{
  "document_metadata": {
    "page_number": "6",
    "document_number": "452",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 6 of 84\n\ntraumatic and psychological consequences, especially when it occurs in the context of complex trauma. The presence of other individuals can facilitate the sexual abuse of minors. Dr. Rocchio is also expected to testify that nondisclosure, incremental disclosure, and secrecy are common among victims of sexual abuse for a variety of reasons, and that memory and disclosure of traumatic or abusive events is impacted by a number of factors, including the circumstances surrounding the trauma.\n\n(Expert Notice, Def. Mot. 3 Ex. 1 at 2). As the notice also explained, Dr. Rocchio has not evaluated any of the victims in this case, and the Government does not currently intend to offer Dr. Rocchio's testimony regarding any specific victim. (See id.).\n\nThere is nothing controversial about this testimony. It is well supported by established scientific principles, and it is the kind of testimony frequently admitted in cases involving sexual abuse. This Court should do the same.\n\nA. Applicable Law\n\nDistrict courts have a \"gatekeeper function\" in analyzing the admissibility of expert testimony. Phelps v. CBS Corp., No. 17 Civ. 8361 (AJN), 2020 WL 7028954, at *3 (S.D.N.Y. Nov. 30, 2020) (quoting Restivo v. Hessemann, 846 F.3d 547, 575 (2d Cir. 2017)). Although the proponent of the evidence carries a burden of proof to establish its admissibility by a preponderance of the evidence, see, e.g., United States v. Jones, 965 F.3d 149, 161 (2d Cir. 2020), courts apply a \"presumption of admissibility of evidence.\" Felix v. City of New York, No. 16 Civ. 5845 (AJN), 2020 WL 6048153, at *6 (S.D.N.Y. Oct. 13, 2020) (quoting Borawick v. Shay, 68 F.3d 597, 610 (2d Cir. 1995)). Accordingly, the relevant rule of evidence, Rule 702, reflects \"the 'liberal thrust' of the Federal Rules and their 'general approach of relaxing the traditional barriers to 'opinion' testimony.'\" Daubert v. Merrell Dow Pharms., Inc., 509 U.S.\n\n5\n\nDOJ-OGR-00006714",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 6 of 84",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "traumatic and psychological consequences, especially when it occurs in the context of complex trauma. The presence of other individuals can facilitate the sexual abuse of minors. Dr. Rocchio is also expected to testify that nondisclosure, incremental disclosure, and secrecy are common among victims of sexual abuse for a variety of reasons, and that memory and disclosure of traumatic or abusive events is impacted by a number of factors, including the circumstances surrounding the trauma.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "(Expert Notice, Def. Mot. 3 Ex. 1 at 2). As the notice also explained, Dr. Rocchio has not evaluated any of the victims in this case, and the Government does not currently intend to offer Dr. Rocchio's testimony regarding any specific victim. (See id.).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "There is nothing controversial about this testimony. It is well supported by established scientific principles, and it is the kind of testimony frequently admitted in cases involving sexual abuse. This Court should do the same.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "A. Applicable Law",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "District courts have a \"gatekeeper function\" in analyzing the admissibility of expert testimony. Phelps v. CBS Corp., No. 17 Civ. 8361 (AJN), 2020 WL 7028954, at *3 (S.D.N.Y. Nov. 30, 2020) (quoting Restivo v. Hessemann, 846 F.3d 547, 575 (2d Cir. 2017)). Although the proponent of the evidence carries a burden of proof to establish its admissibility by a preponderance of the evidence, see, e.g., United States v. Jones, 965 F.3d 149, 161 (2d Cir. 2020), courts apply a \"presumption of admissibility of evidence.\" Felix v. City of New York, No. 16 Civ. 5845 (AJN), 2020 WL 6048153, at *6 (S.D.N.Y. Oct. 13, 2020) (quoting Borawick v. Shay, 68 F.3d 597, 610 (2d Cir. 1995)). Accordingly, the relevant rule of evidence, Rule 702, reflects \"the 'liberal thrust' of the Federal Rules and their 'general approach of relaxing the traditional barriers to 'opinion' testimony.'\" Daubert v. Merrell Dow Pharms., Inc., 509 U.S.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "5",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006714",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Dr. Rocchio"
    ],
    "organizations": [
      "CBS Corp.",
      "City of New York",
      "Merrell Dow Pharms., Inc."
    ],
    "locations": [
      "S.D.N.Y.",
      "New York"
    ],
    "dates": [
      "Nov. 30, 2020",
      "Oct. 13, 2020",
      "11/12/21"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 452",
      "No. 17 Civ. 8361 (AJN)",
      "No. 16 Civ. 5845 (AJN)",
      "846 F.3d 547",
      "965 F.3d 149",
      "68 F.3d 597",
      "509 U.S."
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a sexual abuse case, with expert testimony from Dr. Rocchio. The text is well-formatted and printed, with no visible handwriting or stamps."
}