Epstein Secrets

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

od's operation, and whether the method is accepted by the expert community. United States v. Kidd, 385 F. Supp. 3d 259, 263 (S.D.N.Y. 2019) (citing Daubert v. Merrell Dow Phanns., Inc., 509 U.S. 579, 593-94 (1993)). But Rule 702 ultimately sets a "liberal" and "permissive" standard of admissibility. N

5 (2d Cir. 2017). To determine whether an expert's method is reliable, the Court considers the non-exhaustive list provided by the Supreme Court in Daubert, including whether the expert's method has been tested, whether it has been subjected to peer review, the rate of error, standards controlling the m

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

ssive" standard of admissibility. Nimely v. City of New York, 414 F.3d 381, 395-96 (2d Cir. 2005). In particular, not every expert admissible under Daubert need rely on a method that conforms with "the exactness of hard science methodologies." E.E.O.C. v. Bloomberg L.P., No. 07-CV-8383 (LAP), 2010 WL 3

athan: The Government respectfully requests permission to file a reply brief in support of the Government's motion to preclude the testimony of Dr. Ryan Hall. Among other issues, the defendant's opposition brief raises new arguments about hearsay exceptions that the defendant argues apply to information

e its responsive brief by noon on November 22, 2021, and to respond only regarding Dr. Hall and not the other experts discussed in the Government's Daubert motion. EFTA00078462 Page 2 Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Assistant United States Attorneys Southe

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

ssive" standard of admissibility. Nimely v. City of New York, 414 F.3d 381, 395-96 (2d Cir. 2005). In particular, not every expert admissible under Daubert need rely on a method that conforms with "the exactness of hard science methodologies." E.E.O.C. v. Bloomberg L.P., No. 07-CV-8383 (LAP), 2010 WL 3

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

ssive" standard of admissibility. Nimely v. City of New York, 414 F.3d 381, 395-96 (2d Cir. 2005). In particular, not every expert admissible under Daubert need rely on a method that conforms with "the exactness of hard science methodologies." E.E.O.C. v. Bloomberg L.P., No. 07-CV-8383 (LAP), 2010 WL 3

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

od's operation, and whether the method is accepted by the expert community. United States v. Kidd, 385 F. Supp. 3d 259, 263 (S.D.N.Y. 2019) (citing Daubert v. Merrell Dow Phanns., Inc., 509 U.S. 579, 593-94 (1993)). But Rule 702 ultimately sets a "liberal" and "permissive" standard of admissibility. N

5 (2d Cir. 2017). To determine whether an expert's method is reliable, the Court considers the non-exhaustive list provided by the Supreme Court in Daubert, including whether the expert's method has been tested, whether it has been subjected to peer review, the rate of error, standards controlling the m

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

ives and reviews the documents they have in mind. Doing so, however, would almost certainly lead to mid-trial Dauber! briefing, possibly a mid-trial Daubert hearing, and late-breaking rebuttal expert notice by the Government. The better course is to require the defense to identify, immediately, the docu