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Case 1:20-cr-00330-PAE Document 499 _ Filed 11/23/21 Page11of 28 Third, the government says Dr. Dietz should not be permitted to testify that it is a “commonly accepted bit of clinical lore” that perpetrators often target vulnerable victims. Mot. at 11. The government’s argument misconstrues and misunderstands Dr. Dietz’s point. Dr. Dietz does not dispute that vulnerable people can be and are targeted. Ex. 1, p 4. But what the science does not know, and what there is no data about, is how often perpetrators target individuals who are not characterized as “vulnerable.” /d. There is no comparator, and there is thus no way to know how representative “vulnerable victims” are of all victims of abuse. /d. As Dr. Dietz will testify, experts do not know the empirical relationship between vulnerability and abuse. /d. Again, Dr. Dietz should be able to challenge the reliability of Dr. Rocchio’s opinions by explaining how they lack scientific support. Fed. R. Evid. 702, Advisory Committee Notes, 2000 Amendments (Rule 702 “is broad enough to permit testimony that is the product of competing principles or methods in the same field of expertise.). Fourth, the government disputes Dr. Dietz’s opinion that there is no authority supporting a “theory of grooming by proxy.” Mot. at 11-12.° Once again, though, the government misunderstands Dr. Dietz’s point, and its argument is correspondingly non-responsive. The government says, for example, there is “ample literature on the pimp-prostitute relationship.” Mot. at 12. Dr. Dietz does not deny this. But unless the government (to use its crude vernacular) is saying that the accusers were the prostitutes, Ms. Maxwell was the pimp, and Mr. Epstein was the John, this literature is beside the point and not applicable to this case. Ex. 1, p 4. te Ok ok 3 To the extent Dr. Rocchio offers testimony on this point, addressing or implying “srooming-by-proxy,” Dr. Dietz’s opinion is admissible as described herein. See also supra note a DOJ-OGR-00007476