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Case 1:20-cr-00330-AJN Document 547 Filed 12/15/21 Page 1 of 2 LAW OFFICES OF BOBBI C. STERNHEIA\ 212-243-1100 * Main 225 Broadway, Suite 715 917-912-9698 * Cell New York, NY 10007 888-587-4737 ° Fax besternhein@mac.com December 15, 2021 Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan: The government’s limitation on Dr. Loftus’s testimony is a desperate attempt to restrict relevant testimony. Accusers were asked suggestive questions during interviews and prep sessions with the government. We anticipate that Agent Young will be testifying about the form of questions asked during such interviews and prep sessions. A review of the 3500 material and Jane's testimony exemplify the type of questioning the government posited during their investigation. By way of example, during cross examination, Jane was asked about the government’s repeated questioning regarding whether sexual abuse occurred in New Mexico, during two separate interviews and, during one of those interviews, three separate times. TR 512-516. Also, the government challenged Jane’s recollection that she had seen The Lion King on Broadway during her first trip to New York at age 14, outright suggesting that she saw the movie instead. When Jane’s counsel confirmed that she had seen the Broadway show, not the movie, AUSA Rossmiller told her lawyer that the government would just “assume” that The Lion King trip was not her first trip to New York, even though that is what Jane had reported to them. TR. 503-511; see 3509-010. True to form, at her very next call with the government a few weeks later, she followed their lead and “remembered” that the Lion King trip had not been her first trip to New York. See 3509-011. DOJ-OGR-00008385

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Filename DOJ-OGR-00008385.jpg
File Size 685.3 KB
OCR Confidence 94.2%
Has Readable Text Yes
Text Length 1,868 characters
Indexed 2026-02-03 17:34:23.670700