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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
tics that sexually abused children exhibit" but may not usurp the jury's role of assessing the credibility of any specific victim); United States v. Telles, 6 F.4th 1086, 1097-98 (9th Cir. 2021) (same). This analysis is referred to in the case relied upon by the Defense, United States v. Raymond, and
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
perpetrators. See supra pp. 7-8. Courts have also specifically authorized expert testimony on the subject of grooming. See, e.g., United States v. Telles, 6 F.4th 1086, 1097-1098 (9th Cir. 2021) (holding that admission of expert testimony on grooming did not violate Federal Rules of Evidence 702 or 40
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
tics that sexually abused children exhibit" but may not usurp the jury's role of assessing the credibility of any specific victim); United States v. Telles, 6 F.4th 1086, 1097-98 (9th Cir. 2021) (same). This analysis is referred to in the case relied upon by the Defense, United States v. Raymond, and
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
tics that sexually abused children exhibit" but may not usurp the jury's role of assessing the credibility of any specific victim); United States v. Telles, 6 F.4th 1086, 1097-98 (9th Cir. 2021) (same). This analysis is referred to in the case relied upon by the Defense, United States v. Raymond, and
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 →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 →tics that sexually abused children exhibit" but may not usurp the jury's role of assessing the credibility of any specific victim); United States v. Telles, 6 F.4th 1086, 1097-98 (9th Cir. 2021) (same). This analysis is referred to in the case relied upon by the Defense, United States v. Raymond, and
Page: EFTA00016479 →Entities connected to both Ghislaine Maxwell and Telles

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