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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
6, 158 (5th Cir. 2006), the Ninth Circuit in United States v. Halamek, 5 F.4th 1081, 1087-89 (9th Cir. 2021), the Tenth Circuit in United States v. Batton, 602 F.3d 1191, 1201-02 (10th Cir. 2010), the Eighth 4 EFTA00040110 Circuit in United States v. Johnson, 860 F.3d 1133, 1141 (8th Cir. 2017), and
, 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
6, 158 (5th Cir. 2006), the Ninth Circuit in United States v. Halamek, 5 F.4th 1081, 1087-89 (9th Cir. 2021), the Tenth Circuit in United States v. Batton, 602 F.3d 1191, 1201-02 (10th Cir. 2010), the Eighth 4 EFTA00094656 Circuit in United States v. Johnson, 860 F.3d 1133, 1141 (8th Cir. 2017), and
, 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
6, 158 (5th Cir. 2006), the Ninth Circuit in United States v. Halamek, 5 F.4th 1081, 1087-89 (9th Cir. 2021), the Tenth Circuit in United States v. Batton, 602 F.3d 1191, 1201-02 (10th Cir. 2010), the Eighth 4 EFTA00094645 Circuit in United States v. Johnson, 860 F.3d 1133, 1141 (8th Cir. 2017), and
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