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Case 1:20-cr-00330-PAE Document 499 _ Filed 11/23/21 Page /7 of 28 (b) the testimony is based on sufficient facts or data; (c) the testimony is the product of reliable principles and methods; and (d) the expert has reliably applied the principles and methods to the facts of the case. Fed. R. Evid. 702. As elaborated below, the proposed testimony of Dr. Dietz and Dr. Loftus fall squarely within the ambit of Rule 702. I. Dr. Dietz’s Testimony is Admissible. The government agrees that Dr. Dietz is qualified to offer expert opinion testimony under Rule 702. Even so, the government hopes to limit his testimony by claiming that six categories of his proposed opinions are either unreliable, irrelevant, or invade the province of the jury. The government, though, is trying to have it both ways, by eliciting testimony from its expert Dr. Rocchio while unfairly precluding Ms. Maxwell from responding. The government also seeks to foreclose Dr. Dietz from offering opinions that are independently relevant to this case, irrespective of Dr. Rocchio’s testimony. To make its case, the government engages in the time-honored practice of mischaracterizing a defendant’s position and then responding to the strawman. This Court should reject the government’s efforts, which, if successful, will deprive Ms. Maxwell of her constitutional right to present a complete defense and to confront and cross- examine her accusers. U.S. Const. amends. V, VI. DOJ-OGR-00007472