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Case 1:20-cr-00330-PAE Document692- Filed 11/22/21 Page13o0f17 In addition to diagnosing Alleged Victim 4’s mental conditions, Dr. Hall also concluded The Government moved to exclude this conclusion and the Defense does not make a case for admitting it. The Court will also preclude the opinion. In this circumstance, the lasting mental impact of a crime is at best “minimally probative” of whether that crime was committed. United States v. Hendricks, 921 F.3d 320, 329 (2d Cir. 2019). It also carries a high risk of Rule 403 prejudice by suggesting that the psychological impact on Alleged Victim 4 is relevant to Ms. Maxwell’s guilt beyond a reasonable doubt. It would also cause substantial delay by opening the door to rebuttal evidence by the Government on Alleged Victim 4’s mental health, which would likely lead to mini-trials on irrelevant issues. Next, the disclosure states that Dr. Hall will testify to the “significance” of Alleged Victim 4’s diagnoses. Notice at 12. First, the Court understands that Dr. Hall could not testify to the “significance” of mental health diagnoses without first testifying to what those diagnoses are. Because the Court is precluding Dr. Hall’s testimony on Alleged Victim 4’s diagnoses, the Court will also preclude Dr. Hall’s testimony on their significance. Additionally, the current disclosure on this point does not satisfy Rule 16’s requirement that the Defense provide Dr. Hall’s opinion rather than just the general topic of the testimony. Even if the Court admitted Dr. Hall’s testimony as to Alleged Victim 4’s diagnoses, the Court would preclude his testimony on significance until more specific opinions are disclosed to the Government. Next, the Defense anticipates that Dr. Hall will testify to the “bases for those opinions” in his report. /d. Dr. Hall’s report refers not only to what Alleged Victim 4 told him during their in-person interview but also other records like oe ae 13 DOJ-OGR-00011151