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From Sportico article:

Davis hoped jurors would hear testimony by professor Elise Caccappolo van Vliet, the director of neuropsychology service at the Columbia University Irving Medical Center. Caccappolo wrote in a report that Davis suffered an “intellectual disability” that was “previously referred to as mental retardation.” This disability might have persuaded jurors Davis lacked the necessary intent to defraud a health care plan. But Judge Valerie Caproni denied the testimony in part because it was not based on a review of medical records predating Davis’s criminal acts.