{
  "document_metadata": {
    "page_number": "4",
    "document_number": "424-1",
    "date": "11/08/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 424-1 Filed 11/08/21 Page 4 of 15\nComey, Moe, Pomerantz and Rohrbach\nNovember 1, 2021\nPage 3\nprofessional publications. He has authored more than 100 articles and book chapters, primarily on forensic psychiatry.\nHe has conducted more than 1,000 evaluations of persons charged with crime and, in his role as President of Park Dietz & Associates, Inc., has evaluated or supervised over 1,000 evaluations of allegations of sexual victimization. He has testified as an expert witness in forensic psychiatry on hundreds of occasions, including testimony in criminal matters in federal courts throughout the U.S. and the trial courts of nearly every state.\nDr. Dietz will be qualified as an expert in the areas of psychiatry and behavioral science. Dr. Dietz's curriculum vitae is attached as Exhibit B. Attached as Exhibit C is a list of material reviewed by Dr. Dietz.\nHis testimony may include, but will not be limited to, the following:\n\na. Opinions about Dr. Rocchio's Disclosed Opinions\nThe first use of the word \"grooming\" to refer to strategies that sometimes enable nonforceful, nonthreatening, and nonviolent sexual victimization of minors was the proposition that \"the perpetrator involves children in sexual abuse through a grooming process in which a combination of kindness, attention, material enticement, special privilege, and coercion are expertly applied\" (Conte, 1984, p. 558). Since then, this usage has been widely adopted by social scientists, clinicians, journalists, and others. But this usage has some unintended consequences that threaten the integrity of the adjudicative process, including these:\n(1) Because use of the term \"grooming\" commonly assumes that the grooming party is intentionally using these strategies to gain sexual access to children, to abuse them, and to prevent them from disclosing the abuse, the word \"grooming\" has acquired meaning beyond an objective description of behaviors; it imputes motive and intent without adequate evidence of either.\n(2) In the litigation context, \"when 'grooming' is applied to such common and desirable behaviors as being kind or attentive or helpful or caring, there is considerable risk of misleading the fact finder into believing that these latter behaviors are well established predictors of child sexual abuse,\" when they are not. Park Dietz, Grooming and Seduction, 33 J. Interpersonal Violence, 28, 31 (2018). Dr. Rocchio characterizes \"grooming\" as \"a strategic pattern of behavior[] . . . that can take a variety of forms and function to render the victims vulnerable to abuse, to obscure the nature of the abuse, and to build trust and attachment with their abuser.\" This vague opinion about \"grooming\" carries the risk of imputing motive and intent to the Defendant, when the determination of motive and intent is a task for the fact finder charged with determining the credibility of witnesses, the weight of the evidence, and the ultimate issues. Moreover, this opinion carries the risk of implying that innocuous and even desirable behaviors are associated with nefarious or criminal conduct.\nDOJ-OGR-00006256",
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      "content": "Case 1:20-cr-00330-PAE Document 424-1 Filed 11/08/21 Page 4 of 15",
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    {
      "type": "printed",
      "content": "Comey, Moe, Pomerantz and Rohrbach\nNovember 1, 2021\nPage 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "professional publications. He has authored more than 100 articles and book chapters, primarily on forensic psychiatry.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "He has conducted more than 1,000 evaluations of persons charged with crime and, in his role as President of Park Dietz & Associates, Inc., has evaluated or supervised over 1,000 evaluations of allegations of sexual victimization. He has testified as an expert witness in forensic psychiatry on hundreds of occasions, including testimony in criminal matters in federal courts throughout the U.S. and the trial courts of nearly every state.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Dr. Dietz will be qualified as an expert in the areas of psychiatry and behavioral science. Dr. Dietz's curriculum vitae is attached as Exhibit B. Attached as Exhibit C is a list of material reviewed by Dr. Dietz.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "His testimony may include, but will not be limited to, the following:",
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    {
      "type": "printed",
      "content": "a. Opinions about Dr. Rocchio's Disclosed Opinions",
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    {
      "type": "printed",
      "content": "The first use of the word \"grooming\" to refer to strategies that sometimes enable nonforceful, nonthreatening, and nonviolent sexual victimization of minors was the proposition that \"the perpetrator involves children in sexual abuse through a grooming process in which a combination of kindness, attention, material enticement, special privilege, and coercion are expertly applied\" (Conte, 1984, p. 558). Since then, this usage has been widely adopted by social scientists, clinicians, journalists, and others. But this usage has some unintended consequences that threaten the integrity of the adjudicative process, including these:",
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    {
      "type": "printed",
      "content": "(1) Because use of the term \"grooming\" commonly assumes that the grooming party is intentionally using these strategies to gain sexual access to children, to abuse them, and to prevent them from disclosing the abuse, the word \"grooming\" has acquired meaning beyond an objective description of behaviors; it imputes motive and intent without adequate evidence of either.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "(2) In the litigation context, \"when 'grooming' is applied to such common and desirable behaviors as being kind or attentive or helpful or caring, there is considerable risk of misleading the fact finder into believing that these latter behaviors are well established predictors of child sexual abuse,\" when they are not. Park Dietz, Grooming and Seduction, 33 J. Interpersonal Violence, 28, 31 (2018). Dr. Rocchio characterizes \"grooming\" as \"a strategic pattern of behavior[] . . . that can take a variety of forms and function to render the victims vulnerable to abuse, to obscure the nature of the abuse, and to build trust and attachment with their abuser.\" This vague opinion about \"grooming\" carries the risk of imputing motive and intent to the Defendant, when the determination of motive and intent is a task for the fact finder charged with determining the credibility of witnesses, the weight of the evidence, and the ultimate issues. Moreover, this opinion carries the risk of implying that innocuous and even desirable behaviors are associated with nefarious or criminal conduct.",
      "position": "body"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00006256",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Comey",
      "Moe",
      "Pomerantz",
      "Rohrbach",
      "Dr. Dietz",
      "Dr. Rocchio",
      "Conte"
    ],
    "organizations": [
      "Park Dietz & Associates, Inc."
    ],
    "locations": [
      "U.S."
    ],
    "dates": [
      "November 1, 2021",
      "11/08/21",
      "1984",
      "2018"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 424-1",
      "Exhibit B",
      "Exhibit C",
      "33 J. Interpersonal Violence, 28, 31 (2018)",
      "DOJ-OGR-00006256"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, with expert testimony from Dr. Dietz regarding the concept of 'grooming' in the context of child sexual abuse. The text is primarily printed, with no handwritten annotations or stamps visible."
}