Epstein Secrets

986)); see also United States v. Mallah, 503 F.2d 971, 986 (2d Cir. 1974) (applying this burden-shifting approach post-conviction); United States v. Hernandez, No. 09-CR-625 (HB), 2009 WL 3169226, at *9 (S.D.N.Y. Oct. 1, 2009). 6 EFTA00156405 Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 7 of

d facilitated the sexual abuse of minor victims was a central focus of both parties' cases at trial. The Government called as an expert witness Dr. Lisa Rocchio, who identified the typical steps in sexual abusers' grooming of 10 EFTA00156409 Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 11 of 45

stereotype a witness with a history of mental illness or incorrectly assume that a diagnosed mental condition renders the witness untrustworthy. See Hernandez, 2011 WL 2117611, at *5. Third, mental health diagnoses are of a particularly sensitive nature and, if not relevant, the witness's privacy should n

f those experts, Dr. Park Dietz and Dr. Elizabeth Loftus, are expected to offer opinions that rebut opinions of the Government's expert witness, Dr. Lisa Rocchio. The Government on November 8, 2021, filed a motion to partially preclude the testimony of Dr. Dietz and Dr. Loftus. Dkt. No. 424. The Court has al

stereotype a witness with a history of mental illness or incorrectly assume that a diagnosed mental condition renders the witness untrustworthy. See Hernandez, 2011 WL 2117611, at *5. Third, mental health diagnoses are of a particularly sensitive nature and, if not relevant, the witness's privacy should n

f those experts, Dr. Park Dietz and Dr. Elizabeth Loftus, are expected to offer opinions that rebut opinions of the Government's expert witness, Dr. Lisa Rocchio. The Government on November 8, 2021, filed a motion to partially preclude the testimony of Dr. Dietz and Dr. Loftus. Dkt. No. 424. The Court has al

the risk that jurors will stereotype a witness with r incorrectly assume that a diagnosed mental condition renders the witness untrustworthy. See Hernandez, 2011 WL 2117611, at *5. Third, mental health diagnoses are of a particularly sensitive nature and, if not relevant, the witness's privacy should n

f those experts, Dr. Park Dietz and Dr. Elizabeth Loftus, are expected to offer opinions that rebut opinions of the Government's expert witness, Dr. Lisa Rocchio. The Government on November 8, 2021, filed a motion to partially preclude the testimony of Dr. Dietz and Dr. Loftus. Dkt. No. 424. The Court has al