EFTA00024954.pdf

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Source set: data-set-8

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
S2 20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
Defendant.
THE GOVERNMENT'S MEMORANDUM OF LAW
IN SUPPORT OF ITS MOTION IN LIMINE TO PRECLUDE EXPERT TESTIMONY
OF DR. RYAN HALL, BENNETT GERSHMAN, ROBERT KELSO,
GERALD LAPORTE. AND JENNIFER NASO
DAMIAN WILLIAMS
United States Attorney for the
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Assistant United States Attorneys
Of Counsel
EFTA00024954

TABLE OF CONTENTS
PRELIMINARY STATEMENT
1
I.
APPLICABLE LAW
1
11.
THE COURT SHOULD PRECLUDE THE TESTIMONY OF DR. RYAN HALL
4
A.
Dr. Hall's Opinions
Are Irrelevant
5
B.
The Bases of Dr. Hall's Opinions Are Not Independently Admissible
12
C.
Any Undisclosed Significance of Dr. Hall's Opinions Is Inadmissible
14
D.
Dr. Hall's Fact Testimony Is Inadmissible
15
III.
THE COURT SHOULD PRECLUDE THE TESTIMONY OF BENNETT
GERSHMAN
20
IV.
BEFORE THE DEFENDANT'S REMAINING WITNESSES OFFER EXPERT
TESTIMONY, THE DEFENDANT SHOULD BE REQUIRED TO PROVIDE SUPPLEMENTAL
NOTICE 21
A.
B.
Robert Kelso and

22
Forensic Document Specialists
24
CONCLUSION
26
EFTA00024955

PRELIMINARY STATEMENT
The defendant has notified the Government that she plans to call six additional experts.
One of them, Dr. Ryan Hall,
and drafted a lengthy report, containing largely a recitation of hearsay, attributing some but not all
o
Another, Bennett
Gershman, is a purported expert on prosecutorial misconduct. Neither of these issues is relevant
at trial. and both experts should be precluded.
The defendant has failed to provide adequate notice as to the four remaining experts.
Instead of describing those experts' opinions and the bases for them, as required by Rule 16, the
notice identifies topics on which the experts might testify. The Government is therefore not able
to interpose a Dauber: challenge at this time.' The Court should require the defense to p…

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