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

th Cir. 2004) 30 United States v. Yousef, 327 F.3d 56 (2d Cir. 2003) 6, 8 Yates v. State, 171 S.W.3d 215 (Tex. App. 2005) 17 Other Authorities Bennett & O'Donohue, "The Construct of Grooming in Child Sexual Abuse, 23 J. Child Sexual Abuse 957 (2014) 10 Craven et al., "Sexual grooming of children," 12 J. Sexu

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

wed professional literature in 1984, the term `grooming' has become so widely adopted that it will remain in widespread use for decades to come."); Bennett & O'Donohue, "The Construct of Grooming in Child Sexual Abuse: Conceptual and Measurement Issues," 23 J. Child Sexual Abuse 957, 964-68 (2014) (reviewing the li

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).

t al., 2009; Marshall et al., 2015). Additionally, literature has identified that some offenders may provide the child with drugs or alcohol (e.g., Bennett & O'Donohue, 2014), which would be most commonly used with older victims. Desensitizing the child to sexual content and physical contact Fourth, there appears