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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 PILED DOC 0: DATE FILED:i 102121 20-CR-330 (AJN) MEMORANDUM OPINION & ORDER ALISON J. NATHAN,
the evaluation" and "disclosures made [Alleged Victim 4]." Id. And fourth, he will testify to "the fact that [Alleged Victim 4] did not identify Ms. Maxwell as a perpetrator of any abuse." Id. 4 EFTA00068504 The Government argues, and the Court agrees, that the first two opinions based on Dr. Hall's
TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTR
the fact that [Alleged Victim 4] did not identify Ms. Maxwell as a perpetrator of any abuse." Id. 4 EFTA0006
Hall's testimony and report is unnecessary. Drake v. 10 EFTA00068510 Woods, 547 F. Supp. 2d 253, 266-67 (S.D.N.Y. 2008) (quoting United States v. Roldan-Zapata, 916 F.2d 795, 806 (2d Cir. 1990)). The Court therefore concludes that the minimal probative value of each of Dr. Hall's diagnoses of Alleged Victi
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY PILED DOC 0: DATE FILED:i 102121 20-CR-330 (AJN) MEMORANDUM OPINION & ORDER ALISON J. NATHAN,
the evaluation" and "disclosures made [Alleged Victim 4]." Id. And fourth, he will testify to "the fact that [Alleged Victim 4] did not identify Ms. Maxwell as a perpetrator of any abuse." Id. 4 EFTA00087206 The Government argues, and the Court agrees, that the first two opinions based on Dr. Hall's
TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTR
the fact that [Alleged Victim 4] did not identify Ms. Maxwell as a perpetrator of any abuse." Id. 4 EFTA0008
Hall's testimony and report is unnecessary. Drake v. 10 EFTA00087212 Woods, 547 F. Supp. 2d 253, 266-67 (S.D.N.Y. 2008) (quoting United States v. Roldan-Zapata, 916 F.2d 795, 806 (2d Cir. 1990)). The Court therefore concludes that the minimal probative value of each of Dr. Hall's diagnoses of Alleged Victi
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
ng than the crimes with which [the defendant] was charged," which weighs in favor of admitting these exhibits under Rule 404(b)(2). United States v. Roldan-Zapata, 916 F.2d 795, 804 (2d Cir. 1990). b. Testimony of Employee-1 Employee-1 worked as a personal assistant for Epstein for approximately (October 11
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY PILED DOC 0: DATE FILED:i 102121 20-CR-330 (AJN) MEMORANDUM OPINION & ORDER ALISON J. NATHAN,
the evaluation" and "disclosures made [Alleged Victim 4]." Id. And fourth, he will testify to "the fact that [Alleged Victim 4] did not identify Ms. Maxwell as a perpetrator of any abuse." Id. 4 EFTA00089907 The Government argues, and the Court agrees, that the first two opinions based on Dr. Hall's
TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTR
the fact that [Alleged Victim 4] did not identify Ms. Maxwell as a perpetrator of any abuse." Id. 4 EFTA0008
Hall's testimony and report is unnecessary. Drake v. 10 EFTA00089913 Woods, 547 F. Supp. 2d 253, 266-67 (S.D.N.Y. 2008) (quoting United States v. Roldan-Zapata, 916 F.2d 795, 806 (2d Cir. 1990)). The Court therefore concludes that the minimal probative value of each of Dr. Hall's diagnoses of Alleged Victi
Entities connected to both Ghislaine Maxwell and Roldan-Zapata

Jeffrey Epstein
PERSON
United States
LOCATION
Bloomberg L.P.
ORGANIZATIONSecond Circuit
ORGANIZATION
Paul Ryan
PERSON
Southern District of New York
ORGANIZATION
Harvey Weinstein
PERSON
Bradley Cooper
PERSON
Supreme Court
ORGANIZATION
Russell Simmons
PERSONHaley Robson
PERSON
ALISON J. NATHAN
ORGANIZATION
Jennifer Lopez
PERSON
Hernandez
PERSONUSDC SONY
ORGANIZATION
Valle
PERSONLoftus
PERSONDietz
PERSONDaubert
PERSONUlbricht
PERSON