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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 11/11/21 20-CR-330 (MN) OPINION & ORDER ALISON J. NATHAN, District Ju
mental state when performing the behaviors. Second, the Court finds that Dr. Rocchio's opinions are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as the Second Circuit has explained, expert testimony cannot "constitute evaluations of witness credi
TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTR
ns are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as
F.3d 576, 585 (7th Cir. 1999), the Fifth Circuit in United States v. Hitt, 473 F.3d 146, 158 (5th Cir. 2006), the Ninth Circuit in United States v. Halamek, 5 F.4th 1081, 1087-89 (9th Cir. 2021), the Tenth Circuit in United States v. Batton, 602 F.3d 1191, 1201-02 (10th Cir. 2010), the Eighth 4 EFTA00
K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S OMNIBUS MEMORANDUM
K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S OMNIBUS ME
exual abuse but not a necessary consequence of sexual abuse, jurors have no means to determine whether a Minor Victim is lying or telling the truth GM 7 The defendant also argues that Dr. is not an expert in "the human brain or memory generally." (Def. Mot. 3 at 17). The overnment agrees. But Dr.
m-3's allegations "may reflect conduct 43 EFTA00088845 undertaken in furtherance of the charged conspiracy or be relevant to prove facts such as Maxwell's state of mind." (id. at 26-27). B. Applicable Law It is axiomatic that the Government may offer proof of acts included within the indictment. Th
tion based on [the expert's] own knowledge and experience" (quoting United States v. Johnson, 860 F.3d 1133, 1141 (8th Cir. 2017)); United States v. Halamek, 5 F.4th 1081, 1087-89 (9th Cir. 2021) (holding that expert testimony on grooming was "relevant, reliable, and properly admitted"); United States v
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 11/11/21 20-CR-330 (MN) OPINION & ORDER ALISON J. NATHAN, District Ju
mental state when performing the behaviors. Second, the Court finds that Dr. Rocchio's opinions are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as the Second Circuit has explained, expert testimony cannot "constitute evaluations of witness credi
TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTR
ns are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as
F.3d 576, 585 (7th Cir. 1999), the Fifth Circuit in United States v. Hitt, 473 F.3d 146, 158 (5th Cir. 2006), the Ninth Circuit in United States v. Halamek, 5 F.4th 1081, 1087-89 (9th Cir. 2021), the Tenth Circuit in United States v. Batton, 602 F.3d 1191, 1201-02 (10th Cir. 2010), the Eighth 4 EFTA00
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 11/11/21 20-CR-330 (MN) OPINION & ORDER ALISON J. NATHAN, District Ju
mental state when performing the behaviors. Second, the Court finds that Dr. Rocchio's opinions are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as the Second Circuit has explained, expert testimony cannot "constitute evaluations of witness credi
TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTR
ns are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as
F.3d 576, 585 (7th Cir. 1999), the Fifth Circuit in United States v. Hitt, 473 F.3d 146, 158 (5th Cir. 2006), the Ninth Circuit in United States v. Halamek, 5 F.4th 1081, 1087-89 (9th Cir. 2021), the Tenth Circuit in United States v. Batton, 602 F.3d 1191, 1201-02 (10th Cir. 2010), the Eighth 4 EFTA00
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 11/11/21 20-CR-330 (MN) OPINION & ORDER ALISON J. NATHAN, District Ju
Page: EFTA00016471 →TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTR
Page: EFTA00016471 →F.3d 576, 585 (7th Cir. 1999), the Fifth Circuit in United States v. Hitt, 473 F.3d 146, 158 (5th Cir. 2006), the Ninth Circuit in United States v. Halamek, 5 F.4th 1081, 1087-89 (9th Cir. 2021), the Tenth Circuit in United States v. Batton, 602 F.3d 1191, 1201-02 (10th Cir. 2010), the Eighth 4 EFTA00
Page: EFTA00016474 →mental state when performing the behaviors. Second, the Court finds that Dr. Rocchio's opinions are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as the Second Circuit has explained, expert testimony cannot "constitute evaluations of witness credi
Page: EFTA00016477 →ns are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as
Page: EFTA00016477 →Entities connected to both Ghislaine Maxwell and Halamek

Jeffrey Epstein
PERSON
United States
LOCATION
Julie K. Brown
PERSONDoug Band
PERSON
Scarlett Johansson
PERSON
Bloomberg L.P.
ORGANIZATION
Harvey Weinstein
PERSON
Supreme Court
ORGANIZATION
Elon Musk
PERSON
Russell Simmons
PERSON
ALISON J. NATHAN
ORGANIZATIONUSDC SONY
ORGANIZATION
Torres
PERSONthe Second Circuit's
ORGANIZATIONDaubert
PERSON
Raymond
PERSONEngelmayer
PERSONFurman
PERSONRocchio
PERSONLisa Rocchio
PERSON