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

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. Sexual Aggression 287 (2006) 10 Diamond et al., "The Truth is Out There: A

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

idespread 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 literature on the prevalence of various grooming techniques); Craven et al., "Sexual grooming of children:

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger

ES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. Denver Phone: Christian R. Eve

INE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffr

ruling on the admissibility for two weeks. 15 Ms. Maxwell reiterates her re, uest to defer III. THIS COUR

ticle describing "grooming" as a "construct." Resp, Ex. A, Natalie Bennett & William O'Donohue, The Construct of Grooming in Child Sexual Abuse, 23 J. Child Sexual Abuse 957, 974 (2014). (In fact, Ms. Maxwell cited this article in her motion.) Far from supporting conclusions, the article proves their unreliab