In a filing to Judge Subramanian in United States v. Combs, S3 24 Cr. 542 (AS), the Government requests permission to admit limited additional testimony from expert witness Dr. Dawn Hughes. This request comes in response to what prosecutors describe as "forceful and repeated" arguments made by the defense during their cross-examination of the witness known as Mia. The defense, the Government argues, presented misleading implications about Mia’s behavior and credibility—specifically regarding how victims of abuse are expected to act. Prosecutors contend that this line of questioning has "opened the door" for rebuttal testimony addressing misconceptions about trauma responses.

The Government seeks to have Dr. Hughes offer expert insight drawn from her original notice, focused solely on clarifying how victims of abuse often exhibit behaviors that may seem counterintuitive to jurors unfamiliar with trauma psychology—such as delayed reporting, continued contact with abusers, or minimized disclosure. This testimony, they assert, is necessary to correct the jury’s potential misinterpretation created by the defense's narrative. The request is framed as narrow in scope and designed not to go beyond the boundaries previously set by the Court, but rather to preserve the integrity of the witness's testimony in light of the defense’s strategy.


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source:

gov.uscourts.nysd.628425.376.0_1.pdf

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