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Case 1:20-cr-00330-PAE Document 499 _ Filed 11/23/21 Page14 of 28 flaws allowed him to use his brilliance to manipulate people to do his bidding and to compartmentalize people into isolated cells in which none had complete information about his activities. Ex. 1, p 7. This testimony is patently relevant to Ms. Maxwell’s knowledge and intent and to the conspiracy counts. If this “compartmentalization” prevented Ms. Maxwell from having the required knowledge or intent (an ultimate issue for the jury to decide, on which Dr. Dietz will not opine), then she will be not guilty. The government after all intends to ask the Court to instruct the jury on “willful blindness.” The jury should have the benefit of a scientific understanding of the manner in which a skilled manipulator could have eluded exposure to those around him. The government obviously disagrees with Dr. Dietz in his evaluation of Mr. Epstein. But just because the government has a different view of the facts does not mean Dr. Dietz’s testimony is inadmissible. Rule 702’s emphasis on “sufficient facts or data” does not “authorize a trial court to exclude an expert’s testimony on the ground” that the government “believes one version of the facts and not the other.” See Fed. R. Evid. 702, Advisory Committee Notes, 2000 Amendments. The government’s second objection is easily addressed. The point of the testimony is not to suggest jury nullification, which would be improper as defense counsel and Dr. Dietz well know. Mot. at 17. The testimony is relevant, as explained above. In any case, if the Court is concemed about any potential for Dr. Dietz’s testimony to engender sympathy for Ms. Maxwell, the Court can give a limiting instruction. That limiting instruction would be in addition to the Court’s written instructions, which already will instruct the jury not to decide the case based on sympathy or bias. Malletier v. Dooney & Bourke, Inc., 525 F. Supp. 2d 558, 571 (S.D.N.Y. 2007) (“This Court has routinely relied upon limiting instructions to remind the jury of its role and of the limits of expert testimony and clarify the extent of their consideration of such 10 DOJ-OGR-00007479