{
  "document_metadata": {
    "page_number": "27",
    "document_number": "453",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 27 of 52\n\nas well as [her] experience conducting forensic psychological evaluations of people who have experienced sexual abuse and trauma.\" Mot. Ex. 1, p 2.\n\n- The government tries to disclaim the importance of error rates. Resp. at 15-17. But it's not just that Rocchio cannot identify an error rate, it's that her implicit conclusion is that she doesn't have an error rate. That is, all her patients are telling the truth when they say they were groomed, so any evidence that matches what her patients have told her is therefore evidence of grooming.\n\n- But even if the error-rate discussion were misplaced, that doesn't mean Rocchio's opinions are reliable. As a \"qualitative\" matter, and as the government's own Exhibit A concedes, there are no \"reliable principles and methods' to define and detect grooming.\" Govt. Resp., Ex. A, p 19 (quoting Fed. R. Evid. 702).\n\n- The government apparently expects that, \"somehow, a lay jury without guidance [will] apply [Rocchio's] analyses reliably to the facts of a case in determining guilt.\" See Raymond, 700 F. Supp. 2d at 150 (rejecting argument that a jury could do just that). This Court should not, as the government request, simply punt the matter to the jury. Resp. at 17-18. The Court is the gatekeeper. It must ensure the evidence is reliable and relevant. If it's not both, it has no place in a criminal jury trial, because it will \"radically simplify\" an otherwise complex case, Burns, 2009 WL 3617448, at *5, and it will, as the United States Supreme Court has cautioned, prejudicially mislead the jury, Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579, 595 (1993) (\"Expert evidence can be both powerful and quite misleading because of the difficulty in evaluating it.\")",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 27 of 52",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "as well as [her] experience conducting forensic psychological evaluations of people who have experienced sexual abuse and trauma.\" Mot. Ex. 1, p 2.\n\n- The government tries to disclaim the importance of error rates. Resp. at 15-17. But it's not just that Rocchio cannot identify an error rate, it's that her implicit conclusion is that she doesn't have an error rate. That is, all her patients are telling the truth when they say they were groomed, so any evidence that matches what her patients have told her is therefore evidence of grooming.\n\n- But even if the error-rate discussion were misplaced, that doesn't mean Rocchio's opinions are reliable. As a \"qualitative\" matter, and as the government's own Exhibit A concedes, there are no \"reliable principles and methods' to define and detect grooming.\" Govt. Resp., Ex. A, p 19 (quoting Fed. R. Evid. 702).\n\n- The government apparently expects that, \"somehow, a lay jury without guidance [will] apply [Rocchio's] analyses reliably to the facts of a case in determining guilt.\" See Raymond, 700 F. Supp. 2d at 150 (rejecting argument that a jury could do just that). This Court should not, as the government request, simply punt the matter to the jury. Resp. at 17-18. The Court is the gatekeeper. It must ensure the evidence is reliable and relevant. If it's not both, it has no place in a criminal jury trial, because it will \"radically simplify\" an otherwise complex case, Burns, 2009 WL 3617448, at *5, and it will, as the United States Supreme Court has cautioned, prejudicially mislead the jury, Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579, 595 (1993) (\"Expert evidence can be both powerful and quite misleading because of the difficulty in evaluating it.\")",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "21",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006907",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [],
    "locations": [],
    "dates": [
      "11/12/21",
      "1993"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "453",
      "27",
      "700 F. Supp. 2d at 150",
      "2009 WL 3617448",
      "509 U.S. 579",
      "DOJ-OGR-00006907"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, discussing the reliability of expert testimony and the importance of error rates in forensic psychological evaluations."
}