{
  "document_metadata": {
    "page_number": "8",
    "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 8 of 24\n\nGovernment does not presently intend to offer Dr. Rocchio's testimony regarding any specific victim.\n\nId. at 2.\n\nThe government elaborates that Rocchio will offer this testimony based on her education and training on psychological trauma, traumatic stress, interpersonal violence, and sexual abuse [and her] extensive clinical experience treating individuals who suffered sexual abuse and trauma in childhood and adolescence, as well as [her] experience conducting forensic psychological evaluations of people who have experienced sexual abuse and trauma.\n\nId. at 2.\n\nARGUMENT\n\nI. Rocchio's proposed testimony is inadmissible.\n\nFederal Rule of Evidence 702 governs the admissibility of Rocchio's proposed testimony.\n\nThat rule says:\n\nA witness who is qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion or otherwise if:\n\n(a) the expert's scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue;\n\n(b) the testimony is based on sufficient facts or data;\n\n(c) the testimony is the product of reliable principles and methods; and\n\n(d) the expert has reliably applied the principles and methods to the facts of the case.\n\nFed. R. Evid. 702.\n\nRule 702 charges district courts \"with 'the task of ensuring that an expert's testimony both rests on a reliable foundation and is relevant to the task at hand.'\" Amorgianos v. Nat'l R.R. Passenger Corp., 303 F.3d 256, 265 (2d Cir. 2002) (quoting Daubert, 509 U.S. at 597); see Fed. R. Evid. 401 & 402. A court must ensure that an expert \"employs in the courtroom the same level of intellectual rigor that characterizes the practice of an expert in the relevant field.\" Nimely",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 386 Filed 10/29/21 Page 8 of 24",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Government does not presently intend to offer Dr. Rocchio's testimony regarding any specific victim.\n\nId. at 2.\n\nThe government elaborates that Rocchio will offer this testimony based on her education and training on psychological trauma, traumatic stress, interpersonal violence, and sexual abuse [and her] extensive clinical experience treating individuals who suffered sexual abuse and trauma in childhood and adolescence, as well as [her] experience conducting forensic psychological evaluations of people who have experienced sexual abuse and trauma.\n\nId. at 2.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "ARGUMENT\n\nI. Rocchio's proposed testimony is inadmissible.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Federal Rule of Evidence 702 governs the admissibility of Rocchio's proposed testimony.\n\nThat rule says:\n\nA witness who is qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion or otherwise if:\n\n(a) the expert's scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue;\n\n(b) the testimony is based on sufficient facts or data;\n\n(c) the testimony is the product of reliable principles and methods; and\n\n(d) the expert has reliably applied the principles and methods to the facts of the case.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Fed. R. Evid. 702.\n\nRule 702 charges district courts \"with 'the task of ensuring that an expert's testimony both rests on a reliable foundation and is relevant to the task at hand.'\" Amorgianos v. Nat'l R.R. Passenger Corp., 303 F.3d 256, 265 (2d Cir. 2002) (quoting Daubert, 509 U.S. at 597); see Fed. R. Evid. 401 & 402. A court must ensure that an expert \"employs in the courtroom the same level of intellectual rigor that characterizes the practice of an expert in the relevant field.\" Nimely",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "3",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005632",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Dr. Rocchio",
      "Amorgianos",
      "Daubert",
      "Nimely"
    ],
    "organizations": [
      "Nat'l R.R. Passenger Corp."
    ],
    "locations": [],
    "dates": [
      "10/29/21",
      "2002"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 386",
      "Fed. R. Evid. 702",
      "Fed. R. Evid. 401",
      "Fed. R. Evid. 402",
      "303 F.3d 256",
      "509 U.S. 597",
      "DOJ-OGR-00005632"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the admissibility of expert testimony. The text is well-formatted and clear, with no visible redactions or damage."
}