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Case 1:20-cr-00330-PAE Document 424 Filed 11/08/21 Page 41 of 41 CONCLUSION Accordingly, the Government respectfully requests that: e Dr. Dietz be permitted to testify in response to Dr. Rocchio, limited to the opinion that grooming does not have one settled definition; e Dr. Dietz be precluded from offering opinions regarding hindsight bias, the Halo effect, pathways to false allegations of sexual assault, factors bearing on witness credibility, and post-traumatic stress symptoms, or in the alternative that a hearing be held; e Dr. Loftus be precluded from offering opinions regarding commonsense principles of memory, factors bearing on witness credibility, factual narratives, or false memory formation. Dated: November 8, 2021 New York, New York Respectfully submitted, DAMIAN WILLIAMS United States Attorney for the Southern District of New York By: /s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys af DOJ-OGR-00006252