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Case 1:20-cr-00330-PAE Document508- Filed 11/24/21 Page12 of 25 82)) (quotation omitted). See also United States v. Thompson, 976 F.2d 666, 671 (11th Cir. 1992) (cross-examination regarding witnesses’ “mental condition during the time periods about which they were testifying” is appropriate since those “records [a]re highly probative of the witnesses’ credibility (citing United States v. Lindstrom, 698 F.2d 1154 (11th Cir. 1983); United States v. Partin, 493 F.2d 750 (Sth Cir. 1974))). Applying Sasso, Dr. Hall’s opinions are relevant and admissible. The standard for relevance is “very low,” United States v. Litvak, 808 F.3d 160, 190 (2d Cir. 2015) (reversing conviction based on district court’s erroneous conclusion that defendant’s expert evidence was irrelevant); United States v. White, 692 F.3d 235, 246 (2d Cir. 2012) (explaining that Rule 401 prescribes a “very low standard”), and the definition of relevance is “very broad,” United States v. Certified Envtl. Servs., Inc., 753 F.3d 72, 90 (2d Cir. 2014). “Evidence is relevant if: (a) it has any tendency to make a fact more or less probable than it would be without the evidence; and (b) the fact is of consequence in determining the action.” Fed. R. Evid. 401. “To be relevant, evidence need not be sufficient by itself to prove a fact in issue, much less to prove it beyond a reasonable doubt.” United States v. Abu-Jihaad, 630 F.3d 102, 132 (2d Cir. 2010). “[U]nless an exception applies, all ‘relevant evidence is admissible.’” White, 692 F.3d at 246. Under the “very broad” definition and “very low” standard of relevance, all of Dr. Hall’s opinions are admissible. The government first disputes the relevance of i ——CSSCSCs OO —CSsSCSCis DOJ-OGR-00008097