{
  "document_metadata": {
    "page_number": "14",
    "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 14 of 24 assault. See Schneider, 2010 WL 3734055, at *2-3 (precluding \"grooming\" testimony from psychologist in prosecution for traveling in foreign commerce for the purpose of engaging in sex with a minor because psychologist's \"experience in the field of child sexual abusers and their victims is one-sided, as it is limited to therapeutic sessions with victims of sexual abuse,\" and because she did \"not treat or diagnose adult abusers of children\"). Any opinion Rocchio might offer about the psychology of alleged perpetrator and their so-called \"grooming\" techniques is outside her expertise and therefore unreliable. United States v. Raniere, No. 18-CR-2041-NGG-VMS, 2019 WL 2212639, at *7 (E.D.N.Y. May 22, 2019); see also Celebrity Cruises Inc. v. Essef Corp., 434 F. Supp. 2d 169, 192 (S.D.N.Y. 2006) (expert not \"permitted to testify regarding\" subjects \"outside the expertise of the witness\"). 2. Rocchio's grooming-by-proxy opinions have no valid basis. Rocchio's generalized grooming opinions are unreliable for all the reasons given above. But there is another reason this Court should exclude her grooming opinions under Rule 702 and Daubert: Nothing establishes the reliability of her opinions on \"grooming-by-proxy.\" Recall that Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the government claims that Ms. Maxwell recruited minors to provide sexualized massages for Mr. Epstein. Part of this recruiting, the government alleges, involved grooming behavior by Ms. Maxwell. There is no authority—no journal articles, no studies, no tests, nothing—to support Rocchio's opinions on grooming-by-proxy. These opinions fail under any application of the Daubert test, because the theory has not gained any acceptance (let alone general acceptance) in the relevant community; it has not been peer-reviewed; it has not and cannot be tested; and there is no known or potential rate of error. See Daubert, 509 U.S. at 594. Rocchio's opinions are grooming-by-proxy are nothing but prejudicial speculation. See Wehling v. Sandoz Pharms. 9 DOJ-OGR-00005638",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 386 Filed 10/29/21 Page 14 of 24",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "assault. See Schneider, 2010 WL 3734055, at *2-3 (precluding \"grooming\" testimony from psychologist in prosecution for traveling in foreign commerce for the purpose of engaging in sex with a minor because psychologist's \"experience in the field of child sexual abusers and their victims is one-sided, as it is limited to therapeutic sessions with victims of sexual abuse,\" and because she did \"not treat or diagnose adult abusers of children\"). Any opinion Rocchio might offer about the psychology of alleged perpetrator and their so-called \"grooming\" techniques is outside her expertise and therefore unreliable. United States v. Raniere, No. 18-CR-2041-NGG-VMS, 2019 WL 2212639, at *7 (E.D.N.Y. May 22, 2019); see also Celebrity Cruises Inc. v. Essef Corp., 434 F. Supp. 2d 169, 192 (S.D.N.Y. 2006) (expert not \"permitted to testify regarding\" subjects \"outside the expertise of the witness\").",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "2. Rocchio's grooming-by-proxy opinions have no valid basis.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Rocchio's generalized grooming opinions are unreliable for all the reasons given above. But there is another reason this Court should exclude her grooming opinions under Rule 702 and Daubert: Nothing establishes the reliability of her opinions on \"grooming-by-proxy.\" Recall that Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the government claims that Ms. Maxwell recruited minors to provide sexualized massages for Mr. Epstein. Part of this recruiting, the government alleges, involved grooming behavior by Ms. Maxwell. There is no authority—no journal articles, no studies, no tests, nothing—to support Rocchio's opinions on grooming-by-proxy. These opinions fail under any application of the Daubert test, because the theory has not gained any acceptance (let alone general acceptance) in the relevant community; it has not been peer-reviewed; it has not and cannot be tested; and there is no known or potential rate of error. See Daubert, 509 U.S. at 594. Rocchio's opinions are grooming-by-proxy are nothing but prejudicial speculation. See Wehling v. Sandoz Pharms.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "9",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005638",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Schneider",
      "Rocchio",
      "Raniere",
      "Maxwell",
      "Epstein"
    ],
    "organizations": [
      "Celebrity Cruises Inc.",
      "Essef Corp.",
      "Sandoz Pharms"
    ],
    "locations": [
      "E.D.N.Y.",
      "S.D.N.Y."
    ],
    "dates": [
      "May 22, 2019",
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 386",
      "18-CR-2041-NGG-VMS",
      "2010 WL 3734055",
      "2019 WL 2212639",
      "434 F. Supp. 2d 169",
      "509 U.S. 594",
      "DOJ-OGR-00005638"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case United States v. Raniere. The text discusses the reliability of expert testimony regarding 'grooming' and 'grooming-by-proxy' in the context of child sexual abuse. The document includes citations to various court cases and legal references."
}