{
  "document_metadata": {
    "page_number": "2",
    "document_number": "443-1",
    "date": "11/12/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 443-1 Filed 11/12/21 Page 2 of 4 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 Sternheim, Esq. Law Offices of Bobbi C. Sternheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) 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. Lisa Rocchio, 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. Lisa Rocchio is the President-Elect of the Division of Trauma Psychology of the American Psychological Association (\"APA\"). Dr. Rocchio 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. Rocchio has specialized in treating patients with trauma, including sexual trauma in childhood and adolescence. In the last twenty-three years, Dr. Rocchio has treated hundreds of victims of trauma, many of whom were minor victims of sexual abuse. Dr. Rocchio has also received specialized training in traumatic stress, sexual abuse, and clinical DOJ-OGR-00006612",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 443-1 Filed 11/12/21 Page 2 of 4",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Department of Justice United States Attorney Southern District of New York",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 April 23, 2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BY ELECTRONIC MAIL",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "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 Sternheim, Esq. Law Offices of Bobbi C. Sternheim 33 West 19th Street-4th Fl. New York, NY 10007",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "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. Lisa Rocchio, 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.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "I. Disclosure by the Government",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dr. Lisa Rocchio is the President-Elect of the Division of Trauma Psychology of the American Psychological Association (\"APA\"). Dr. Rocchio 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. Rocchio has specialized in treating patients with trauma, including sexual trauma in childhood and adolescence. In the last twenty-three years, Dr. Rocchio has treated hundreds of victims of trauma, many of whom were minor victims of sexual abuse. Dr. Rocchio has also received specialized training in traumatic stress, sexual abuse, and clinical",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006612",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Christian Everdell",
      "Mark Cohen",
      "Laura Menninger",
      "Jeffrey Pagliuca",
      "Bobbi Sternheim",
      "Ghislaine Maxwell",
      "Dr. Lisa Rocchio"
    ],
    "organizations": [
      "Cohen & Gresser LLP",
      "Haddon, Morgan and Foreman, P.C.",
      "Law Offices of Bobbi C. Sternheim",
      "U.S. Department of Justice",
      "United States Attorney",
      "American Psychological Association",
      "Alpert Medical School of Brown University"
    ],
    "locations": [
      "New York",
      "Denver",
      "Southern District of New York"
    ],
    "dates": [
      "April 23, 2021",
      "11/12/21",
      "1995",
      "1998"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 443-1",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00006612"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to various attorneys regarding the case United States v. Ghislaine Maxwell. The letter is dated April 23, 2021, and is related to the disclosure of an expert witness, Dr. Lisa Rocchio."
}