{
  "document_metadata": {
    "page_number": "15",
    "document_number": "499",
    "date": "11/23/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 499 Filed 11/23/21 Page 15 of 28\ntestimony.\" (cleaned up)). The government's speculative concern about the effect of Dr. Dietz's testimony is no reason to exclude it when the Court has ample tools at its disposal to address the governments (ill-founded) worries.\nAlmost as an aside, the government disingenuously suggests that Dr. Dietz's opinion is inadmissible because \"it appears\" to be based \"solely on one interview of Epstein with Steven Bannon.\" Mot. at 17. As the government well knows, Dr. Dietz's opinion is based on much more. To be sure, Dr. Dietz quoted the interview in his disclosure, Ex. 1, p 6, but he also reviewed and considered thousands of pages of material before reaching his opinion, including most significantly all the material available to him about the Palm Beach Investigations of Mr. Epstein, Ex. 1, p 166-69.\nD. Pathways to False Allegations of Sexual Assault.\nThe government misses the mark in its hyperbolic objection to Dr. Dietz's opinions about the multiple pathways to false sex assault allegations. Mot. at 18-22. The government claims these opinions invade the province of the jury are unreliable and unhelpful. Not so.\nFirst, the opinions do not invade the province of the jury because Dr. Dietz is not offering an opinion on the truthfulness of the accusers' allegations in this case. See Nimely v. City of New York, 414 F.3d 381, 395-96 (2d Cir. 2005) (expert testimony is inadmissible if it \"comment[s] directly, under the guise of expert opinion, on the credibility of trial testimony from\" specific fact witnesses.); cf. Hygh v. Jacobs, 961 F.2d 359, 364 (2d Cir. 1992) (expert not permitted to offer testimony that \"merely [tells] the jury what result to reach\"). Dr. Dietz's opinions rely on his clinical experience and the vast body of literature explaining how an accuser might come to falsely allege sexual assault.\nOne point (but by no means the only one) of Dr. Dietz's opinion is to challenge the reliability of Dr. Rocchio's opinions, which she bases on the untested assumption that her\n11\nDOJ-OGR-00007480",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 499 Filed 11/23/21 Page 15 of 28",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "testimony.\" (cleaned up)). The government's speculative concern about the effect of Dr. Dietz's testimony is no reason to exclude it when the Court has ample tools at its disposal to address the governments (ill-founded) worries.\nAlmost as an aside, the government disingenuously suggests that Dr. Dietz's opinion is inadmissible because \"it appears\" to be based \"solely on one interview of Epstein with Steven Bannon.\" Mot. at 17. As the government well knows, Dr. Dietz's opinion is based on much more. To be sure, Dr. Dietz quoted the interview in his disclosure, Ex. 1, p 6, but he also reviewed and considered thousands of pages of material before reaching his opinion, including most significantly all the material available to him about the Palm Beach Investigations of Mr. Epstein, Ex. 1, p 166-69.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "D. Pathways to False Allegations of Sexual Assault.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government misses the mark in its hyperbolic objection to Dr. Dietz's opinions about the multiple pathways to false sex assault allegations. Mot. at 18-22. The government claims these opinions invade the province of the jury are unreliable and unhelpful. Not so.\nFirst, the opinions do not invade the province of the jury because Dr. Dietz is not offering an opinion on the truthfulness of the accusers' allegations in this case. See Nimely v. City of New York, 414 F.3d 381, 395-96 (2d Cir. 2005) (expert testimony is inadmissible if it \"comment[s] directly, under the guise of expert opinion, on the credibility of trial testimony from\" specific fact witnesses.); cf. Hygh v. Jacobs, 961 F.2d 359, 364 (2d Cir. 1992) (expert not permitted to offer testimony that \"merely [tells] the jury what result to reach\"). Dr. Dietz's opinions rely on his clinical experience and the vast body of literature explaining how an accuser might come to falsely allege sexual assault.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "One point (but by no means the only one) of Dr. Dietz's opinion is to challenge the reliability of Dr. Rocchio's opinions, which she bases on the untested assumption that her",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "11",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00007480",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Dr. Dietz",
      "Steven Bannon",
      "Epstein",
      "Dr. Rocchio"
    ],
    "organizations": [
      "City of New York"
    ],
    "locations": [
      "Palm Beach",
      "New York"
    ],
    "dates": [
      "11/23/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "499",
      "DOJ-OGR-00007480"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving allegations of sexual assault. The text discusses the admissibility of expert testimony from Dr. Dietz and challenges the government's objections to his opinions."
}