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 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 provides notice that it may call as an expert witness at trial Dr. a clinical instructor of psychiatry and human behavior at the Alpert Medical School of Brown University. 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 Dr. is the President-Elect of the Division of Trauma Psychology of the American Psychological Association ("APA"). Dr. has practiced psychology since earning her Ph.D. in 1995, and she is currently a clinical instructor at the Alpert Medical School of Brown University, where she trains psychiatric residents in treating trauma survivors. Since she entered private practice in 1998, Dr. has specialized in treating patients with trauma, including sexual trauma in childhood and adolescence. In the last twenty-three years, Dr. has treated hundreds of victims of trauma, many of whom were minor victims of sexual abuse. Dr. has also received specialized training in traumatic stress, sexual abuse, and clinical EFTA00080136