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Case 1:20-cr-00330-AJN Document 547 Filed 12/15/21 Page 2 of 2 With regard to “response pressure,” Professor Loftus may discuss the many different forms that suggestive processes can have on a witness’s memory. Dr. Rocchio testified, e.g., about "parental factors" that have no foundation in the record of this case. She discussed “violence between parents,” "the extent that the parents themselves have experienced any form of abuse in their own backgrounds," and the presence of a step-father in the home as all placing a child at a higher risk. TR. 732. She went on to discuss "family factors," including "families where there are other children in the home that are being abused or have been abused" being placed "at higher risk." /d. The government's attempt to limit expert testimony in the fashion they suggest is directly contrary to the information they elicited from their own expert on direct examination. Professor Loftus’ testimony on the effect of suggestive post-event information and "response pressure" is relevant and within her area of expertise. Suggestion can come from a variety of sources and there is no reason to restrict to expert testimony on the science of memory and factors that impact memory. The government puts forth no legal basis for its position and attempts to raise a baseless and untimely Daubert challenge. The government’s extreme efforts to restrict Ms. Maxwell’s right to put on a defense should not be countenanced by the Court. Very truly yours, /s/ BOBBI C. STERNHEIM cc: All counsel of record DOJ-OGR-00008386