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Case 1:20-cr-00330-PAE Document291 Filed 05/21/21 Page12o0f13 Page 12 documentary evidence) at the same time as it discloses /3500 material. Defense Expert Disclosures The government's proposal that Ms. Maxwell disclose any expert testimony eight weeks in advance of trial, prior even to the prosecution's disclosure of the 3500/Jencks Act materials or government exhibits, puts the proverbial cart before the horse. All proposed opinion testimony must be "relevant to the task at hand.” Daubert v. Merrell Dow Pharmaceuticals, 509 U.S. 579, 597 (1993). To be reliable, the proposed expert must have, inter alia, “applied the principles and methods reliably fo the facts of the case.” United States v. Williams, 506 F.3d 151, 160 (2d Cir. 2007) (emphasis supplied, citations omitted). Any defense expert that relates to the testimony of the accusers or 404(b) witnesses cannot possibly be disclosed before Ms. Maxwell has even been provided access to that testimony. To illustrate the point, one need look only at the government's expert disclosure. The proposed testimony for the government's expert, although purportedly not based on a review of the facts of this case, nevertheless appears to have been crafted by the government with full knowledge of the accusers’ specific allegations. For example, the government proffers that their expert will testify that "minor victims ... may not identify themselves as victims of abuse while it is ongoing, and may not recognize the consequences of that abuse until adulthood." Clearly, the accusers must have represented facts to support these contentions or else there would be no grounds to admit this "blind" expert opinion testimony. Ms. Maxwell cannot be expected to hire experts and divine what would be relevant to this case before she is provided the statements by these accusers, whose credibility will be the central question for the jury in this case. The Court originally ordered the defense expert disclosures four weeks before trial and DOJ-OGR- 00004262