{
  "document_metadata": {
    "page_number": "35 of 41",
    "document_number": "424",
    "date": "11/08/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 424 Filed 11/08/21 Page 35 of 41\nabout the bases or details of Dr. Loftus's opinion—it simply states that she is testifying \"[b]ased on her education, training, experience, and research.\" (Ex. A at 1).11\nMoreover, there is specific reason to doubt the reliability of Dr. Loftus's opinions as to false memory formation. A number of Dr. Loftus's opinions were tested and rejected in United States v. Libby, 461 F. Supp. 2d at 8-18. There, the defendant relied on Dr. Loftus's research regarding alleged juror misperceptions of the reliability of eyewitness identifications, presented in a 2006 article. See id. at 10-11 (citing, e.g., R. Schmechel, T. O'Toole, C. Easterly, & E. Loftus, Beyond the Ken? Testing Jurors' Understanding of Eyewitness Reliability Evidence, 46 Jurimetrics J. 177-214 (2006)). The district court rejected such research, concluding that \"the design of these surveys demonstrates their limited value.\" Libby, 461 F. Supp. 2d at 11. The court found that the survey design used in Loftus's article was \"based primarily on hypothetical situations involving eyewitness identification and the credibility of eyewitnesses.\" Id. The court also found—and Dr. Loftus \"reluctantly agreed in part\"—that the some of the studies were in part \"structurally flawed\" because certain questions asked of respondents were \"unclear.\" Id. at 16.\nThe Government, moreover, understands that much of Dr. Loftus's research involves controlled laboratory experiments rather than clinical work because studies about, for instance, the creation of false memories, may be unethical in the clinical context. See, e.g. Elizabeth F. Loftus, UCI\n11 While the Government's expert notice for Dr. Rocchio contained similar language, it also explained that Dr. Rocchio was testifying based on her \"extensive clinical experience treating individuals who suffered s]exual abuse and trauma in childhood and adolescence, as well as Dr. Rocchio's experience conducting forensic psychological evaluations of people who have experienced sexual abuse and trauma.\" (Def. Mot. 3 Ex. A at 2). The Government also produced its notes from its interviews with Dr. Rocchio simultaneously with its expert notice. The defense expert notice identifies no particular form of training, experience, or research on which Dr. Loftus is relying, nor has the defense produced any notes of its conversations with Dr. Loftus.\n31\nDOJ-OGR-00006246",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 424 Filed 11/08/21 Page 35 of 41",
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    {
      "type": "printed",
      "content": "about the bases or details of Dr. Loftus's opinion—it simply states that she is testifying \"[b]ased on her education, training, experience, and research.\" (Ex. A at 1).11\nMoreover, there is specific reason to doubt the reliability of Dr. Loftus's opinions as to false memory formation. A number of Dr. Loftus's opinions were tested and rejected in United States v. Libby, 461 F. Supp. 2d at 8-18. There, the defendant relied on Dr. Loftus's research regarding alleged juror misperceptions of the reliability of eyewitness identifications, presented in a 2006 article. See id. at 10-11 (citing, e.g., R. Schmechel, T. O'Toole, C. Easterly, & E. Loftus, Beyond the Ken? Testing Jurors' Understanding of Eyewitness Reliability Evidence, 46 Jurimetrics J. 177-214 (2006)). The district court rejected such research, concluding that \"the design of these surveys demonstrates their limited value.\" Libby, 461 F. Supp. 2d at 11. The court found that the survey design used in Loftus's article was \"based primarily on hypothetical situations involving eyewitness identification and the credibility of eyewitnesses.\" Id. The court also found—and Dr. Loftus \"reluctantly agreed in part\"—that the some of the studies were in part \"structurally flawed\" because certain questions asked of respondents were \"unclear.\" Id. at 16.\nThe Government, moreover, understands that much of Dr. Loftus's research involves controlled laboratory experiments rather than clinical work because studies about, for instance, the creation of false memories, may be unethical in the clinical context. See, e.g. Elizabeth F. Loftus, UCI",
      "position": "main body"
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    {
      "type": "printed",
      "content": "11 While the Government's expert notice for Dr. Rocchio contained similar language, it also explained that Dr. Rocchio was testifying based on her \"extensive clinical experience treating individuals who suffered s]exual abuse and trauma in childhood and adolescence, as well as Dr. Rocchio's experience conducting forensic psychological evaluations of people who have experienced sexual abuse and trauma.\" (Def. Mot. 3 Ex. A at 2). The Government also produced its notes from its interviews with Dr. Rocchio simultaneously with its expert notice. The defense expert notice identifies no particular form of training, experience, or research on which Dr. Loftus is relying, nor has the defense produced any notes of its conversations with Dr. Loftus.",
      "position": "main body"
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    {
      "type": "printed",
      "content": "31",
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    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006246",
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  ],
  "entities": {
    "people": [
      "Dr. Loftus",
      "Dr. Rocchio",
      "R. Schmechel",
      "T. O'Toole",
      "C. Easterly",
      "E. Loftus",
      "Elizabeth F. Loftus"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "11/08/21",
      "2006"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 424",
      "461 F. Supp. 2d",
      "46 Jurimetrics J. 177-214",
      "Def. Mot. 3 Ex. A at 2",
      "DOJ-OGR-00006246"
    ]
  },
  "additional_notes": "The document appears to be a court filing discussing the reliability of Dr. Loftus's opinions and research on false memory formation. The text is printed and legible, with no visible handwriting or stamps."
}