DOJ-OGR-00008118.pdf
epstein-pdf-nov2025 PDF 653.3 KB • Feb 4, 2026
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**Case 1:20-cr-00330-PAE**
**Document 509-1**
**Filed 11/24/21**
**Page 7 of 10**
**Case 1:20-cr-00330-PAE**
**Document 509-1**
**Filed 11/24/21**
**Page 7 of 10**
hearsay only where that hearsay is needed to help the jury understand the expert's opinion. See, e.g., United States v. Rodriguez, 651 F. App'x 44, 46 (2d Cir. 2016). Because Dr. Hall could explain his opinions without relating hearsay statements about
Rule 703 does not help her.
Rule 803(4). The defendant claims that Minor Victim-4's statements to Dr. Hall are admissible under Federal Rule of Evidence 803(4). That Rule excludes from the prohibition on hearsay certain statements "made for - and reasonably pertinent to - medical diagnosis or treatment." Fed. R. Evid. 803(4)(A). But Dr. Hall told Minor Victim-4 that he was interviewing her not as a care provider, but rather
That renders Rule 803(4) inapplicable: The rationale underlying this rule is that "a statement made in the course of procuring medical services, where the declarant knows that a false statement may cause misdiagnosis or mistreatment, carries special guarantees of credibility." White v. Illinois, 502 U.S. 346, 356 (1992). Because Minor Victim-4 was not seeking medical diagnosis or treatment from Dr. Hall cannot convert her statements to him into non-hearsay. See United States v. Funds Held in the Name or For the Ben. of John Hugh Wetterer, 991 F. Supp. 112, 114, 123-24 (E.D.N.Y. 1998) (statements made by sex abuse victims to doctor not admissible under Rule 803(4) where doctor was investigating sex abuse allegations for news program rather than seeking to treat interviewees).
Rule 801(d)(1)(A). The defendant also claims that Minor Victim-4's "answers to interrogatories and her deposition testimony ... are admissible under Rule 801(d)(1)(A)." That
**DOJ-OGR-00008118**
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