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Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 21 of 84 return to Epstein’s home for sexual abuse, or why some occasionally expressed affection for the defendant and Epstein. Although Dr. Rocchio will not testify about these specific Minor Victims, her testimony will help the jurors understand the “psychological dynamic often seen in abusive relationships that leads an abuse victim to behave in counterintuitive ways, such as by declining to take opportunities to leave an abusive situation or by expressing gratitude to an abuser.” Torres, 2021 WL 1947503, at *7. This psychological dynamic between a victim of child sexual abuse and her abusers is “beyond the knowledge of the average juror and would or could plainly be helpful in understanding the psychological dynamics at play.” Oct. 17, 2019 Tr. at 27:3-7, United States v. Dupigny, No. 18 Cr. 528 (JMF) (S.D.N.Y.), Dkt. No. 198; cf’ See Feb. 25, 2020 Tr. at 38:13-20, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335 (“[B]y and large the relationship between prostitutes and pimps is not the subject of common knowledge. Jurors are not apt to intuitively understand the mechanisms that may lead a woman who is not physically restrained or confined to heed the demands of a pimp to traffic herself.”). Accordingly, Dr. Rocchio’s testimony will help the jury understand and contextualize the other testimony it will hear.‘ The defendant expresses concern that a lay jury will be unable to apply Dr. Rocchio’s analyses to the facts of this case, stating “[t]hat is not how Rule 702 works.” (Def. Mot. at 10). * Relying again on Raymond, the District of Maine case, the defendant argues that expert testimony about “general principles is helpful only when it ‘describes widely recognized and highly predictable and verifiable phenomena.’” (Def. Mot. 10 (quoting Raymond, 700 F. Supp. 2d at 150 n.12 (alterations omitted)). That proposition comes from footnote 12 of Raymond, which attempted to distinguish that expert’s “profile” testimony from the Federal Rules Advisory Committee’s observation that the 2000 amendment “does not alter the venerable practice of using 20 DOJ-OGR-00005804