EFTA00028212Set 8
2021-11-082p304w
From:
To: • )"
(USAIN
I MIIME>
Subject: RE: Daubert motion
Date: Mon, 08 Nov 2021 04:25:54 +0000
Attachments: Motion_to_preclude_Dietz_and_Loflus_v5_-pm.docx
For whatever reason ... revisions/etc.
From: I
Sent: Sunday, November 7, 202111:20 PM
To: ) >; (USANYS) >
Subject: RE: Daubert motion
Here are one or two very small things. This looks great ... stuff.
From:
Sent: Sunday, November 7, 2021 10:04 PM
To: (USANYS)
Subject: RE: Daubert motion
Hi all,
Here's a version that incorporates the Loftus section. The plan
https://www.justice.gov/epstein/files/DataSet%208/EFTA00028212.pdf
EFTA00028211Set 8
2021-11-081p216w
From:
To:
Subject: RE: Daubert motion
Date: Mon, 08 Nov 2021 04:20:10 +0000
Attachments: Motion_to_preclude_Dietz_and_Loflus_v5.moe.docx
Here are one or two very small things. This looks great ... Sunday, November 7, 2021 10:04 PM
To: (USANYS) c
sc M >
Subject: RE: Daubert motion
Hi all,
Here's a version that incorporates the Loftus section. The plan ... will come later...
Thanks,
From:
Sent: Sunday, November 7, 2021 8:00 PM
Subject: Daubert motion
Hi team,
In the interest of expediency, here is the Daubert motion for your
https://www.justice.gov/epstein/files/DataSet%208/EFTA00028211.pdf
EFTA00009983Set 8
2021-11-092p332w
From
To:
Cc: (USANYS)"
Subject: RE: Daubert motion
Date: Tue, 09 Nov 2021 03:37:45 +0000
Attachments: Exhibit_B.pdf
Thanks,
I'd been planning to redact the exhibits ... From
Sent: Monda November 8, 2021 9:43 PM
To: )
Cc: USANYS)
Subject: RE: Daubert motion
Thanks very much, I've reviewed and have no substantive edits. There were ... From:
Sent: Monday, November 8, 2021 7:02 PM
To:
Cc: (USANYS)
Subject: FW: Daubert motion
This is the version ready for you, and specifically, Part I.C.4-6.
Also, team
https://www.justice.gov/epstein/files/DataSet%208/EFTA00009983.pdf
EFTA00018897Set 8
2021-11-081p160w
From: "a"
To: : 1.1NIT' ,MEMI. )i
Subject: RE: Daubert motion
Date: Mon, 08 Nov 2021 03:03:42 +0000
Attachments: Motion_to_preclude_Dietz_and_Loflus_v5.doex
Hi all,
Here's a version that incorporates ... come later...
Thanks,
From:
Sent: Sunday, November 7, 2021 8:00 PM
To: >
Subject: Daubert motion
Hi team,
In the interest of expediency, here is the Daubert motion for your
https://www.justice.gov/epstein/files/DataSet%208/EFTA00018897.pdf
EFTA00086354Set 9
2021-11-092p286w
From:
Sent: Monday, November 8, 2021 9:43 PM
To:
Cc SANYS
Subject: RE: Daubert motion
Thanks very much, I've reviewed and have no substantive edits. There were ... Sent: Monday, November 8, 2021 7:02 PM
To:
Cc: (USANYS)
Subject: FW: Daubert motion
This is the version ready for you, and specifically, Part I.C.4-6.
Also, team ... customary sealing footnote.
From:
Sent: Monda November 8 2021 6:57 PM
To:
Subject: Daubert motion
Hey.
Passing the pen back to you while I'm joining the Rocchio witness
https://www.justice.gov/epstein/files/DataSet%209/EFTA00086354.pdf
EFTA00016471Set 8
2021-11-1011p3,312w
Defense's motion are timely and
may be considered in resolving the Daubert motion.
Turning to the proffered expert opinions, as articulated in the Government's disclosure ... witnesses.
Last, as previously mentioned, the Court will grant in part the Defense's Daubert motion.
The Defense argues that Dr. Rocchio's opinion that grooming can be done
https://www.justice.gov/epstein/files/DataSet%208/EFTA00016471.pdf
EFTA00094653Set 9
2021-11-1011p3,312w
Defense's motion are timely and
may be considered in resolving the Daubert motion.
Turning to the proffered expert opinions, as articulated in the Government's disclosure ... witnesses.
Last, as previously mentioned, the Court will grant in part the Defense's Daubert motion.
The Defense argues that Dr. Rocchio's opinion that grooming can be done
https://www.justice.gov/epstein/files/DataSet%209/EFTA00094653.pdf
EFTA00040107Set 9
2021-11-1011p3,312w
Defense's motion are timely and
may be considered in resolving the Daubert motion.
Turning to the proffered expert opinions, as articulated in the Government's disclosure ... witnesses.
Last, as previously mentioned, the Court will grant in part the Defense's Daubert motion.
The Defense argues that Dr. Rocchio's opinion that grooming can be done
https://www.justice.gov/epstein/files/DataSet%209/EFTA00040107.pdf
EFTA00094642Set 9
2021-11-1011p3,312w
Defense's motion are timely and
may be considered in resolving the Daubert motion.
Turning to the proffered expert opinions, as articulated in the Government's disclosure ... witnesses.
Last, as previously mentioned, the Court will grant in part the Defense's Daubert motion.
The Defense argues that Dr. Rocchio's opinion that grooming can be done
https://www.justice.gov/epstein/files/DataSet%209/EFTA00094642.pdf
EFTA00070837Set 9
2021-03-1241p13,013w
satisfy the Daubert standard. First, the expert notice—which closely parallels the defense's
Daubert motion—improperly discusses the facts of this particular case and comments on various
legal documents ... These opinions, while potentially relevant to the Court's consideration of a
Daubert motion, are not properly put before a jury.
9
EFTA00070849
Second, certain of Dr. Dietz's opinions
https://www.justice.gov/epstein/files/DataSet%209/EFTA00070837.pdf
EFTA00023414Set 8
2021-11-151p107w
From:
To:
Cc:
Subject: RE: Second Daubert Motion
Date: Mon, 15 Nov 2021 04:43:33 +0000
Attachments: Motion_to_preclude_Hall_et_al_v3.docx
I should have noted —=did the vast majority of the heavy ... Hall.
From:
Sent: Sunda November 14, 2021 11:41PM
To:
Cc:
Subject: Second Daubert Motion
Hi Chiefs,
I hope you had a nice weekend! Attached is our second Doubert motion
https://www.justice.gov/epstein/files/DataSet%208/EFTA00023414.pdf
EFTA00018896Set 8
2021-11-081p95w
From: 'a" alMIE>
To: 'a im
ISANYS2:nUSANYS)"
Subject: Daubert motion
Date: Mon, 08 Nov 2021 00:59:53 +0000
Attachments: Motion_to_preclude_Dietz_and_Loftus_v4.docx
Hi team,
In the interest of expediency, here ... Daubert motion for your comments. I still need to write my section, and I'm
doing some significant revisions to the Loftus section, but the Dietz section is done
https://www.justice.gov/epstein/files/DataSet%208/EFTA00018896.pdf