509-01.pdf

Type: pdf
Source set: house-oversight-doj
Pages: 10
Text status: Searchable text available
OCR confidence: 0.8982977845589457

Extracted text

Case 1:20-cr-00330-PAE Document 509-1 Filed 11/24/21 Page1of10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA Rigs S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT?’S REPLY IN SUPPORT OF ITS MOTION IN LIMINE TO PRECLUDE THE TESTIMONY OF DR. RYAN HALL DAMIAN WILLIAMS United States Attorney for the Southern District of New York One St. Andrew’s Plaza New York, New York 10007 Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Of Counsel DOJ-OGR-00008112

Case 1:20-cr-00330-PAE Document 509-1 Filed 11/24/21 Page 2 of 10 PRELIMINARY STATEMENT On November 15, 2021, the Government filed its motion (““Mot.”) to exclude the testimony of Dr. Ryan Hall as irrelevant, more prejudicial than probative, and consisting of hearsay not subject to an exception. This reply addresses several of the most salient arguments in the defendant’s November 19, 2021 opposition (“Opp.”).! 1 [ERR Do Not Bear on Minor Victim-4’s Credibility. The defendant does not dispute that Dr. Hall’s principal conclusion (moving to exclude this conclusion) with Opp. 4 (noting conclusion but not defending its admissibility)). The parties also appear to agree on the relevant legal standard for assessing Dr. As BE (Mot. 6 (quoting United States v. Sasso, 59 F.3d 341, 347-48 (2d Cir. 1995); Opp. 7 (same)). From there, however, the defendant’s response strays. The Government’s Motion applied the caselaw messi (Mot. 6-10). The defendant expanded upon the general legal standard (Opp. 7-8) but then offered only ad hoc arguments, untied to the law and without offering evidence that they were sufficiently serious to satisfy the standard Lo : This reply does not address the defendant’s other five proposed experts (see Mot. 20-25), or those arguments of the defendant that seem entirely unresponsive. 1 DOJ-OGR-00008113

= DOJ-OGR-00008114

3 The defendant’s supplementary citation to Pe adds nothing to her opposition, since t…

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