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Case 1:20-cr-00330-PAE Document 499 Filed 11/23/21 Page5of28 Ghislaine Maxwell submits this Response to the Government’s Motion in Limine to Preclude Expert Testimony of Dr. Park Dietz and Dr. Elizabeth Loftus. INTRODUCTION AND SUMMARY OF THE ARGUMENT The government asks this Court to drastically limit the expert opinions of Dr. Park Dietz and Dr. Elizabeth Loftus. The government’s motion seeks to unfairly capitalize on this Court’s decision largely overruling Ms. Maxwell’s Daubert challenge to the government’s expert, Dr. Lisa Rocchio. If the government gets its way, Dr. Rocchio will present the jury with a one-sided version of events while Ms. Maxwell will be crippled in her ability to respond. This Court should not permit the asymmetry the government hopes to create. There is no dispute that Drs. Dietz and Loftus are supremely qualified in their respective areas of expertise. Attached as Exhibit 1 is the defense disclosure of the expert opinions of Dr. Dietz and Dr. Loftus. That 374-page document includes eleven exhibits (Exhibits A — K) describing the qualifications and bases of the opinions Ms. Maxwell’s experts will offer at trial. Dr. Dietz is so well-regarded that Dr. Rocchio herself has relied on his opinions, Exhibit 2, p 58:1-24 (transcript of Nov. 10, 2021 hearing), and Dr. Loftus all but wrote the book on the science of memory. Unable to challenge the qualifications of either Dr. Dietz or Dr. Loftus, the government’s motion mischaracterizes their proposed opinions in an effort persuade this Court that they either invade the province of the jury or are unhelpful to the finder of fact. This Court should not fall for the government’s construction of strawmen. Beyond their responsiveness to Dr. Rocchio’s testimony, Dr. Dietz’s and Dr. Loftus’s expert opinions are independently relevant because they will help the jury understand the facts of this case. To the extent the government contends these opinions don’t “fit,” that objection is flat- out wrong or at least premature, since the government hasn’t put any evidence on yet. Because DOJ-OGR-00007470