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Case 1:20-cr-00330-PAE Document508- Filed 11/24/21 Page10of25 Instead of seeking relief under Rule 702, the government actually seeks relief under Rules 401 and 403, with an additional mention of Rule 703. None of the government’s arguments is well taken, however, if only because, “as with an expert’s qualifications and the reliability of his or her methodology, the liberality of Rule 702 insists that ‘doubts about whether an expert’s testimony will be useful should generally be resolved in favor of admissibility unless there are strong factors such as time or surprise favoring exclusions.’” Washington v. Kellwood Co., 105 F. Supp. 3d 293, 308 (S.D.N.Y. 2015) (quoting Jn re Zyprexa Prods. Liab. Litig., 489 F. Supp. 2d 230, 288 (E.D.N.Y. 2007)). C. Excluding Dr. Hall’s expert opinions would deprive Ms. Maxwell of her constitutional rights to confrontation and to present a defense. “Whether rooted directly in the Due Process Clause... , or in the Compulsory Process or Confrontation clauses of the Sixth Amendment, the Constitution guarantees criminal defendants a meaningful opportunity to present a complete defense.” Crane v. Kentucky, 476 U.S. 683, 690 (1986) (quoting California v. Trombetta, 467 U.S. 479, 485 (1984)); see U.S. Const. amends. V, VI. A court violates a defendant’s right to present a defense when it excludes competent and reliable evidence that is central to the defense. See Crane, 476 U.S. at 690. The exclusion of such evidence “deprives a defendant of the basic right to have the prosecutor’s case encounter and ‘survive the crucible of meaningful adversarial testing.’” /d. at 690-91 (quoting United States v. Cronic, 466 U.S. 648, 656 (1984)). The Constitution also affords Ms. Maxwell the right to confront her accusers. U.S. amend. VI; Olden v. Kentucky, 488 U.S. 227, 231 (1988). “[A] criminal defendant states a violation of the Confrontation Clause by showing that [she] was prohibited from engaging in otherwise appropriate cross-examination designed to show a prototypical form of bias on the part of the witness, and thereby ‘to expose to the jury the facts from which jurors .. . could DOJ-OGR-00008095