DOJ-OGR-00017955.pdf
epstein-pdf-nov2025 PDF 612.0 KB • Feb 4, 2026
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**Case 1:20-cr-00330-PAE**
**Document 747**
**Filed 08/10/22**
**Page 82 of 228**
**LC2Qmax3**
**MR. PAGLIUCA: Okay. Ms. Pomerantz.**
**MS. POMERANTZ: That question seems fine, your Honor.**
**I think the government agrees with your Honor that the other questions were beyond the scope.**
**MR. PAGLIUCA: May I? As long as we're on this topic, your Honor, I would like to preview another area from this article that I think is within this, but I want to make sure that the Court agrees with me before I go down this road.**
**THE COURT: Go ahead.**
**MR. PAGLIUCA: The article that we're talking about which is at 3502-018, the government's disclosure, the study that was done in this particular article, and which I believe this is the basis for her testimony about this grooming the environment, and so the study that she is referring to factually, there were 395 undergraduate students at John Jay College here who were given the five vignettes, I will call them, of this grooming behavior and asked in a sixth vignette which was non-grooming behavior, and they were asked to predict prospectively whether or not that was grooming behavior, and they couldn't. And the conclusion of the study was the five factors that she was talking about cannot be used to prospectively predict grooming behavior. And I would like to bring out those facts on cross-examination.**
**THE COURT: Sure. I mean, that's consistent with her testimony.**
**SOUTHERN DISTRICT REPORTERS, P.C.**
**(212) 805-0300**
**DOJ-OGR-00017955**
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