Epstein Secrets

Dr. Rocchio's proposed testimony is silent as to whether she is expected to impute a theory of `grooming-by-proxy' to the defendant," and that "Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself," but instead that she "recruited and grooming minors to provide sexualized

K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S MEMORANDUM OF LAW

K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S MEMORANDUM

`grooming-by-proxy' to the defendant," and that "Ms. Maxwell is not accused of soliciting or enticing sexualiz

children I0 EFTA00070850 with "a poor relationship with their parents," who "do not have many friends," or who "have already been victimized." (Craven et al., "Sexual grooming of children," 12 J. Sexual Aggression 287, 292 (2006), Dkt. No. 397 Ex. A (citations omitted)). Dr. Rocchio's clinical experience

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

in touching; (4) isolating the victim; and (5) engaging in emotional manipulation. Grooming efforts can also extend to "grooming the environment." Craven et al., "Sexual grooming of children: Review of literature and theoretical considerations," 3 J. of Sexual Aggression 287, 292-93 (2006) ("Some offenders

al prevention model for child sexual abuse. In R. Wortley & S. Smallbone (Eds.), Crime 3502-033 Page 18 of 22 EFTA_00001680 EFTA00157021 18 0 GM. WINTERS ET AL prevention studies: Vol. 19. Situational prevention of child sexual abuse (pp. 101-144). Criminal Justice Press. Knoll, J. (2010).

mily circumstances in the victim selection process (e.g., lack parental supervision, parental discord, parental mental health/substance use issues; Craven et al., 2006; Jackson et al., 2015; Kaufman et al., 2006). Gaining access and isolation Second, many of the prior models identify that an offender seeks