Epstein Secrets

.D.N.C. March 12, 2021) 17 Boucher v. US. Suzuki Motor Corp., 73 F.3d 18 (2d Cir. 1996) 8, 23 Bourjaior v. United States, 483 U.S. 171 (1987) 6 Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579 (1993) passim deWit v. UPS Ground Freight, Inc., No. 16 Civ. 36, 2017 WL 5905575 (N.D. Fl. Jul. 25, 2017)

iry is flexible and "must be tied to the facts of a particular case." Id. at 6 EFTA00070846 150 (citations and internal quotation marks omitted). The Second Circuit has emphasized that "it is critical that an expert's analysis be reliable at every step." Amorgianos v. Nat'l R.R. Pass. Corp., 303 F.3d 256, 267 (

sed" by Epstein, and Give the Jury an Appropriate Limiting Instruction 14 CONCLUSION 16 i EFTA00074480 TABLE OF AUTHORITIES Page(s) Cases Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993) 12 Esquivel-Quintana v. Sessions, 137 S. Ct. 1562 (2017) 14 Grunewald v. United State

074492 prejudicial to Ms. Maxwell and will mislead the jury into believing that the alleged sex acts between Epstein and Accuser-3 were unlawful.; The Second Circuit takes an "inclusionary approach" to Rule 404(b) evidence, which admits "other act" evidence "that does not serve the sole purpose of showing the def

sed" by Epstein, and Give the Jury an Appropriate Limiting Instruction 14 CONCLUSION 16 i EFTA00087775 TABLE OF AUTHORITIES Page(s) Cases Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993) 12 Esquivel-Quintana v. Sessions, 137 S. Ct. 1562 (2017) 14 Grunewald v. United State

087787 prejudicial to Ms. Maxwell and will mislead the jury into believing that the alleged sex acts between Epstein and Accuser-3 were unlawful.; The Second Circuit takes an "inclusionary approach" to Rule 404(b) evidence, which admits "other act" evidence "that does not serve the sole purpose of showing the def

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

ons, the Defense should be permitted to admit Dr. Hall's conclusion as to Alleged Victim 4's substance abuse Def. Br. at 12-13 (collecting cases). The Second Circuit instructs: It is, of course, within the proper scope of cross-examination to determine whether a witness was under the influence of drugs or narcot