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will testify but actually "summarize the experts' opinions about those topics" and "describe the bases for the experts' opinions." United States v. Ulbricht, 858 F.3d 71, 115 (2d Cir. 2017) (emphasis added); United States v. Valle, No. 12-CR-847 (PGG), 2013 WL 440687, at *5 (S.D.N.Y. Feb. 2, 2013) ("Mer
s."). If the Defense's disclosure of an expert witness does not satisfy Rule 16, the Court has "broad discretion" to fashion an appropriate remedy. Ulbricht, 858 F.3d at 115. That discretion is guided by factors including "why disclosure was not made, the extent of the prejudice, if any, to the opposing
vernment's motion can be resolved only with additional information and the context of trial. A. The Court will preclude the expert testimony of Dr. Ryan Hall The Government moves to preclude the expert testimony of Dr. Ryan Hall. Dr. Hall was retained by Jeffrey Epstein to evaluate Alleged Victim 4, whic
will testify but actually "summarize the experts' opinions about those topics" and "describe the bases for the experts' opinions." United States v. Ulbricht, 858 F.3d 71, 115 (2d Cir. 2017) (emphasis added); United States v. Valle, No. 12-CR-847 (PGG), 2013 WL 440687, at *5 (S.D.N.Y. Feb. 2, 2013) ("Mer
s."). If the Defense's disclosure of an expert witness does not satisfy Rule 16, the Court has "broad discretion" to fashion an appropriate remedy. Ulbricht, 858 F.3d at 115. That discretion is guided by factors including "why disclosure was not made, the extent of the prejudice, if any, to the opposing
vernment's motion can be resolved only with additional information and the context of trial. A. The Court will preclude the expert testimony of Dr. Ryan Hall The Government moves to preclude the expert testimony of Dr. Ryan Hall. Dr. Hall was retained by Jeffrey Epstein to evaluate Alleged Victim 4, whic
will testify but actually "summarize the experts' opinions about those topics" and "describe the bases for the experts' opinions." United States v. Ulbricht, 858 F.3d 71, 115 (2d Cir. 2017) (emphasis added); United States v. Valle, No. 12-CR-847 (PGG), 2013 WL 440687, at *5 (S.D.N.Y. Feb. 2, 2013) ("Mer
s."). If the Defense's disclosure of an expert witness does not satisfy Rule 16, the Court has "broad discretion" to fashion an appropriate remedy. Ulbricht, 858 F.3d at 115. That discretion is guided by factors including "why disclosure was not made, the extent of the prejudice, if any, to the opposing
reclude the testimony of the remaining six experts. The Defense filed a response on November 19, 2021. The Court addressed the admissibility of Dr. Ryan Hall in a separate written opinion. In this opinion, the Court addresses the preliminary admissibility of Bennett Gershman based on the parties' current
will testify but actually "summarize the experts' opinions about those topics" and "describe the bases for the experts' opinions." United States v. Ulbricht, 858 F.3d 71, 115 (2d Cir. 2017) (emphasis added); United States v. Valle, No. 12-CR-847 (PGG), 2013 WL 440687, at *5 (S.D.N.Y. Feb. 2, 2013) ("Mer
s."). If the Defense's disclosure of an expert witness does not satisfy Rule 16, the Court has "broad discretion" to fashion an appropriate remedy. Ulbricht, 858 F.3d at 115. That discretion is guided by factors including "why disclosure was not made, the extent of the prejudice, if any, to the opposing
vernment's motion can be resolved only with additional information and the context of trial. A. The Court will preclude the expert testimony of Dr. Ryan Hall The Government moves to preclude the expert testimony of Dr. Ryan Hall. Dr. Hall was retaine( tfhe Defense anticipates that Dr. Hall will testif
30 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION IN LIMINE TO PRECLUDE EXPERT TESTIMONY OF DR. RYAN HALL, BENNETT GERSHMAN, ROBERT KELSO, GERALD LAPORTE. AND JENNIFER NASO DAMIAN WILLIAMS United States Attorney for the Southern District of New York
Page: EFTA00024954 →mary of the bases of the expert's opinion." Id. The content of the expert notice must actually "summarize the experts' opinions." United States v. Ulbricht, 858 F.3d 71, 115 (2d Cir. 2017), abrogated on other grounds by Carpenter v. United States, 138 S. Ct. 2206 (2018). "Merely identifying the general
Page: EFTA00024957 →reclude the testimony of the remaining six experts. The Defense filed a response on November 19, 2021. The Court addressed the admissibility of Dr. Ryan Hall in a separate written opinion. In this opinion, the Court addresses the preliminary admissibility of Bennett Gershman based on the parties' current
Page: EFTA00014701 →will testify but actually "summarize the experts' opinions about those topics" and "describe the bases for the experts' opinions." United States v. Ulbricht, 858 F.3d 71, 115 (2d Cir. 2017) (emphasis added); United States v. Valle, No. 12-CR-847 (PGG), 2013 WL 440687, at *5 (S.D.N.Y. Feb. 2, 2013) ("Mer
Page: EFTA00014703 →Entities connected to both Ulbricht and Ryan Hall

Jeffrey Epstein
PERSON
Paul Ryan
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Bradley Edwards
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATION
Southern District of New York
ORGANIZATION
Prince Andrew
PERSON
Supreme Court
ORGANIZATION
Virginia Giuffre
PERSONElizabeth Loftus
PERSONDietz
PERSONSecond Circuit
ORGANIZATIONPark Dietz
PERSONLoftus
PERSONDaubert
PERSON
Stephen Hawking
PERSON
Valle
PERSONMaria Farmer
PERSON