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  "document_metadata": {
    "page_number": "15",
    "document_number": "424",
    "date": "11/08/21",
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  "full_text": "Case 1:20-cr-00330-PAE Document 424 Filed 11/08/21 Page 15 of 41\nleave to the jury whether such behaviors occurred in this case. Dr. Dietz is free to tell the jury that, in his view, assessing whether grooming occurred is difficult and subjective. (Id. at 4). But it invades the province of the jury to go a further step and tell the jury that it lacks evidence to impute motive or intent. This is, in the most direct way possible, simply telling the jury \"what result to reach.\" H ygh, 961 F.2d at 364 (internal quotation marks omitted).\nThird, Dr. Dietz proposes to opine that the notion that perpetrators target vulnerable victims is \"a commonly accepted bit of clinical lore\" that is unsupported by any empirical data and cannot be verified. (Ex. A at 4). This claim is itself unsupported by any evidence. It is also wrong. For instance, an article cited by Dr. Dietz describes a literature review of sexual abuse involving teachers, which identified \"factors that make a child vulnerable to educator sexual abuse, such as problems at home with parents, lack of confidence, and participation in other risky behavior.\" (See Bennett & O'Donohue, \"The Construct of Grooming in Child Sexual Abuse, 23 J. Child Sexual Abuse 957, 964 (2014), Dkt. No. 397 Ex. A; Ex A at 4 (citing the same)). Other scholars have recognized that \"[g]rooming the child begins with recognizing a vulnerable child,\" such as children with \"a poor relationship with their parents,\" who \"do not have many friends,\" or who \"have already been victimized.\" (Craven et al., \"Sexual grooming of children,\" 12 J. Sexual Aggression 287, 292 (2006), Dkt. No. 397 Ex. A (citations omitted)). Dr. Rochio's clinical experience is supported by the academic literature, in which perpetrators' targeting of vulnerable victims is well established. Dr. Dietz must do more to show the reliability of his view than simply call this literature 'clinical lore' and complain about the lack of data.\nFourth, Dr. Dietz states that \"no authority . . . support[s] a theory of grooming-by-proxy.\" (Ex. A at 4). To the extent that Dr. Dietz is pointing to the fact that the term \"grooming-by-11\nDOJ-OGR-00006226",
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      "content": "Case 1:20-cr-00330-PAE Document 424 Filed 11/08/21 Page 15 of 41",
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      "type": "printed",
      "content": "leave to the jury whether such behaviors occurred in this case. Dr. Dietz is free to tell the jury that, in his view, assessing whether grooming occurred is difficult and subjective. (Id. at 4). But it invades the province of the jury to go a further step and tell the jury that it lacks evidence to impute motive or intent. This is, in the most direct way possible, simply telling the jury \"what result to reach.\" H ygh, 961 F.2d at 364 (internal quotation marks omitted).\nThird, Dr. Dietz proposes to opine that the notion that perpetrators target vulnerable victims is \"a commonly accepted bit of clinical lore\" that is unsupported by any empirical data and cannot be verified. (Ex. A at 4). This claim is itself unsupported by any evidence. It is also wrong. For instance, an article cited by Dr. Dietz describes a literature review of sexual abuse involving teachers, which identified \"factors that make a child vulnerable to educator sexual abuse, such as problems at home with parents, lack of confidence, and participation in other risky behavior.\" (See Bennett & O'Donohue, \"The Construct of Grooming in Child Sexual Abuse, 23 J. Child Sexual Abuse 957, 964 (2014), Dkt. No. 397 Ex. A; Ex A at 4 (citing the same)). Other scholars have recognized that \"[g]rooming the child begins with recognizing a vulnerable child,\" such as children with \"a poor relationship with their parents,\" who \"do not have many friends,\" or who \"have already been victimized.\" (Craven et al., \"Sexual grooming of children,\" 12 J. Sexual Aggression 287, 292 (2006), Dkt. No. 397 Ex. A (citations omitted)). Dr. Rochio's clinical experience is supported by the academic literature, in which perpetrators' targeting of vulnerable victims is well established. Dr. Dietz must do more to show the reliability of his view than simply call this literature 'clinical lore' and complain about the lack of data.\nFourth, Dr. Dietz states that \"no authority . . . support[s] a theory of grooming-by-proxy.\" (Ex. A at 4). To the extent that Dr. Dietz is pointing to the fact that the term \"grooming-by-",
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      "content": "DOJ-OGR-00006226",
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  "entities": {
    "people": [
      "Dr. Dietz",
      "Dr. Rochio",
      "Bennett",
      "O'Donohue",
      "Craven"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "11/08/21",
      "2014",
      "2006"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 424",
      "Dkt. No. 397 Ex. A",
      "DOJ-OGR-00006226"
    ]
  },
  "additional_notes": "The document appears to be a court filing discussing expert testimony in a child sexual abuse case. The text is mostly printed, with no handwritten annotations or stamps visible."
}