__ Case 1:20-cr-00330-PAE Document 406 Filed 11/02/21 Page 1 of 6 ae U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 2, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Pursuant to the Court’s order dated October 31, 2021, the parties write regarding the date for the hearing on the defendant’s Rule 412 motion and the defendant’s motion to exclude the testimony of Dr. Lisa Rocchio pursuant to Federal Rule of Evidence 702 and Daubert v. Merrell Down Pharmaceuticals, Inc., 509 U.S. 579 (1993). Government’s Position Last night, defense counsel emailed the Government expert notice for eight individuals. See Ex. A.' One of the individuals, Dr. Park Dietz, appears to offer opinions in direct response to Dr. Rocchio’s, and another, Dr. Elizabeth Loftus, appears to offer opinions that relate to Dr. Rocchio’s. ' The Government is submitting Exhibit A temporarily under seal with proposed redactions to give the defense an opportunity to seek any additional redactions. The Government’s proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter and its attached exhibit are judicial documents subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims (including victims who have not identified themselves on the record in this case and who have not publicly identified themselves as victims referenced in the Indictment in this case). DOJ-OGR-00006043