Paul DerOhannesian II

Paul DerOhannesian II represented Keith Raniere and challenged both the scope of expert testimony and the foundations of photographic evidence. On Day 18, he renewed objections to psychologist Dawn Hughes's qualifications, the scope of her testimony, and the notice given to the defense. He also proposed a limiting instruction. The court qualified Hughes over defense objections and deferred expert instructions until the final charge.

In cross-examination, DerOhannesian tested Hughes's assessment methods, reporting motives, and treatment of consent. Hughes acknowledged limits on her general testimony, while the court restricted psychiatric-history and legal questions. During the instruction discussion, he argued that offender behavior fell outside her qualification and that coercive relationships exceeded the notice's scope. He also raised a profiling concern. The court removed a disputed sentence with both sides' agreement; that resolution was distinct from his broader objections to the testimony.

On Day 23, DerOhannesian questioned Brian Booth about evidence-collection records, unreliable file-system creation dates, and limits on reconstructing device history. The court directed a search for disputed FBI Computer Analysis Response Team records, and defense counsel reviewed newly produced notes before questioning continued. His further cross-examination elicited acknowledgments of apparent changes to media-card access dates during FBI possession and limits on identifying users or photographers. Two defense evidence-handling records were admitted.

These questions distinguished what the digital records could establish about dates and devices from what they could establish about individual conduct. On redirect, Booth emphasized EXIF dates over file-system timestamps. DerOhannesian then elicited on recross that EXIF data can be altered, without establishing that the images in this case had been altered.