{
  "document_metadata": {
    "page_number": "24 of 28",
    "document_number": "499",
    "date": "11/23/21",
    "document_type": "court document",
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  "full_text": "Case 1:20-cr-00330-PAE Document 499 Filed 11/23/21 Page 24 of 28 trauma on memory. The government does not explain how it can be fair to oppose the testimony of an actual memory expert. According to the government, (Dkt. 397), Dr. Rocchio's testimony about memory is proper under Fed. R. Evid. 702 because: Sexual abuse also impacts the way memory is encoded. In traumatic circumstances, often only the most salient details are encoded, and over time, specific details may be lost. With traumatic memory in particular, adrenaline and cortisol responses in the context of fear and trauma cause people to narrow their focus to the most salient and relevant details. If someone is abused multiple times or by multiple people, it is very common for memories of similar occurrences to jumble together, although the victim can remember the perpetrator and maybe some of the locations where the abuse occurred. Taken together, Dr. Rocchio's expert testimony explains why victims of child sexual abuse-and especially repeated sexual abuse-may disclose their abuse in a delayed and incremental fashion, and why their memories may lack some level of detail when the disclosure finally occurs. The validity of these opinions is debatable. What is not, however, is that these opinions are a small part of what may or may not affect someone's memory over time. The government desperately wants to avoid discussing the other factors that may affect memory such as suggestibility, substance abuse (both short and long term), secondary gain, the effects of time, psychological disorders, and confabulation (Dr. Rocchio admitted that these things impact memory during the 702 hearing). E.g., Ex. 2, p 121-22. These are not topics readily understandable. The government has selected a \"trauma\" expert who will present only a small, self-serving part of the science related to memory. Experts such as Dr. Loftus spend a lifetime researching and writing about these concepts which have been regularly misunderstood by fact finders. One need only to consider the extraordinary number of innocent people convicted on what was thought to be reliable testimony based on faulty memories of witnesses whose convictions were reversed after DNA evidence proved the \"memories\" incorrect. Jurors do not understand these scientific concepts and will benefit from 20 DOJ-OGR-00007489",
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      "content": "Case 1:20-cr-00330-PAE Document 499 Filed 11/23/21 Page 24 of 28",
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      "content": "trauma on memory. The government does not explain how it can be fair to oppose the testimony of an actual memory expert. According to the government, (Dkt. 397), Dr. Rocchio's testimony about memory is proper under Fed. R. Evid. 702 because: Sexual abuse also impacts the way memory is encoded. In traumatic circumstances, often only the most salient details are encoded, and over time, specific details may be lost. With traumatic memory in particular, adrenaline and cortisol responses in the context of fear and trauma cause people to narrow their focus to the most salient and relevant details. If someone is abused multiple times or by multiple people, it is very common for memories of similar occurrences to jumble together, although the victim can remember the perpetrator and maybe some of the locations where the abuse occurred. Taken together, Dr. Rocchio's expert testimony explains why victims of child sexual abuse-and especially repeated sexual abuse-may disclose their abuse in a delayed and incremental fashion, and why their memories may lack some level of detail when the disclosure finally occurs. The validity of these opinions is debatable. What is not, however, is that these opinions are a small part of what may or may not affect someone's memory over time. The government desperately wants to avoid discussing the other factors that may affect memory such as suggestibility, substance abuse (both short and long term), secondary gain, the effects of time, psychological disorders, and confabulation (Dr. Rocchio admitted that these things impact memory during the 702 hearing). E.g., Ex. 2, p 121-22. These are not topics readily understandable. The government has selected a \"trauma\" expert who will present only a small, self-serving part of the science related to memory. Experts such as Dr. Loftus spend a lifetime researching and writing about these concepts which have been regularly misunderstood by fact finders. One need only to consider the extraordinary number of innocent people convicted on what was thought to be reliable testimony based on faulty memories of witnesses whose convictions were reversed after DNA evidence proved the \"memories\" incorrect. Jurors do not understand these scientific concepts and will benefit from",
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      "content": "20",
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    {
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      "content": "DOJ-OGR-00007489",
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  "entities": {
    "people": [
      "Dr. Rocchio",
      "Dr. Loftus"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "11/23/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 499",
      "Dkt. 397",
      "Ex. 2",
      "DOJ-OGR-00007489"
    ]
  },
  "additional_notes": "The document appears to be a court filing discussing the testimony of Dr. Rocchio and its relevance to memory and trauma. The text is printed and there are no visible stamps or handwritten notes. The document is from a legal case with the reference number 1:20-cr-00330-PAE."
}