{
  "document_metadata": {
    "page_number": "26 of 52",
    "document_number": "398",
    "date": "10/29/21",
    "document_type": "court document",
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  "full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 26 of 52\nsituation here, in which the alleged \"groomer\" was not the person who perpetrated the alleged abuse.\n- Even where the \"groomer\" and \"perpetrator\" are the same person, courts have recognized the unreliability of grooming testimony. United States v. Gonyer, No. 1:12-CR-00021-JAW, 2012 WL 3043020, at *2-3 (D. Me. July 24, 2012); United States v. Raymond, 700 F. Supp. 2d 142, 146-47 (D. Me. 2010); United States v. Schneider, No. CRIM.A. 10-29, 2010 WL 3734055, at *4 (E.D. Pa. Sept. 22, 2010); see also United States v. Raniere, No. 18-CR-2041-NGG-VMS, 2019 WL 2212639, at *7 (E.D.N.Y. May 22, 2019); United States v. Burns, No. 07 CR 556, 2009 WL 3617448, at *5 (N.D. Ill. Oct. 27, 2009) (criticizing the \"grooming theory\" in the context of a sentencing guidelines calculation).\n- The government tries to distinguish United States v. Raymond by saying that the expert's own book in that case \"disavow[ed] [its] reliability . . . for legal use.\" Resp. at 14. But that is exactly the situation here, because the primary article on which the government relies—Exhibit A to its response—flatly says \"that grooming is not a construct that ought to be used in forensic settings as it does not meet some of the criteria in the Daubert standard.\" Resp., Ex. A, p 19.\n- The government says Rocchio's opinions are not \"anecdotal.\" But that's not right either, as her endorsement makes clear: Rocchio's opinions are based \"on her education and training on psychological trauma, traumatic stress, interpersonal violence, and sexual abuse [and her] extensive clinical experience treating individuals who suffered sexual abuse and trauma in childhood and adolescence,\n20\nDOJ-OGR-00005981",
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      "content": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 26 of 52",
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      "type": "printed",
      "content": "situation here, in which the alleged \"groomer\" was not the person who perpetrated the alleged abuse.",
      "position": "top"
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    {
      "type": "printed",
      "content": "- Even where the \"groomer\" and \"perpetrator\" are the same person, courts have recognized the unreliability of grooming testimony. United States v. Gonyer, No. 1:12-CR-00021-JAW, 2012 WL 3043020, at *2-3 (D. Me. July 24, 2012); United States v. Raymond, 700 F. Supp. 2d 142, 146-47 (D. Me. 2010); United States v. Schneider, No. CRIM.A. 10-29, 2010 WL 3734055, at *4 (E.D. Pa. Sept. 22, 2010); see also United States v. Raniere, No. 18-CR-2041-NGG-VMS, 2019 WL 2212639, at *7 (E.D.N.Y. May 22, 2019); United States v. Burns, No. 07 CR 556, 2009 WL 3617448, at *5 (N.D. Ill. Oct. 27, 2009) (criticizing the \"grooming theory\" in the context of a sentencing guidelines calculation).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- The government tries to distinguish United States v. Raymond by saying that the expert's own book in that case \"disavow[ed] [its] reliability . . . for legal use.\" Resp. at 14. But that is exactly the situation here, because the primary article on which the government relies—Exhibit A to its response—flatly says \"that grooming is not a construct that ought to be used in forensic settings as it does not meet some of the criteria in the Daubert standard.\" Resp., Ex. A, p 19.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- The government says Rocchio's opinions are not \"anecdotal.\" But that's not right either, as her endorsement makes clear: Rocchio's opinions are based \"on her education and training on psychological trauma, traumatic stress, interpersonal violence, and sexual abuse [and her] extensive clinical experience treating individuals who suffered sexual abuse and trauma in childhood and adolescence,",
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      "content": "DOJ-OGR-00005981",
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  "entities": {
    "people": [],
    "organizations": [
      "United States"
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    "locations": [
      "Maine",
      "Pennsylvania",
      "New York",
      "Illinois"
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    "dates": [
      "July 24, 2012",
      "September 22, 2010",
      "May 22, 2019",
      "October 27, 2009",
      "October 29, 2021"
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    "reference_numbers": [
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  "additional_notes": "The document appears to be a court filing discussing the reliability of 'grooming testimony' in a legal context. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and legible."
}