Case 1:20-cr-00330-PAE Document 418-1 Filed 11/08/21 Page1of14 Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca Oo 150 East 10th Avenue Denver, Colorado 80203 HADDON PH 303.831.7364 MORGAN FX 303.832.2628 FOREMAN www.hmflaw.com [email protected] November 1, 2021 VIA EMAIL Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach 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: 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 DOJ-OGR-00006181