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Case 1:20-cr-00330-PAE Document 499 _ Filed 11/23/21 Page 19 of 28 Finally, the government points to Dr. Dietz’s “acknowledgement” that credibility should be judged on a “case-by-case basis.” Mot at 23. That is exactly right. And it is exactly what Dr. Rocchio does not do in her clinical practice, which is one reason why Dr. Dietz’s testimony is admissible. F. Post-Traumatic Stress Disorder. Dr. Dietz’s opinions on PTSD are relevant, reliable, and admissible. The government’s first argument is that it doesn’t understand Dr. Dietz’s proposed testimony, particularly Dr. Dietz’s statement that victims with PTSD symptoms are unlikely “to unnecessarily recreate a sexual assault event.” Mot. at 23. To be clear, the point Dr. Dietz was making in this statement and this paragraph of his disclosure is that victims with PTSD will likely avoid reminders of the event that caused the trauma in the first place—for example, they will avoid continued communication with the alleged perpetrator and they are unlikely to wear clothing provided by the alleged perpetrator. Dr. Dietz is not saying, as the government claims, that victims should bear “responsibility for experiencing repeated assaults.” According to the government, the critical distinction in this case involves the difference between victims of sexual assaults who are involved an ongoing relationship of attachment and coercion with their abusers—including the power imbalance arising from the age differential between them and the abusers—and those who are not. To the extent Dr. Dietz’s testimony primarily addresses the latter category, such an opinion is irrelevant and should be precluded for lack of fit with the facts of the case. . . . To the extent Dr. Dietz intends instead to opine on the former category, that opinion is not reliable. Mot. at 23-24 (citations omitted). This argument fails as well. On the one hand, the government says Dr. Dietz’s opinion does not “fit the facts” of the case because this case is about alleged “victims of sexual assaults who are involved an ongoing relationship of attachment and coercion with their abusers.” But this argument begs the 15 DOJ-OGR-00007484