Epstein Secrets

, Dkt. No. 198 at 27, by Judge Engelmayer in United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y. 2020), Dkt. No. 335 at 24-30, and by Judge Cote in United States v. Torres, No. 20-CR-608 (DLC), 2021 WL 1947503, at *7 (S.D.N.Y. May 13, 2021). Their decisions are consistent with the vast majority of courts to c

ed on the admissibility of a grooming expert, it has previously recognized the academic literature on grooming to facilitate sexual abuse of minors. See United States v. Brand, 467 F.3d 179, 203 (2d Cir. 2006). The Defense cites to several contrary articles that suggest experts disagree on the kinds of behaviors

. No. 397, and Defendant filed a reply, Dkt. No. 398. The Court conducted a Daubert hearing on November 10, 2021, at which both parties examined Dr. Rocchio. Dkt. No. 431. The Court stated its oral opinion at that hearing that it would deny and grant in part Defendant's motion, to be followed by this op

ense may make arguments attacking the credibility of victims, the Government is free to argue that these witnesses are, in fact, victims of a crime. Cl United States v. Thai, 29 F.3d 785, 807 (2d Cir. 1994) (explaining that prosecutors may also "respond to an argument that impugns its integrity or the integrity

y this form of testimony, as explained above. To the extent Raymond stands for such a broad proposition, it is contrary to the law of this Circuit. See United States v. Joseph, 542 F.3d 13, 21-22 (2d Cir. 2008), abrogated on other grounds as recognized by United States v. Ferguson, 676 F.3d 260, 276 n.14 (2d Cir.

prevent disclosure. (Id. 18 EFTA00088820 (emphasis added)). Dr. testimony will also include discussion of techniques used by perpetrators. Dr. Rocchio's testimony regarding such techniques is supported by Dr. review of the relevant literature, see Exhibit A, and through her clinical work. By virtue

, Dkt. No. 198 at 27, by Judge Engelmayer in United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y. 2020), Dkt. No. 335 at 24-30, and by Judge Cote in United States v. Torres, No. 20-CR-608 (DLC), 2021 WL 1947503, at *7 (S.D.N.Y. May 13, 2021). Their decisions are consistent with the vast majority of courts to c

ed on the admissibility of a grooming expert, it has previously recognized the academic literature on grooming to facilitate sexual abuse of minors. See United States v. Brand, 467 F.3d 179, 203 (2d Cir. 2006). The Defense cites to several contrary articles that suggest experts disagree on the kinds of behaviors

. No. 397, and Defendant filed a reply, Dkt. No. 398. The Court conducted a Daubert hearing on November 10, 2021, at which both parties examined Dr. Rocchio. Dkt. No. 431. The Court stated its oral opinion at that hearing that it would deny and grant in part Defendant's motion, to be followed by this op

, Dkt. No. 198 at 27, by Judge Engelmayer in United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y. 2020), Dkt. No. 335 at 24-30, and by Judge Cote in United States v. Torres, No. 20-CR-608 (DLC), 2021 WL 1947503, at *7 (S.D.N.Y. May 13, 2021). Their decisions are consistent with the vast majority of courts to c

ed on the admissibility of a grooming expert, it has previously recognized the academic literature on grooming to facilitate sexual abuse of minors. See United States v. Brand, 467 F.3d 179, 203 (2d Cir. 2006). The Defense cites to several contrary articles that suggest experts disagree on the kinds of behaviors

. No. 397, and Defendant filed a reply, Dkt. No. 398. The Court conducted a Daubert hearing on November 10, 2021, at which both parties examined Dr. Rocchio. Dkt. No. 431. The Court stated its oral opinion at that hearing that it would deny and grant in part Defendant's motion, to be followed by this op

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defendant with various crimes related to the sexual abuse of mionrs. The Government anticipates that this case will proceed of trial. At trial. Dr. Rocchio will serve as a testifying expert to explain various topics related sexual abuse and trauma. Specifically. Dr. Rocchio will serve as a testifying ex

ing juror sympathy."). Any attempt to encourage such sympathy is therefore an attempt at nullification, which is itself plainly improper. See, e.g., United States v. Thomas, 116 F.3d 606, 615 (2d Cir. 1997) (Jury nullification is "by no means a right or 3 Evidence of the defendant's motive may be relevant evid

also unreliable, squarely within the ken of the average juror, or would invade the province of the Court and the jury if offered. To the extent Dr. Rocchio is permitted to testify on her opinions, the Court should admit reliable opinions on the same topics by defense experts. But the defense's expert no

00 2-3 Specifications/MA Statement The United States Attorneys' Office (USAO) conducts litigation in the Southern District of New York on behalf of the United States of America. Frequently. there is a need for expert witness work prior to a case going to trial and during the trial. When appropriate. and pursuant to guidelin

defendant with various crimes related to the sexual abuse of mionrs. The Government anticipates that this case will proceed of trial. At trial, Dr. Rocchio will serve as a testifying expert to explain various topics related sexual abuse and trauma. Specifically, Dr. Rocchio will serve as a testifying ex