mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00008090.json

{
  "document_metadata": {
    "page_number": "5",
    "document_number": "508",
    "date": "11/24/21",
    "document_type": "court document",
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  },
  "full_text": "Case 1:20-cr-00330-PAE Document 508 Filed 11/24/21 Page 5 of 25 Ghislaine Maxwell submits this Response to the Government's Motion to Preclude the Expert Testimony of Dr. Ryan Hall, Bennett Gershman, Robert Kelso, John Lopez, Gerald LaPorte, and Jennifer Naso. INTRODUCTION AND SUMMARY OF THE ARGUMENT The government claims to bring its motion under Federal Rule of Evidence 702. In reality, though, the government doesn't challenge the expertise of any of Ms. Maxwell's expert witnesses or the reliability of their opinions. Instead, training its sights almost exclusively on Dr. Hall, the government says that the opinions of Ms. Maxwell's expert witnesses are either irrelevant or unfairly prejudicial. The government also claims to lack adequate notice of some of the experts' proposed opinions. This Court can deny the motion for the simple reason that the government is proceeding under the wrong rule at the wrong time. Because Ms. Maxwell's expert witnesses are qualified and because their opinions are reliable, their testimony is admissible under Rule 702. As for relevance and prejudice, the government's arguments are both unfounded and premature. Finally, if the government is entitled to additional notice, Ms. Maxwell will provide it. For the reasons given below, the exclusion of Ms. Maxwell's expert witnesses would violate both her constitutional right to confrontation and her constitutional to present a defense. This Court, therefore, should deny the government's motion. ARGUMENT I. Dr. Hall's Testimony Is Admissible. Although the government offers some type of challenge, however conclusory, to all of Ms. Maxwell's expert witnesses, the true target of the government's motion is Dr. Ryan Hall. Dr. Hall is an eminently qualified M.D. who conducted an independent medical examination of His 108-page,",
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      "content": "Case 1:20-cr-00330-PAE Document 508 Filed 11/24/21 Page 5 of 25",
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    {
      "type": "printed",
      "content": "Ghislaine Maxwell submits this Response to the Government's Motion to Preclude the Expert Testimony of Dr. Ryan Hall, Bennett Gershman, Robert Kelso, John Lopez, Gerald LaPorte, and Jennifer Naso.",
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    {
      "type": "printed",
      "content": "INTRODUCTION AND SUMMARY OF THE ARGUMENT",
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    {
      "type": "printed",
      "content": "The government claims to bring its motion under Federal Rule of Evidence 702. In reality, though, the government doesn't challenge the expertise of any of Ms. Maxwell's expert witnesses or the reliability of their opinions. Instead, training its sights almost exclusively on Dr. Hall, the government says that the opinions of Ms. Maxwell's expert witnesses are either irrelevant or unfairly prejudicial. The government also claims to lack adequate notice of some of the experts' proposed opinions.",
      "position": "middle"
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    {
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      "content": "This Court can deny the motion for the simple reason that the government is proceeding under the wrong rule at the wrong time. Because Ms. Maxwell's expert witnesses are qualified and because their opinions are reliable, their testimony is admissible under Rule 702. As for relevance and prejudice, the government's arguments are both unfounded and premature. Finally, if the government is entitled to additional notice, Ms. Maxwell will provide it.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "For the reasons given below, the exclusion of Ms. Maxwell's expert witnesses would violate both her constitutional right to confrontation and her constitutional to present a defense. This Court, therefore, should deny the government's motion.",
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    {
      "type": "printed",
      "content": "ARGUMENT",
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    {
      "type": "printed",
      "content": "I. Dr. Hall's Testimony Is Admissible.",
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    {
      "type": "printed",
      "content": "Although the government offers some type of challenge, however conclusory, to all of Ms. Maxwell's expert witnesses, the true target of the government's motion is Dr. Ryan Hall. Dr. Hall is an eminently qualified M.D. who conducted an independent medical examination of His 108-page,",
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    {
      "type": "printed",
      "content": "DOJ-OGR-00008090",
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  "entities": {
    "people": [
      "Ghislaine Maxwell",
      "Dr. Ryan Hall",
      "Bennett Gershman",
      "Robert Kelso",
      "John Lopez",
      "Gerald LaPorte",
      "Jennifer Naso",
      "Ms. Maxwell"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "11/24/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 508"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ghislaine Maxwell. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and easy to read."
}