{
  "document_metadata": {
    "page_number": "18",
    "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 18 of 84\n\n.\" Joseph, 542 F.3d at 21-22 (first and second alterations in original) (citations and internal quotation marks omitted).\n\nThat point is particularly true in sex trafficking cases. As Judge Engelmayer explained when evaluating the testimony of a similar expert in a sex trafficking case, analyzing error rates is an \"unusually poor fit\" in this area:\n\n[S]tudying the circumstances and psychological drivers of trafficked women is not like studying diseases or potential cures in laboratory animals. . . . Given the necessarily retrospective nature of such a study, given the small size of the populations under review, and given the inherently individualized circumstances presented by different perpetrators, victims, and contexts in this tumultuous and emotionally fraught area of criminal conduct, the vocabulary of error rates . . . is an unusually poor fit. . . . The testing that has been done as to trauma bonding and coercive control, instead, necessarily uses more qualitative research methodologies. These involve interviews and case studies and clinical examinations conducted over time.\"\n\nFeb. 25, 2020 Tr. at 29:4-30:20, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335. Because statistical rigor is not a useful method for evaluating the reliability of qualitative research like Dr. Rocchio's, statistical tools like error rates are irrelevant to the Daubert analysis.\n\nContrary to the defendant's next claim, these opinions are not \"impregnable for purposes of cross examination.\" (Def. Mot. 3 at 7 (citation and internal quotation marks omitted)). The defendant is free to cross Dr. Rocchio on how frequently she sees grooming in her patients and how she evaluates whether they are telling the truth. The defendant is also free to explore, in cross examination, the difficulties in assessing whether a patient has been groomed. The defense can also make arguments—in cross examination and in jury addresses—about the lack of quantitative rigor in this qualitative area of science. That is the point: it is for the jury, after hearing the\n\n17\n\nDOJ-OGR-00006726",
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      "content": "Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 18 of 84",
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      "type": "printed",
      "content": ".\" Joseph, 542 F.3d at 21-22 (first and second alterations in original) (citations and internal quotation marks omitted).\n\nThat point is particularly true in sex trafficking cases. As Judge Engelmayer explained when evaluating the testimony of a similar expert in a sex trafficking case, analyzing error rates is an \"unusually poor fit\" in this area:\n\n[S]tudying the circumstances and psychological drivers of trafficked women is not like studying diseases or potential cures in laboratory animals. . . . Given the necessarily retrospective nature of such a study, given the small size of the populations under review, and given the inherently individualized circumstances presented by different perpetrators, victims, and contexts in this tumultuous and emotionally fraught area of criminal conduct, the vocabulary of error rates . . . is an unusually poor fit. . . . The testing that has been done as to trauma bonding and coercive control, instead, necessarily uses more qualitative research methodologies. These involve interviews and case studies and clinical examinations conducted over time.\"\n\nFeb. 25, 2020 Tr. at 29:4-30:20, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335. Because statistical rigor is not a useful method for evaluating the reliability of qualitative research like Dr. Rocchio's, statistical tools like error rates are irrelevant to the Daubert analysis.\n\nContrary to the defendant's next claim, these opinions are not \"impregnable for purposes of cross examination.\" (Def. Mot. 3 at 7 (citation and internal quotation marks omitted)). The defendant is free to cross Dr. Rocchio on how frequently she sees grooming in her patients and how she evaluates whether they are telling the truth. The defendant is also free to explore, in cross examination, the difficulties in assessing whether a patient has been groomed. The defense can also make arguments—in cross examination and in jury addresses—about the lack of quantitative rigor in this qualitative area of science. That is the point: it is for the jury, after hearing the",
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      "content": "17",
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      "content": "DOJ-OGR-00006726",
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  ],
  "entities": {
    "people": [
      "Joseph",
      "Judge Engelmayer",
      "Dr. Rocchio"
    ],
    "organizations": [
      "United States"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "Feb. 25, 2020",
      "11/12/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 452",
      "19 Cr. 131 (PAE)",
      "Dkt. No. 335",
      "DOJ-OGR-00006726"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a sex trafficking case, discussing the reliability of expert testimony and the limitations of statistical analysis in qualitative research."
}