{
  "document_metadata": {
    "page_number": "24 of 84",
    "document_number": "397",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 24 of 84\n\nThe defense argues that this opinion is outside Dr. Rocchio's expertise because she has \"no experience treating alleged perpetrators,\" so \"her view . . . is entirely one-sided.\" (Id.). As is clear from the above excerpt, her testimony is about largely about trust and attachment built in victims, and the resultant ways in which victims process abuse. But she is also an expert in the actions and techniques of perpetrators through her review of the literature and the lens of what she has learned through victims. This opinion is therefore squarely within Dr. Rocchio's expertise.\n\nFinally, the defendant argues that this testimony violates Rule 704, because it is an \"opinion that the alleged victims in this case are testifying truthfully,\" and 403, because it \"risks jurors accepting her 'expert' opinion as gospel at the expense of their duty to evaluate the evidence.\" (Def. Mot. 3 at 13). Dr. Rocchio has not evaluated the victims in this case and will not express an opinion as to whether they are testifying truthfully. And the defense motion is entirely unclear on the features of this expert opinion that create risk that the jurors would abdicate their responsibilities. To the contrary, the defense concerns underscore how relevant this opinion will be in aiding the jurors in understanding the testimony at trial.\n\n3. Dr. Rocchio's Opinion on the Long-Term Consequences of Abuse is Admissible\nDr. Rocchio will also testify that \"[r]epeated exploitation and abuse can increase the likelihood of victimization later in life and can result in long-term traumatic and psychological consequences, especially when it occurs in the context of complex trauma.\" (Def. Mot. 3 Ex. 1 at 2). As Dr. Rocchio will explain, and as is detailed in her Jencks Act material6, experiencing child\n\n6 The Government produced Dr. Rocchio's Jencks Act material to the defense at the time of the expert notice. (See Def. Mot. 3 Ex. 1 at 2 (\"The Government is producing notes from the Government's interviews with Dr. Rocchio today as well.\"))\n\n23\nDOJ-OGR-00005807",
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      "content": "Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 24 of 84",
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    {
      "type": "printed",
      "content": "The defense argues that this opinion is outside Dr. Rocchio's expertise because she has \"no experience treating alleged perpetrators,\" so \"her view . . . is entirely one-sided.\" (Id.). As is clear from the above excerpt, her testimony is about largely about trust and attachment built in victims, and the resultant ways in which victims process abuse. But she is also an expert in the actions and techniques of perpetrators through her review of the literature and the lens of what she has learned through victims. This opinion is therefore squarely within Dr. Rocchio's expertise.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Finally, the defendant argues that this testimony violates Rule 704, because it is an \"opinion that the alleged victims in this case are testifying truthfully,\" and 403, because it \"risks jurors accepting her 'expert' opinion as gospel at the expense of their duty to evaluate the evidence.\" (Def. Mot. 3 at 13). Dr. Rocchio has not evaluated the victims in this case and will not express an opinion as to whether they are testifying truthfully. And the defense motion is entirely unclear on the features of this expert opinion that create risk that the jurors would abdicate their responsibilities. To the contrary, the defense concerns underscore how relevant this opinion will be in aiding the jurors in understanding the testimony at trial.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "3. Dr. Rocchio's Opinion on the Long-Term Consequences of Abuse is Admissible",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Dr. Rocchio will also testify that \"[r]epeated exploitation and abuse can increase the likelihood of victimization later in life and can result in long-term traumatic and psychological consequences, especially when it occurs in the context of complex trauma.\" (Def. Mot. 3 Ex. 1 at 2). As Dr. Rocchio will explain, and as is detailed in her Jencks Act material6, experiencing child",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "6 The Government produced Dr. Rocchio's Jencks Act material to the defense at the time of the expert notice. (See Def. Mot. 3 Ex. 1 at 2 (\"The Government is producing notes from the Government's interviews with Dr. Rocchio today as well.\"))",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "23",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005807",
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  ],
  "entities": {
    "people": [
      "Dr. Rocchio"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "397",
      "DOJ-OGR-00005807"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, discussing the admissibility of expert testimony from Dr. Rocchio. The text is well-formatted and clear, with no visible redactions or damage."
}