{
  "document_metadata": {
    "page_number": "10",
    "document_number": "386",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 386 Filed 10/29/21 Page 10 of 24\nelement of the crime charged or of a defense\" because those \"matters are for the trier of fact alone.\" Fed R. Evid. 704(b).\nRule 403 demands exclusion when the probative value of evidence is substantially outweighed by the danger of unfair prejudice or misleading the jury. Fed. R. Evid. 403.\nAnd Rule 404 prohibits any witness, witness or lay, from offering evidence \"of a person's character or character trait . . . to prove that on a particular occasion the person acted in accordance with the character or trait.\" Fed. R. Evid. 404(a)(1).\nApplying these provisions, and as elaborated below, each of Rocchio's opinions is inadmissible.\nA. Opinion 1: Minor victims are often subject to a strategic pattern of behaviors, often called grooming, 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.\n1. Rocchio's grooming opinions are unreliable.\nRocchio's first and most prominent proposed area of testimony concerns \"grooming,\" which she characterizes 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.\" Ex. 1, p 2. Rocchio continues that \"[i]ndividuals with particular vulnerabilities are often targeted [through grooming] by perpetrators of sexual abuse\" and that \"[s]exual abuse of minors frequently occurs through the use of manipulation or coercion in the context of an established relationship that is developed over time, rather than through the use of forcible rape.\" Id.\nThese opinions on grooming are not based \"on scientific research or data.\" Gonyer, 2012 WL 3043020, at *2 (granting defendant's motion to preclude evidence from the government's \"expert on sexual predator grooming techniques in its case-in-chief in a jury trial on charges of",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 386 Filed 10/29/21 Page 10 of 24",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "element of the crime charged or of a defense\" because those \"matters are for the trier of fact alone.\" Fed R. Evid. 704(b).\nRule 403 demands exclusion when the probative value of evidence is substantially outweighed by the danger of unfair prejudice or misleading the jury. Fed. R. Evid. 403.\nAnd Rule 404 prohibits any witness, witness or lay, from offering evidence \"of a person's character or character trait . . . to prove that on a particular occasion the person acted in accordance with the character or trait.\" Fed. R. Evid. 404(a)(1).\nApplying these provisions, and as elaborated below, each of Rocchio's opinions is inadmissible.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "A. Opinion 1: Minor victims are often subject to a strategic pattern of behaviors, often called grooming, 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.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1. Rocchio's grooming opinions are unreliable.\nRocchio's first and most prominent proposed area of testimony concerns \"grooming,\" which she characterizes 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.\" Ex. 1, p 2. Rocchio continues that \"[i]ndividuals with particular vulnerabilities are often targeted [through grooming] by perpetrators of sexual abuse\" and that \"[s]exual abuse of minors frequently occurs through the use of manipulation or coercion in the context of an established relationship that is developed over time, rather than through the use of forcible rape.\" Id.\nThese opinions on grooming are not based \"on scientific research or data.\" Gonyer, 2012 WL 3043020, at *2 (granting defendant's motion to preclude evidence from the government's \"expert on sexual predator grooming techniques in its case-in-chief in a jury trial on charges of",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "5",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005634",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Rocchio",
      "Gonyer"
    ],
    "organizations": [
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "10/29/21",
      "2012"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 386",
      "2012 WL 3043020"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, discussing the admissibility of expert testimony regarding 'grooming' behaviors in the context of sexual abuse of minors. The text is printed and there are no visible stamps or handwritten annotations."
}