{
  "document_metadata": {
    "page_number": "23",
    "document_number": "398",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 23 of 52\n\nB. Rocchio's proposed testimony is inadmissible.\nAccording to the government, Ms. Maxwell \"does not contest that Dr. Rocchio is a qualified expert.\" Resp. at 9. To the degree that Dr. Rocchio has the credentials of a potential expert, the government is right.\nBut saying that Rocchio is a \"qualified expert\" is not enough. The government must identify what Rocchio is an expert in. Fed. R. Evid. 702; Fed. R. Crim. 16. As Ms. Maxwell pointed out in her motion, the government hasn't done that. Mot. at 2.\nWhat's more, even if Rocchio is a \"qualified expert\" in something, she is not a \"qualified expert\" in everything. (For example, the government agrees that she is not an expert in the human brain or memory generally. Resp. at 30 n.7.) And as even the government admits, Rocchio has no experience or expertise in diagnosing, evaluating, or treating alleged perpetrators of sexual abuse. Resp. at 19, 23, 26. She cannot therefore speak to the psychology of alleged perpetrators and their so-called \"grooming techniques.\"\nThe government attempts a two-step to get around this problem. \"By virtue of experience treating victims,\" says the government, \"Dr. Rocchio is necessarily informed about perpetrators' actions.\" Resp. at 19.\nBut how does Rocchio know her patients were victims of sexual abuse? Because her patients told her so, and Rocchio assumes they are telling the truth. Again, Rocchio's opinions are based on her treatment of a self-selected, unrepresentative group of individuals she assumes are telling the truth and are therapeutic consumers in a financial relationship with her.\nThe government has no response to this, other than to say that Rocchio and other \"[c]linical psychologists are not so credulous.\" Resp. at 16. If this were right, though, one would expect the government to explain how clinical psychologists ensure their patients are telling the truth — in other words, how clinical psychologists like Rocchio test and verify their opinions.\n17\nDOJ-OGR-00005978",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 23 of 52",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "B. Rocchio's proposed testimony is inadmissible.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "According to the government, Ms. Maxwell \"does not contest that Dr. Rocchio is a qualified expert.\" Resp. at 9. To the degree that Dr. Rocchio has the credentials of a potential expert, the government is right.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "But saying that Rocchio is a \"qualified expert\" is not enough. The government must identify what Rocchio is an expert in. Fed. R. Evid. 702; Fed. R. Crim. 16. As Ms. Maxwell pointed out in her motion, the government hasn't done that. Mot. at 2.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "What's more, even if Rocchio is a \"qualified expert\" in something, she is not a \"qualified expert\" in everything. (For example, the government agrees that she is not an expert in the human brain or memory generally. Resp. at 30 n.7.) And as even the government admits, Rocchio has no experience or expertise in diagnosing, evaluating, or treating alleged perpetrators of sexual abuse. Resp. at 19, 23, 26. She cannot therefore speak to the psychology of alleged perpetrators and their so-called \"grooming techniques.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government attempts a two-step to get around this problem. \"By virtue of experience treating victims,\" says the government, \"Dr. Rocchio is necessarily informed about perpetrators' actions.\" Resp. at 19.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "But how does Rocchio know her patients were victims of sexual abuse? Because her patients told her so, and Rocchio assumes they are telling the truth. Again, Rocchio's opinions are based on her treatment of a self-selected, unrepresentative group of individuals she assumes are telling the truth and are therapeutic consumers in a financial relationship with her.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government has no response to this, other than to say that Rocchio and other \"[c]linical psychologists are not so credulous.\" Resp. at 16. If this were right, though, one would expect the government to explain how clinical psychologists ensure their patients are telling the truth — in other words, how clinical psychologists like Rocchio test and verify their opinions.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "17",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005978",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Rocchio",
      "Maxwell"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "398",
      "DOJ-OGR-00005978"
    ]
  },
  "additional_notes": "The document appears to be a court filing discussing the admissibility of expert testimony. The text is printed and legible, with no visible handwriting or stamps."
}