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Case 1:20-cr-00330-PAE Document509-1 Filed 11/24/21 Page 2 of 10 PRELIMINARY STATEMENT On November 15, 2021, the Government filed its motion (““Mot.”) to exclude the testimony of Dr. Ryan Hall as irrelevant, more prejudicial than probative, and consisting of hearsay not subject to an exception. This reply addresses several of the most salient arguments in the defendant’s November 19, 2021 opposition (“Opp.”).! 1 [RRR Do Not Bear on Minor Victim-4’s Credibility. The defendant does not dispute that Dr. Hall’s principal conclusion (moving to exclude this conclusion) with Opp. 4 (noting conclusion but not defending its admissibility)). The parties also appear to agree on the relevant legal standard for assessing Dr. Rs PE (Mot. 6 (quoting United States v. Sasso, 59 F.3d 341, 347-48 (2d Cir. 1995); Opp. 7 (same)). From there, however, the defendant’s response strays. The Government’s Motion applied the caselaw to Po (Mot. 6-10). The defendant expanded upon the general legal standard (Opp. 7-8) but then offered only ad hoc arguments, untied to the law and without offering evidence that they were sufficiently serious to satisfy the standard | : This reply does not address the defendant’s other five proposed experts (see Mot. 20-25), or those arguments of the defendant that seem entirely unresponsive. 1 DOJ-OGR-00008113