Federal Court Filing: The Government'S Omnibus Memorandum In Opposition (EFTA00088802)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S MOTIONS IN LIMINE 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 EFTA00088802 Table of Contents PRELIMINARY STATEMENT 1 ARGUMENT 4 I. The Court Should Admit the Testimony of Dr. 4 A. Applicable Law 5 B. Discussion 9 1. Dr. )pinions on Coercion and Attachment are Admissible 10 2. Dr. Opinion on the Relationship Between Trust and Victim Awareness of Their Abuse is Admissible 22 3. Dr. MINtDpinion on the Long-Term Consequences of Abuse is Admissible 23 4. Dr. Opinion About the Significance of the Presence of Third Parties is Admissible 25 5. Dr. Opinion on Delayed Disclosure is Admissible 27 II. The Evidence Contained in