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Case 1:20-cr-00330-PAE Document 499 _ Filed 11/23/21 Page13 of 28 lacked actual knowledge of and intent to facilitate the alleged grooming and abuse, she is not guilty, even if, as a matter of hindsight, it should have been obvious. The government’s second argument falls short as well. Although the phrase “20/20 hindsight” might be well-known, the power of hindsight bias and the degree to which it might unreliably affect the outcome of this case is not. To be sure, as Dr. Dietz laid out in his disclosure, the scientific literature about hindsight bias is voluminous. Ex. 1, p 4-5. These expert articles wouldn’t exist if the concept were obvious to everyone, and surely it wouldn’t be the case that, as Dr. Dietz notes, “[e]ven individuals with specialized training and expertise succumb to hindsight bias,” id. at 5. The government concedes that “the jury, and not the court, should be the one to decide among conflicting experts.” Mot. at 9 (quoting United States v. Randall, No. 19 Cr. 131 (PAE) (S.D.N.Y.)). But for the jury to do that job, it must be equipped with the necessary tools. And one of those tools is Dr. Dietz’s perfectly permissible opinion that Dr. Rocchio’s testimony cannot carry the water the government wants it to because it is tainted by hindsight bias. See United States v. Brown, 557 F.2d 541, 556 (6th Cir. 1977) (“Conflicting testimony concerning the conclusions drawn by experts, so long as they are based on a generally accepted and reliable scientific principle, ordinarily go to the weight of the testimony rather than to its admissibility.”). C. The Halo Effect. The government has two objections to Dr. Dietz’s opinions on the “halo effect.” The first is that it is irrelevant (though, again, not unreliable). The second is that it improperly seeks to engender sympathy for Ms. Maxwell. First, the government is wrong to argue the testimony is irrelevant. Take just one (representative) example. Dr. Dietz opines that Mr. Epstein’s DOJ-OGR-00007478