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, 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
is inadmissible if it "comment[s] directly, under the guise of expert opinion, on the credibility of trial testimony from" specific fact witnesses. Nimely, 414 F.3d at 398. Additionally, if the expert's "opinion is one that the jury could reach with their own `common knowledge and common sense,' no ex
, 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
is inadmissible if it "comment[s] directly, under the guise of expert opinion, on the credibility of trial testimony from" specific fact witnesses. Nimely, 414 F.3d at 398. Additionally, if the expert's "opinion is one that the jury could reach with their own `common knowledge and common sense,' no ex
, 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
is inadmissible if it "comment[s] directly, under the guise of expert opinion, on the credibility of trial testimony from" specific fact witnesses. Nimely, 414 F.3d at 398. Additionally, if the expert's "opinion is one that the jury could reach with their own `common knowledge and common sense,' no 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
mony is simply an attempt to invade the province of the jury by putting a thumb on the scale in their assessment of witness credibility.6 See, e.g., Nimely, 414 F.3d at 398 ("[E]xpert opinions that constitute evaluations of witness credibility, even when such evaluations are rooted in scientific or tec
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