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.

wed professional literature in 1984, the term `grooming' has become so widely adopted that it will remain in widespread 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 li

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

th Cir. 2004) 30 United States v. Yousef, 327 F.3d 56 (2d Cir. 2003) 6, 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. Sexu

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

t al., 2009; Marshall et al., 2015). Additionally, literature has identified that some offenders may provide the child with drugs or alcohol (e.g., Bennett & O'Donohue, 2014), which would be most commonly used with older victims. Desensitizing the child to sexual content and physical contact Fourth, there appears