell, Esq. 
Mark Cohen, Esq. 
Cohen & Gresser LLP 
800 Third Avenue 
New York, NY 10022 
Laura Menninger, Esq. 
Jeffrey Pagliuca, Esq. 
Haddon, Morgan and Foreman, P.C. 
150 East Tenth Avenue 
Denver, CO 80203 
Bobbi Stemheim, Esq. 
Law Offices of Bobbi C. Stemheim 
33 West 19th Street-4th Fl. 
New York, NY 10007 
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 
ovides notice that it may call as an expert witness at trial 
a clinical 
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 
EFTA00016950


Page 2 
is expected to testify, based on her relevant education, training, experience, 
and research to the following: Individuals with particular vulnerabilities are often targeted by 
perpetrators of sexual abuse. Sexual abuse of minors frequently occurs through the use of 
manipulation or coercion in the context of an established relationship that is developed over time, 
rather than through the use of forcible rape. Minor victims are often subject to a strategic pattern 
of behaviors, often called grooming, that can take a variety of forms and function to render the 
victims vulnerable to abuse, to obscure the nature of the abuse, and to build trust and attachment 
with their abuser. The relationship of trust and attachment can prevent victims from being aware 
that what they are experiencing is abuse and can prevent disclosure. Minor victims therefore may 
not identify themselves as victims of abuse while it is ongoing, and may not recognize the 
consequences of that abuse until adulthood. …

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