Epstein Secrets

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.

in touching; (4) isolating the victim; and (5) engaging in emotional manipulation. Grooming efforts can also extend to "grooming the environment." Craven et al., "Sexual grooming of children: Review of literature and theoretical considerations," 3 J. of Sexual Aggression 287, 292-93 (2006) ("Some offenders

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

children I0 EFTA00070850 with "a poor relationship with their parents," who "do not have many friends," or who "have already been victimized." (Craven et al., "Sexual grooming of children," 12 J. Sexual Aggression 287, 292 (2006), Dkt. No. 397 Ex. A (citations omitted)). Dr. Rocchio's clinical experience

United States and Canada (Briere & Eliott, 2003; Canadian Centre for Justice Statistics, 2017; Finkelhor et al., 2015; Letourneau et al., 2018). In the United States, individuals incarcerated for sexual offenses comprise 12% of state inmate populations (Department of Justice, 2014). Notably, however, preva- lence

mily circumstances in the victim selection process (e.g., lack parental supervision, parental discord, parental mental health/substance use issues; Craven et al., 2006; Jackson et al., 2015; Kaufman et al., 2006). Gaining access and isolation Second, many of the prior models identify that an offender seeks