{
  "document_metadata": {
    "page_number": "17",
    "document_number": "499",
    "date": "11/23/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 499 Filed 11/23/21 Page 17 of 28\n\ntestimony. To the contrary, the text of Rule 702 expressly contemplates that an expert may be qualified on the basis of experience.\n\nThird, in admitting Dr. Rocchio's testimony over an objection by Ms. Maxwell similar to the one offered here by the government, this Court said as follows:\n\nDr. Rocchio's opinions speak only to concepts and will not (and indeed may not) suggest that the jury find any alleged victim witness to be credible or to find Ms. Maxwell guilty. . . . It is the jury's role to determine whether and how Dr. Rocchio's opinions apply to the facts of this case and the credibility of the witnesses.\n\n(Dkt. 435, p 10). The same logic applies to Dr. Dietz's opinions.\n\nFinally, the government says the Dr. Dietz's opinions don't \"fit the facts of the case.\" Mot. at 21. But because the accusers' stories have changed so much over the last twenty years, and because it's still unclear what they will testify to at trial, this objection is premature at best.\n\nIf the government believes Dr. Dietz's opinions do not \"fit\" the facts, this Court can consider that argument once there is evidence of what the facts really are.\n\nE. Dr. Dietz's Alleged Opinions about the Accusers' \"Credibility.\"\n\nNowhere in Dr. Dietz's expert disclosure does he propose to opine on the credibility of Ms. Maxwell's accusers. Ex. 1. The government can argue otherwise only by mischaracterizing his opinions. See Mot. at 22-23.\n\nFor one thing, Dr. Dietz should be able to critique Dr. Rocchio's methods and conclusions by opining that experts in the field would not be \"so credulous\" as Dr. Rocchio is.\n\nSee Gov't Omnibus Resp. to Maxwell Mot. in Limine, at 16; Ex. 2, p 16:11-16 (Dr. Rocchio: \"In my clinical practice, it's not - I have to deal with what the patients tell me in the room. It's not my job to go out and verify any part of what's being told in the clinical room, but, rather, to hear what they're telling me and then relate that back to my other skills-training experience, the scientific literature.\"). Dr. Dietz proposes to opine that Dr. Rocchio erred in assuming that her\n\n13\n\nDOJ-OGR-00007482",
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 499 Filed 11/23/21 Page 17 of 28",
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    },
    {
      "type": "printed",
      "content": "testimony. To the contrary, the text of Rule 702 expressly contemplates that an expert may be qualified on the basis of experience.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Third, in admitting Dr. Rocchio's testimony over an objection by Ms. Maxwell similar to the one offered here by the government, this Court said as follows:",
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    },
    {
      "type": "printed",
      "content": "Dr. Rocchio's opinions speak only to concepts and will not (and indeed may not) suggest that the jury find any alleged victim witness to be credible or to find Ms. Maxwell guilty. . . . It is the jury's role to determine whether and how Dr. Rocchio's opinions apply to the facts of this case and the credibility of the witnesses.",
      "position": "middle"
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    {
      "type": "printed",
      "content": "(Dkt. 435, p 10). The same logic applies to Dr. Dietz's opinions.",
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    {
      "type": "printed",
      "content": "Finally, the government says the Dr. Dietz's opinions don't \"fit the facts of the case.\" Mot. at 21. But because the accusers' stories have changed so much over the last twenty years, and because it's still unclear what they will testify to at trial, this objection is premature at best.",
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    {
      "type": "printed",
      "content": "If the government believes Dr. Dietz's opinions do not \"fit\" the facts, this Court can consider that argument once there is evidence of what the facts really are.",
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    },
    {
      "type": "printed",
      "content": "E. Dr. Dietz's Alleged Opinions about the Accusers' \"Credibility.\"",
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    },
    {
      "type": "printed",
      "content": "Nowhere in Dr. Dietz's expert disclosure does he propose to opine on the credibility of Ms. Maxwell's accusers. Ex. 1. The government can argue otherwise only by mischaracterizing his opinions. See Mot. at 22-23.",
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    },
    {
      "type": "printed",
      "content": "For one thing, Dr. Dietz should be able to critique Dr. Rocchio's methods and conclusions by opining that experts in the field would not be \"so credulous\" as Dr. Rocchio is.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "See Gov't Omnibus Resp. to Maxwell Mot. in Limine, at 16; Ex. 2, p 16:11-16 (Dr. Rocchio: \"In my clinical practice, it's not - I have to deal with what the patients tell me in the room. It's not my job to go out and verify any part of what's being told in the clinical room, but, rather, to hear what they're telling me and then relate that back to my other skills-training experience, the scientific literature.\"). Dr. Dietz proposes to opine that Dr. Rocchio erred in assuming that her",
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    {
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      "content": "13",
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    {
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      "content": "DOJ-OGR-00007482",
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  ],
  "entities": {
    "people": [
      "Dr. Rocchio",
      "Ms. Maxwell",
      "Dr. Dietz"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "11/23/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 499",
      "Dkt. 435",
      "Mot. at 21",
      "Mot. at 22-23",
      "Ex. 1",
      "Ex. 2",
      "DOJ-OGR-00007482"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, with discussions about expert testimonies and their admissibility."
}