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results/IMAGES003/DOJ-OGR-00007151.json

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+  "document_metadata": {
+    "page_number": "100",
+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
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+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 100 of 127 LB1TMAX3 the defense to engage in the full set of questions that counsel has indicated, but for purposes of the in limine motion, it's denied. Defense 19. Here, the defense seeks to suppress alleged Victim-4's identification of Ms. Maxwell on the ground that the government used unduly suggestive photo array procedures that violate due process rights. I am prepared to deny this motion. Eyewitness identifications should be excluded when improper police conduct created a substantial likelihood of misidentification. Perry v. New Hampshire, 565 U.S. 228, (2012). I follow a two-step analysis in ruling on the admissibility of identification evidence. First, I must determine whether the pretrial identification procedures were unduly suggestive. Some examples of suggestive procedures include using a very small number of photographs, making suggestive comments, or the display of the accused in a way that so stood out from all other photographs to suggest to an identifying eyewitness that the person was more likely to be the culprit. See, United States v. Concepcion, 983 F.2d 369, (2d Cir. 1992). Looking at the photo array, neither the photos used or the procedure itself was unduly suggestive. The array contained a sufficient number of photos larger than many arrays that courts have held were not unduly suggestive. Defense's SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007151",
+  "text_blocks": [
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+      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 100 of 127",
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+    {
+      "type": "printed",
+      "content": "LB1TMAX3 the defense to engage in the full set of questions that counsel has indicated, but for purposes of the in limine motion, it's denied. Defense 19. Here, the defense seeks to suppress alleged Victim-4's identification of Ms. Maxwell on the ground that the government used unduly suggestive photo array procedures that violate due process rights. I am prepared to deny this motion. Eyewitness identifications should be excluded when improper police conduct created a substantial likelihood of misidentification. Perry v. New Hampshire, 565 U.S. 228, (2012). I follow a two-step analysis in ruling on the admissibility of identification evidence. First, I must determine whether the pretrial identification procedures were unduly suggestive. Some examples of suggestive procedures include using a very small number of photographs, making suggestive comments, or the display of the accused in a way that so stood out from all other photographs to suggest to an identifying eyewitness that the person was more likely to be the culprit. See, United States v. Concepcion, 983 F.2d 369, (2d Cir. 1992). Looking at the photo array, neither the photos used or the procedure itself was unduly suggestive. The array contained a sufficient number of photos larger than many arrays that courts have held were not unduly suggestive. Defense's",
+      "position": "main content"
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+    {
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+      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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+      "content": "DOJ-OGR-00007151",
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+  ],
+  "entities": {
+    "people": [
+      "Ms. Maxwell",
+      "Victim-4"
+    ],
+    "organizations": [
+      "SOUTHERN DISTRICT REPORTERS, P.C."
+    ],
+    "locations": [
+      "New Hampshire"
+    ],
+    "dates": [
+      "11/15/21",
+      "2012"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 465",
+      "DOJ-OGR-00007151"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript or legal document. The text is typed, and there are no visible handwritten notes or stamps. The document includes a case number, document number, and filing date."
+}

results/IMAGES003/DOJ-OGR-00007152.json

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+{
+  "document_metadata": {
+    "page_number": "101",
+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court document",
+    "has_handwriting": false,
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+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 101 of 127\nLB1TMAX3\n\nargument that the Ms. Maxwell's photo looks like a mugshot and is different from the others doesn't persuade me here. Alleged Victim-4 identified at least one other photo in the array that she thought could be Ms. Maxwell but she ultimately chose Ms. Maxwell's photo, and there were several photos in the array that were of roughly the same quality and angle as Ms. Maxwell's photo.\n\nThe defense fails to identify any suggestive comments made during the identification that would deem the procedures unduly suggestive. The government appears to have asked whether the individual recognized anyone in the book. So I conclude the identification procedure was not unduly suggestive.\n\nEven assuming the photo array was unduly suggestive, the identification here had independent reliability factors I must consider under the totality of circumstances that include the opportunity of the witness to view the individual at the time of the alleged crime, the witness's degree of attention, the accuracy of the the witness's prior description of the individual, the level of uncertainty demonstrated, the length of time between the alleged crime and the confrontation. See, Neil v. Biggers, 409 U.S. 188, (1972).\n\nHere, the alleged Victim-4 had the opportunity to view Ms. Maxwell. They interacted several times over the span of years. As the government points out, the alleged interactions\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00007152",
+  "text_blocks": [
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+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 101 of 127",
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+      "type": "printed",
+      "content": "LB1TMAX3",
+      "position": "header"
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+    {
+      "type": "printed",
+      "content": "argument that the Ms. Maxwell's photo looks like a mugshot and is different from the others doesn't persuade me here. Alleged Victim-4 identified at least one other photo in the array that she thought could be Ms. Maxwell but she ultimately chose Ms. Maxwell's photo, and there were several photos in the array that were of roughly the same quality and angle as Ms. Maxwell's photo.",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "The defense fails to identify any suggestive comments made during the identification that would deem the procedures unduly suggestive. The government appears to have asked whether the individual recognized anyone in the book. So I conclude the identification procedure was not unduly suggestive.",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Even assuming the photo array was unduly suggestive, the identification here had independent reliability factors I must consider under the totality of circumstances that include the opportunity of the witness to view the individual at the time of the alleged crime, the witness's degree of attention, the accuracy of the the witness's prior description of the individual, the level of uncertainty demonstrated, the length of time between the alleged crime and the confrontation. See, Neil v. Biggers, 409 U.S. 188, (1972).",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Here, the alleged Victim-4 had the opportunity to view Ms. Maxwell. They interacted several times over the span of years. As the government points out, the alleged interactions",
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+    {
+      "type": "printed",
+      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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+      "content": "DOJ-OGR-00007152",
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+  ],
+  "entities": {
+    "people": [
+      "Ms. Maxwell",
+      "Victim-4",
+      "Neil"
+    ],
+    "organizations": [
+      "SOUTHERN DISTRICT REPORTERS, P.C."
+    ],
+    "locations": [],
+    "dates": [
+      "11/15/21",
+      "1972"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 465",
+      "409 U.S. 188",
+      "DOJ-OGR-00007152"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript or legal document. The text is typed, and there are no visible handwritten notes or stamps. The document is from a court case involving Ms. Maxwell."
+}

results/IMAGES003/DOJ-OGR-00007154.json

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+{
+  "document_metadata": {
+    "page_number": "103",
+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court transcript",
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+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 103 of 127\nLB15max4\n1 THE COURT: (Continuing)\n2 The government also correctly notes that the delay in time between the alleged misconduct and identification is not determinative because of the frequency of interactions between the alleged individual and Ms. Maxwell. Alleged Victim 4 was able to identify Ms. Maxwell when she got to the photo in the array with little hesitation. The argument that -- I will leave it at that.\n3\n4\n5\n6\n7\n8\n9 The defense requested an evidentiary hearing on this issue but I don't see facts put forward by the defense that puts, in genuine dispute, any facts that would support suppression of the identification so there would be nothing gained from an evidentiary rehearing, see United States v. Brown, 784 F. App'x 1 (2d Cir. 2019) so the request is denied.\n10\n11\n12\n13\n14\n15 Defense 10. Expert testimony by law enforcement officers which the defense moves to exclude and the government has noticed intent to call three law enforcement officers as fact witnesses but not as experts. The government represents that it will not elicit expert testimony from any of them.\n16\n17\n18\n19\n20 So, the law enforcement officers can testify as fact witnesses to the facts that they personally perceived but not provide testimony that summarizes parts of the investigation which the officer did not personally experience and may not provide testimony that relies on specialized training and experience. The government's example of a law enforcement\n21\n22\n23\n24\n25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00007154",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 103 of 127",
+      "position": "header"
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+    {
+      "type": "printed",
+      "content": "LB15max4",
+      "position": "header"
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+    {
+      "type": "printed",
+      "content": "1 THE COURT: (Continuing)\n2 The government also correctly notes that the delay in time between the alleged misconduct and identification is not determinative because of the frequency of interactions between the alleged individual and Ms. Maxwell. Alleged Victim 4 was able to identify Ms. Maxwell when she got to the photo in the array with little hesitation. The argument that -- I will leave it at that.\n9 The defense requested an evidentiary hearing on this issue but I don't see facts put forward by the defense that puts, in genuine dispute, any facts that would support suppression of the identification so there would be nothing gained from an evidentiary rehearing, see United States v. Brown, 784 F. App'x 1 (2d Cir. 2019) so the request is denied.\n15 Defense 10. Expert testimony by law enforcement officers which the defense moves to exclude and the government has noticed intent to call three law enforcement officers as fact witnesses but not as experts. The government represents that it will not elicit expert testimony from any of them.\n20 So, the law enforcement officers can testify as fact witnesses to the facts that they personally perceived but not provide testimony that summarizes parts of the investigation which the officer did not personally experience and may not provide testimony that relies on specialized training and experience. The government's example of a law enforcement",
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+  "entities": {
+    "people": [
+      "Ms. Maxwell",
+      "Alleged Victim 4"
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+      "SOUTHERN DISTRICT REPORTERS, P.C."
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+      "1:20-cr-00330-PAE",
+      "Document 465",
+      "784 F. App'x 1",
+      "DOJ-OGR-00007154"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript with clear and legible text. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007155.json

@@ -0,0 +1,54 @@
+{
+  "document_metadata": {
+    "page_number": "104",
+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court transcript",
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+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 104 of 127 LB15max4 officer testifying as to what the officer himself found and participated in while executing a search seems to me permissible fact testimony. Anything to take up here from the defense, Ms. Menninger? MS. MENNINGER: No, your Honor. Thank you THE COURT: Ms. Moe? MS. MOE: No, your Honor. Thank you. THE COURT: Defense 11 is anticipated testimony regarding an alleged rape by Jeffrey Epstein. Let me ask the government to explain what it intends to do with respect to this and for what purpose the testimony would be sought to be introduced. MS. MOE: Certainly, your Honor. As a threshold matter, your Honor, I would note that there is an overlap here between the arguments in the defendant's motion in limine and the 412 motion. I think one motion seeks to introduce some of this evidence but characterize it as consensual and the other motion seeks to preclude it, reference it to be non-consensual. And so, I would be happy to address that now, but it may be easier to address that issue in the context of the 412 briefing. THE COURT: Counsel, do you agree? MR. EVERDELL: Your Honor, we can wait until the 412 briefing. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007155",
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+      "content": "LB15max4 officer testifying as to what the officer himself found and participated in while executing a search seems to me permissible fact testimony. Anything to take up here from the defense, Ms. Menninger? MS. MENNINGER: No, your Honor. Thank you THE COURT: Ms. Moe? MS. MOE: No, your Honor. Thank you. THE COURT: Defense 11 is anticipated testimony regarding an alleged rape by Jeffrey Epstein. Let me ask the government to explain what it intends to do with respect to this and for what purpose the testimony would be sought to be introduced. MS. MOE: Certainly, your Honor. As a threshold matter, your Honor, I would note that there is an overlap here between the arguments in the defendant's motion in limine and the 412 motion. I think one motion seeks to introduce some of this evidence but characterize it as consensual and the other motion seeks to preclude it, reference it to be non-consensual. And so, I would be happy to address that now, but it may be easier to address that issue in the context of the 412 briefing. THE COURT: Counsel, do you agree? MR. EVERDELL: Your Honor, we can wait until the 412 briefing.",
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+  "additional_notes": "The document appears to be a court transcript with clear and legible text. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007156.json

@@ -0,0 +1,58 @@
+{
+  "document_metadata": {
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+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court transcript",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 105 of 127 105 LB15max4\n\nTHE COURT: So to the extent there is overlap in these issues, it's best to take it up in the 412 proceeding so that we can discuss the issues without violating that rule.\n\nDefendant's 13. This is a motion to preclude the admission of several exhibits. I'm going to grant the motion with respect to Exhibit 251 and 288. Based on the briefing before me, 401 relevance is minimal, at best, and outweighed by 403 prejudice. 294, so some of the same questions around the authentication issue so I think that ruling holds. I won't otherwise preclude this evidence. It is potentially corroborative evidence of testimony and 403 prejudice does not rule out 401 but the defense can maintain the search and authentication issues that we have discussed.\n\nExhibit 403 I won't preclude, it's potentially probative of the relationship between the defendant and Mr. Epstein. The government proffers that it will corroborate and that the photo would corroborate anticipated witness testimony and I don't -- so, there is 401 relevance and not substantially outweighed by any 403 prejudice.\n\nOn this last one I may have said the wrong number. I had 403 on mine. So, Exhibit 313 is the photograph that I have indicated I am not excluding, it is potentially probative of the relationship between the defendant and Mr. Epstein and not outweighed by prejudice.\n\nAnd then 606, this is the issue on authentication and\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n\nDOJ-OGR-00007156",
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+      "content": "THE COURT: So to the extent there is overlap in these issues, it's best to take it up in the 412 proceeding so that we can discuss the issues without violating that rule.\n\nDefendant's 13. This is a motion to preclude the admission of several exhibits. I'm going to grant the motion with respect to Exhibit 251 and 288. Based on the briefing before me, 401 relevance is minimal, at best, and outweighed by 403 prejudice. 294, so some of the same questions around the authentication issue so I think that ruling holds. I won't otherwise preclude this evidence. It is potentially corroborative evidence of testimony and 403 prejudice does not rule out 401 but the defense can maintain the search and authentication issues that we have discussed.\n\nExhibit 403 I won't preclude, it's potentially probative of the relationship between the defendant and Mr. Epstein. The government proffers that it will corroborate and that the photo would corroborate anticipated witness testimony and I don't -- so, there is 401 relevance and not substantially outweighed by any 403 prejudice.\n\nOn this last one I may have said the wrong number. I had 403 on mine. So, Exhibit 313 is the photograph that I have indicated I am not excluding, it is potentially probative of the relationship between the defendant and Mr. Epstein and not outweighed by prejudice.\n\nAnd then 606, this is the issue on authentication and",
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+}

results/IMAGES003/DOJ-OGR-00007157.json

@@ -0,0 +1,54 @@
+{
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+    "document_number": "465",
+    "date": "11/15/21",
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+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 106 of 127 106 LB15max4 hearsay grounds that I have already indicated I'm going to have the parties address further, correct? MR. PAGLIUCA: Yes, your Honor. THE COURT: All right. Any questions about any of those rulings? MS. MOE: Not from the government, your Honor. Thank you. MR. PAGLIUCA: No, your Honor. Thank you. THE COURT: And about the time frames I have set on the different pieces that I require briefing on after everybody has. And, you will get the transcript. MS. MOE: Understood, your Honor. Thank you. THE COURT: All right. With that, I think we can pick up some outstanding logistics issues and I will hear from counsel as to any issues they want to raise. So, we begin our questionnaire process on Thursday. The government -- my chambers will produce the copies as an original matter. The government will take the completed copies from the jury department -- the completed questionnaires with no identifying information and make copies for the defense and for the Court. My request is to give both a paper copy and an electronic copy. I think that will aid everybody's use of the document since we have got multiple people looking at them, and then of course return the originals to the Court. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007157",
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+      "content": "LB15max4 hearsay grounds that I have already indicated I'm going to have the parties address further, correct? MR. PAGLIUCA: Yes, your Honor. THE COURT: All right. Any questions about any of those rulings? MS. MOE: Not from the government, your Honor. Thank you. MR. PAGLIUCA: No, your Honor. Thank you. THE COURT: And about the time frames I have set on the different pieces that I require briefing on after everybody has. And, you will get the transcript. MS. MOE: Understood, your Honor. Thank you. THE COURT: All right. With that, I think we can pick up some outstanding logistics issues and I will hear from counsel as to any issues they want to raise. So, we begin our questionnaire process on Thursday. The government -- my chambers will produce the copies as an original matter. The government will take the completed copies from the jury department -- the completed questionnaires with no identifying information and make copies for the defense and for the Court. My request is to give both a paper copy and an electronic copy. I think that will aid everybody's use of the document since we have got multiple people looking at them, and then of course return the originals to the Court.",
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+  "additional_notes": "The document appears to be a court transcript with a clear and readable format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007158.json

@@ -0,0 +1,54 @@
+{
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+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 107 of 127 107 LB15max4\n\n1 Any questions from the government on its obligations there?\n2\n3 MS. MOE: No, your Honor. Thank you.\n4\n5 THE COURT: The video remarks, at our last conference, as we discussed, my plan is to video record the preliminary instructions to be played for each panel before the questionnaire. I sent the parties my script and there were no objections. I'm actually going to record that tomorrow. I just want, does either party request to see the video before it's played for the prospective jurors on Thursday? Obviously I'm going to record it exactly as stated in the script.\n6\n7 MS. MOE: No, your Honor.\n8\n9 MS. STERNHEIM: Judge, unless you are wearing some funky t-shirt, no.\n10\n11 THE COURT: It's just a robe. Thank you.\n12\n13 Just in thinking ahead to the voir dire process, I have preliminary instructions that I'm drafting that I will give to each panel before they are individually brought in for the voir dire. Thinking ahead again, just for time-saving purposes, what I propose is we do another video of that so that it is played for each panel -- there is a morning panel and afternoon panel. And the logistics of all of this is complicated. So, what I propose I will send out, again, my script, let me know if you have any comments or objections, and once we all agree I will record it so that the jury staff can\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00007158",
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+      "content": "1 Any questions from the government on its obligations there?\n2\n3 MS. MOE: No, your Honor. Thank you.\n4\n5 THE COURT: The video remarks, at our last conference, as we discussed, my plan is to video record the preliminary instructions to be played for each panel before the questionnaire. I sent the parties my script and there were no objections. I'm actually going to record that tomorrow. I just want, does either party request to see the video before it's played for the prospective jurors on Thursday? Obviously I'm going to record it exactly as stated in the script.\n6\n7 MS. MOE: No, your Honor.\n8\n9 MS. STERNHEIM: Judge, unless you are wearing some funky t-shirt, no.\n10\n11 THE COURT: It's just a robe. Thank you.\n12\n13 Just in thinking ahead to the voir dire process, I have preliminary instructions that I'm drafting that I will give to each panel before they are individually brought in for the voir dire. Thinking ahead again, just for time-saving purposes, what I propose is we do another video of that so that it is played for each panel -- there is a morning panel and afternoon panel. And the logistics of all of this is complicated. So, what I propose I will send out, again, my script, let me know if you have any comments or objections, and once we all agree I will record it so that the jury staff can",
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+  "additional_notes": "The document appears to be a court transcript with a clear and readable format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007159.json

@@ -0,0 +1,52 @@
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+    "date": "11/15/21",
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+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 108 of 127 108 LB15max4 just play it once each panel is assembled. Any concerns with that, Ms. Moe? MS. MOE: No, your Honor. Thank you. THE COURT: Ms. Sternheim? MS. STERNHEIM: No. THE COURT: I think what I am also going to do, we haven't talked through the specifics of the logistics of the voir dire days -- I think I did generally -- but we are going to have a morning panel, the jurors are going to come in to a courtroom which is sort of the holding courtroom. The preliminary instructions will be played and then we bring them in one at a time. The afternoon panel is going to assemble somewhere else so there is no overlap, they'll be played the instructions. Once we are finished with the morning panel, they'll be brought in and the like. We will do the individual voir dire, obviously if anyone is struck for cause following that they'll be excused. Those who are not struck for cause, what I propose is that we give them an instruction sheet that tells them where and when they're returning for the final stage of the process and remind them the basic instructions about media restrictions and the like just so they have that and they take it with them. Of course I would show you what I am thinking before we do it but that basic idea. I want to see if anybody has any concerns or SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007159",
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+      "type": "printed",
+      "content": "LB15max4 just play it once each panel is assembled. Any concerns with that, Ms. Moe? MS. MOE: No, your Honor. Thank you. THE COURT: Ms. Sternheim? MS. STERNHEIM: No. THE COURT: I think what I am also going to do, we haven't talked through the specifics of the logistics of the voir dire days -- I think I did generally -- but we are going to have a morning panel, the jurors are going to come in to a courtroom which is sort of the holding courtroom. The preliminary instructions will be played and then we bring them in one at a time. The afternoon panel is going to assemble somewhere else so there is no overlap, they'll be played the instructions. Once we are finished with the morning panel, they'll be brought in and the like. We will do the individual voir dire, obviously if anyone is struck for cause following that they'll be excused. Those who are not struck for cause, what I propose is that we give them an instruction sheet that tells them where and when they're returning for the final stage of the process and remind them the basic instructions about media restrictions and the like just so they have that and they take it with them. Of course I would show you what I am thinking before we do it but that basic idea. I want to see if anybody has any concerns or",
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+}

results/IMAGES003/DOJ-OGR-00007160.json

@@ -0,0 +1,55 @@
+{
+  "document_metadata": {
+    "page_number": "109",
+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court transcript",
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+    "has_stamps": false
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+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 109 of 127 109 LB15max4 objections. MS. MOE: No, your Honor. Thank you. MS. STERNHEIM: No objection. THE COURT: I do think once we do that, the non-struck jurors, with that information, can then be excused for the day and returning on -- and obviously I haven't indicated yet -- the 19th or the 29th, those instructions. But they don't need to sit around for the rest of the day while we do the other individuals. Any objections to that process, Ms. Moe? MS. MOE: No. Thank you. THE COURT: Ms. Sternheim? MS. STERNHEIM: No, thank you. THE COURT: There are logistical issues we are dealing with for bringing the full panel back for the exercised peremptories as well as setting up the courtroom with distancing issues which turns, to some extent, on the vaccine status of the individuals because we have different spacing requirements under the current protocols for the vaccinated versus unvaccinated. Now, the parties have proposed that I ask that question in voir dire and I rejected that because I don't think there is any proper basis for striking based on vaccination status. But what I would propose, in order to facilitate the Court's logistical process which is complicated, is that for our non-struck jurors, as we give them the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007160",
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+      "type": "printed",
+      "content": "LB15max4 objections. MS. MOE: No, your Honor. Thank you. MS. STERNHEIM: No objection. THE COURT: I do think once we do that, the non-struck jurors, with that information, can then be excused for the day and returning on -- and obviously I haven't indicated yet -- the 19th or the 29th, those instructions. But they don't need to sit around for the rest of the day while we do the other individuals. Any objections to that process, Ms. Moe? MS. MOE: No. Thank you. THE COURT: Ms. Sternheim? MS. STERNHEIM: No, thank you. THE COURT: There are logistical issues we are dealing with for bringing the full panel back for the exercised peremptories as well as setting up the courtroom with distancing issues which turns, to some extent, on the vaccine status of the individuals because we have different spacing requirements under the current protocols for the vaccinated versus unvaccinated. Now, the parties have proposed that I ask that question in voir dire and I rejected that because I don't think there is any proper basis for striking based on vaccination status. But what I would propose, in order to facilitate the Court's logistical process which is complicated, is that for our non-struck jurors, as we give them the",
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+}

results/IMAGES003/DOJ-OGR-00007161.json

@@ -0,0 +1,80 @@
+{
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+    "document_number": "465",
+    "date": "11/15/21",
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+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 110 of 127 110 LB15max4\n1 instruction, they're handed a sheet of paper which says write your juror number and check a box, vaccinated, not vaccinated, I don't want to say, and the Court gets that but not the parties. And that way we can set up the courtroom, we can figure out where we are going to put everybody for peremptories and the like.\n2\n3\n4\n5\n6\n7 Ms. Moe?\n8 MS. MOE: The government has no objection to that, your Honor.\n9\n10 MS. STERNHEIM: No objection.\n11\n12 THE COURT: I do think we are going to do the peremptories on the 29th, as I have indicated. We are still working through the logistics. This piece helps. As I said, there are pros and cons to both, but I think that the safest course for proceeding with a full jury is to bring them back on the 29th -- I will give you my final resolution as to that when I have it -- but my thinking is we are in the courtroom, all of us. The panel, approximately 50 to 60 people who I will bring back are in two other courtrooms because we can't get them all in one place, with a video, in which I ask some very preliminary questions: Does anybody need to change any answers and has anybody had media exposure, etc. Hands raised. If anybody does raise their hands, we will have staff in each of those rooms who we can bring in one at a time to deal with.\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25 And assuming not, or once we deal with that, that's our panel,\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00007161",
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+      "content": "MS. MOE: The government has no objection to that, your Honor.",
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+    {
+      "type": "printed",
+      "content": "MS. STERNHEIM: No objection.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "THE COURT: I do think we are going to do the peremptories on the 29th, as I have indicated. We are still working through the logistics. This piece helps. As I said, there are pros and cons to both, but I think that the safest course for proceeding with a full jury is to bring them back on the 29th -- I will give you my final resolution as to that when I have it -- but my thinking is we are in the courtroom, all of us. The panel, approximately 50 to 60 people who I will bring back are in two other courtrooms because we can't get them all in one place, with a video, in which I ask some very preliminary questions: Does anybody need to change any answers and has anybody had media exposure, etc. Hands raised. If anybody does raise their hands, we will have staff in each of those rooms who we can bring in one at a time to deal with.",
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+      "content": "And assuming not, or once we deal with that, that's our panel,",
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+      "position": "footer"
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+    ],
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+      "1:20-cr-00330-PAE",
+      "Document 465",
+      "DOJ-OGR-00007161"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript with a clear and readable format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007162.json

@@ -0,0 +1,54 @@
+{
+  "document_metadata": {
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+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court transcript",
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+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 111 of 127 111 LB15max4 the parties exercise the peremptories by list, and we are done. So, as I say, I am still working through the specific logistics of that but that's my thinking as to how we will do it. Any reactions, Ms. Moe? MS. MOE: No, your Honor. Thank you. THE COURT: Ms. Sternheim? MS. STERNHEIM: Yes. My only reaction is are we going to be able to see the jurors as they respond to the Court's questioning? THE COURT: So, I think what we can do is have staff in each of the courtrooms, I will ask my question, anyone who raises their hand will be brought in individually. If you would like to have someone in each of those rooms for the hand-raising, that's fine with me. MS. STERNHEIM: OK. THE COURT: We would be happy to do that. MS. STERNHEIM: Thank you. THE COURT: But because there are other trials being selected on the 29th we can't use the jury assembly room and, in any event, it would slow us down. So I think this is the way to go logistically but that's what it will entail for the exercised peremptories. MS. STERNHEIM: Thank you. THE COURT: One of the obstacles to the jury selection SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007162",
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+    {
+      "type": "printed",
+      "content": "LB15max4 the parties exercise the peremptories by list, and we are done. So, as I say, I am still working through the specific logistics of that but that's my thinking as to how we will do it. Any reactions, Ms. Moe? MS. MOE: No, your Honor. Thank you. THE COURT: Ms. Sternheim? MS. STERNHEIM: Yes. My only reaction is are we going to be able to see the jurors as they respond to the Court's questioning? THE COURT: So, I think what we can do is have staff in each of the courtrooms, I will ask my question, anyone who raises their hand will be brought in individually. If you would like to have someone in each of those rooms for the hand-raising, that's fine with me. MS. STERNHEIM: OK. THE COURT: We would be happy to do that. MS. STERNHEIM: Thank you. THE COURT: But because there are other trials being selected on the 29th we can't use the jury assembly room and, in any event, it would slow us down. So I think this is the way to go logistically but that's what it will entail for the exercised peremptories. MS. STERNHEIM: Thank you. THE COURT: One of the obstacles to the jury selection",
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+  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007163.json

@@ -0,0 +1,58 @@
+{
+  "document_metadata": {
+    "page_number": "112",
+    "document_number": "465",
+    "date": "11/15/21",
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+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 112 of 127 112 LB15max4 here is length of trial and the timing of trial. I would like the parties, in light of -- you have gotten some rulings, obviously not everything yet -- to think about whether what we include in the questionnaire is still the six-week time frame that we have indicated. And if it is, it is, but if there is any basis to suggest a lower estimate as the parties have continued preparing their cases and in light of any rulings, I would certainly be open to hearing it if we could safely put a shorter time frame in the questionnaire. Again, maybe we can't. So I just ask you to think about it and confer and put in a letter by November 2nd, on ECF, indicating whether the parties agree that there should be any different estimate to the trial length than what we have indicated in the current draft of the questionnaire. I recognize that may change after that but for jury selection purposes it won't help us if a few days later we decide that we could say four weeks instead of six weeks. So you will let me know and I will ask the parties to confer. You don't need to put in specific reasons, just if you can put in a joint submission as to the parties' best overall estimate of length of trial is to see if it can be realistically any shorter than what is in the questionnaire to help facilitate jury selection. That's what I have. I will hear from counsel any other issues. Ms. Moe? MS. MOE: Yes, your Honor; very briefly on two SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007163",
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+      "type": "printed",
+      "content": "LB15max4 here is length of trial and the timing of trial. I would like the parties, in light of -- you have gotten some rulings, obviously not everything yet -- to think about whether what we include in the questionnaire is still the six-week time frame that we have indicated. And if it is, it is, but if there is any basis to suggest a lower estimate as the parties have continued preparing their cases and in light of any rulings, I would certainly be open to hearing it if we could safely put a shorter time frame in the questionnaire. Again, maybe we can't. So I just ask you to think about it and confer and put in a letter by November 2nd, on ECF, indicating whether the parties agree that there should be any different estimate to the trial length than what we have indicated in the current draft of the questionnaire. I recognize that may change after that but for jury selection purposes it won't help us if a few days later we decide that we could say four weeks instead of six weeks. So you will let me know and I will ask the parties to confer. You don't need to put in specific reasons, just if you can put in a joint submission as to the parties' best overall estimate of length of trial is to see if it can be realistically any shorter than what is in the questionnaire to help facilitate jury selection. That's what I have. I will hear from counsel any other issues. Ms. Moe?",
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+      "content": "MS. MOE: Yes, your Honor; very briefly on two",
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+      "465",
+      "DOJ-OGR-00007163",
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+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript with a clear and readable format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007164.json

@@ -0,0 +1,76 @@
+{
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+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court transcript",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 113 of 127 113 LB15max4 administrative items. First, it is the practice in this district to place on the record at a final pretrial conference the status of plea discussions and so I just wanted to place on the record -- THE COURT: I guess I hadn't assumed this is our final pretrial conference and I do usually do that, but there is no point in not at least doing that now in case we don't get together again, which seems unlikely. But, go ahead. MS. MOE: Yes, your Honor; for that reason we wanted to place on the record that the government has not issued any plea offers to the defense and the defense has not requested any plea offers from the government, and we would respectfully request that the Court confer with the defendant that that is accurate. THE COURT: OK. Ms. Sternheim? MS. STERNHEIM: Do you want to hear from me? THE COURT: I will hear from you first and then I will ask Ms. Maxwell. MS. STERNHEIM: That is correct. We take the position that our client has not committed a crime so plea bargaining was not an issue. THE COURT: Ms. Maxwell, what Ms. Sternheim indicated is accurate and correct? THE DEFENDANT: I have not committed any crime and -- THE COURT: And what Ms. Sternheim indicated is SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007164",
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+      "type": "printed",
+      "content": "LB15max4 administrative items. First, it is the practice in this district to place on the record at a final pretrial conference the status of plea discussions and so I just wanted to place on the record --",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "THE COURT: I guess I hadn't assumed this is our final pretrial conference and I do usually do that, but there is no point in not at least doing that now in case we don't get together again, which seems unlikely. But, go ahead.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "MS. MOE: Yes, your Honor; for that reason we wanted to place on the record that the government has not issued any plea offers to the defense and the defense has not requested any plea offers from the government, and we would respectfully request that the Court confer with the defendant that that is accurate.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "THE COURT: OK. Ms. Sternheim? MS. STERNHEIM: Do you want to hear from me? THE COURT: I will hear from you first and then I will ask Ms. Maxwell. MS. STERNHEIM: That is correct. We take the position that our client has not committed a crime so plea bargaining was not an issue.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "THE COURT: Ms. Maxwell, what Ms. Sternheim indicated is accurate and correct? THE DEFENDANT: I have not committed any crime and -- THE COURT: And what Ms. Sternheim indicated is",
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+  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007165.json

@@ -0,0 +1,49 @@
+{
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+    "document_number": "465",
+    "date": "11/15/21",
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+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 114 of 127 114 LB15max4 accurate? THE DEFENDANT: Oh sorry. Yes, your Honor. THE COURT: Anything else on that, Ms. Moe? MS. MOE: No, your Honor. Thank you. Just with respect to the second administrative item, the government has received the Court's order related to the Daubert hearing. Because the defense's Daubert briefing was focused on the question of grooming it would be helpful to understand the scope of the hearing and, in particular, whether the Court would like the government to present evidence with respect to the full scope of the expert's findings and conclusions that were addressed in the motions or whether the hearing would be focused on the question of grooming. THE COURT: I guess I think it goes to each of the proffered opinions being offered -- MS. MOE: Thank you, your Honor. THE COURT: -- in part because of overlap in those issues. I don't know that it's obvious to me how to separate them out at this point. MS. MOE: Thank you, your Honor. It is very helpful to know in advance of the hearing. THE COURT: Ms. Sternheim, anything on that? MS. STERNHEIM: Yes, Judge. These, I guess you put them under the housekeeping category and I know tomorrow the government is to respond to a SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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+    {
+      "type": "printed",
+      "content": "LB15max4 accurate? THE DEFENDANT: Oh sorry. Yes, your Honor. THE COURT: Anything else on that, Ms. Moe? MS. MOE: No, your Honor. Thank you. Just with respect to the second administrative item, the government has received the Court's order related to the Daubert hearing. Because the defense's Daubert briefing was focused on the question of grooming it would be helpful to understand the scope of the hearing and, in particular, whether the Court would like the government to present evidence with respect to the full scope of the expert's findings and conclusions that were addressed in the motions or whether the hearing would be focused on the question of grooming. THE COURT: I guess I think it goes to each of the proffered opinions being offered -- MS. MOE: Thank you, your Honor. THE COURT: -- in part because of overlap in those issues. I don't know that it's obvious to me how to separate them out at this point. MS. MOE: Thank you, your Honor. It is very helpful to know in advance of the hearing. THE COURT: Ms. Sternheim, anything on that? MS. STERNHEIM: Yes, Judge. These, I guess you put them under the housekeeping category and I know tomorrow the government is to respond to a",
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+  "additional_notes": "The document appears to be a court transcript with a clear and readable format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007166.json

@@ -0,0 +1,59 @@
+{
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+    "date": "11/15/21",
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+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 115 of 127 115 LB15max4 letter that I raised concerning legal mail, but we still have the issue that Ms. Maxwell has not received trial-related discovery that is imperative for her to review to consult with counsel. It also has bearing on some of the issues -- THE COURT: What hasn't been received? MS. STERNHEIM: Recent disclosures that the government has made, she still has not received some of them. They're sent by the government to the MDC. THE COURT: Yes. But, specifically, what are you talking about? MS. STERNHEIM: 3500 material that we -- counsel received electronically the other day. THE COURT: And by the other day what do you mean, Ms. Sternheim? MS. STERNHEIM: It was Monday, Judge. She has still not received the production made by the government which I believe they send via federal express. THE COURT: So, Ms. Moe, the government made a 3500 production a week ago? MS. MOE: Your Honor, the government has been supplementing its 3500 productions on a rolling basis. I don't recall the exact date but we have been supplementing them and have made productions last week. THE COURT: And do you know why -- the representation is a production made a week ago has not made its way to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007166",
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+    {
+      "type": "printed",
+      "content": "LB15max4 letter that I raised concerning legal mail, but we still have the issue that Ms. Maxwell has not received trial-related discovery that is imperative for her to review to consult with counsel. It also has bearing on some of the issues -- THE COURT: What hasn't been received? MS. STERNHEIM: Recent disclosures that the government has made, she still has not received some of them. They're sent by the government to the MDC. THE COURT: Yes. But, specifically, what are you talking about? MS. STERNHEIM: 3500 material that we -- counsel received electronically the other day. THE COURT: And by the other day what do you mean, Ms. Sternheim? MS. STERNHEIM: It was Monday, Judge. She has still not received the production made by the government which I believe they send via federal express. THE COURT: So, Ms. Moe, the government made a 3500 production a week ago? MS. MOE: Your Honor, the government has been supplementing its 3500 productions on a rolling basis. I don't recall the exact date but we have been supplementing them and have made productions last week. THE COURT: And do you know why -- the representation is a production made a week ago has not made its way to",
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+  "additional_notes": "The document appears to be a court transcript with a clear and readable format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007167.json

@@ -0,0 +1,56 @@
+{
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+    "document_number": "465",
+    "date": "11/15/21",
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+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 116 of 127 116 LB15max4\n1 Ms. Maxwell. Do you know anything about that?\n2 MS. MOE: Your Honor if I could have one moment?\n3 THE COURT: Sure.\n4 MS. MOE: Thank you.\n5 (Counsel conferring)\n6 MS. MOE: Your Honor, I don't have particular information about the series of disclosures we made last week and whether or not they've been processed by the MDC but we will certainly be conferring with the MDC in connection with a response to the defense's letter on Friday. Our understanding is that, generally, that drives have been received by MDC, processed through their warehouse, picked up by legal counsel and produced to the defense in regular time frame. I can't speak to any particular package that was mailed last week because I am hearing about it now for the first time.\n16 THE COURT: Well, OK. You will include in your letter -- I mean, I think at this point a week is too long. I think the representation in the prior letter was one to two days for legal mail, maybe this is different because this is different?\n21 MS. MOE: I don't believe so, your Honor. Part of the reason why I want to look into this and confer with my colleague is we are not quite sure whether the date was Monday or Wednesday that we produced this material to the defense and we want to just double-check the mailing date to make sure we\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007167",
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+      "type": "printed",
+      "content": "1 Ms. Maxwell. Do you know anything about that?\n2 MS. MOE: Your Honor if I could have one moment?\n3 THE COURT: Sure.\n4 MS. MOE: Thank you.\n5 (Counsel conferring)\n6 MS. MOE: Your Honor, I don't have particular information about the series of disclosures we made last week and whether or not they've been processed by the MDC but we will certainly be conferring with the MDC in connection with a response to the defense's letter on Friday. Our understanding is that, generally, that drives have been received by MDC, processed through their warehouse, picked up by legal counsel and produced to the defense in regular time frame. I can't speak to any particular package that was mailed last week because I am hearing about it now for the first time.\n16 THE COURT: Well, OK. You will include in your letter -- I mean, I think at this point a week is too long. I think the representation in the prior letter was one to two days for legal mail, maybe this is different because this is different?\n21 MS. MOE: I don't believe so, your Honor. Part of the reason why I want to look into this and confer with my colleague is we are not quite sure whether the date was Monday or Wednesday that we produced this material to the defense and we want to just double-check the mailing date to make sure we",
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+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007168.json

@@ -0,0 +1,51 @@
+{
+  "document_metadata": {
+    "page_number": "117",
+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court transcript",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 117 of 127 117 LB15max4 have all our facts straight about the exact timeline. So I am happy to address that in the letter. THE COURT: Yes, do address that in the letter. Is there anything the government can do -- you know, there is going to be some time built in for the facilities screening process and it getting to the defendant. Obviously there are other individuals in the same situation pretrial, heading into trial, and there are a lot of inmates, but -- so you will address what's happening on the institution side in the letter. What can the government do to facilitate the process going forward? MS. MODE: Your Honor, we have been trying to produce materials as quickly as possible. We have been FedExing those materials promptly to the facility. When we do so, we notify the facility that, in particular, a disclosure for this defendant is in-bound to the facility so that legal counsel knows about it and can keep an eye out for it which I think is unusual but we are happy to continue to take that step in this case. My understanding is that materials have been received by the defendant at the facility. We will continue to check on that issue. I would note that our rolling productions are going to be frequent but also small as we continue to meet with witnesses and produce small amounts of rolling materials. I SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007168",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 117 of 127 117 LB15max4",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "have all our facts straight about the exact timeline. So I am happy to address that in the letter. THE COURT: Yes, do address that in the letter. Is there anything the government can do -- you know, there is going to be some time built in for the facilities screening process and it getting to the defendant. Obviously there are other individuals in the same situation pretrial, heading into trial, and there are a lot of inmates, but -- so you will address what's happening on the institution side in the letter. What can the government do to facilitate the process going forward? MS. MODE: Your Honor, we have been trying to produce materials as quickly as possible. We have been FedExing those materials promptly to the facility. When we do so, we notify the facility that, in particular, a disclosure for this defendant is in-bound to the facility so that legal counsel knows about it and can keep an eye out for it which I think is unusual but we are happy to continue to take that step in this case. My understanding is that materials have been received by the defendant at the facility. We will continue to check on that issue. I would note that our rolling productions are going to be frequent but also small as we continue to meet with witnesses and produce small amounts of rolling materials. I",
+      "position": "main content"
+    },
+    {
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+      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
+      "position": "footer"
+    },
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+      "type": "printed",
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+      "position": "footer"
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+  ],
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+      "MS. MODE"
+    ],
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+      "SOUTHERN DISTRICT REPORTERS, P.C."
+    ],
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+    "dates": [
+      "11/15/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 465",
+      "DOJ-OGR-00007168"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript with a clear and readable format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007169.json

@@ -0,0 +1,61 @@
+{
+  "document_metadata": {
+    "page_number": "118 of 127",
+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court transcript",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 118 of 127 118 LB15max4 think the defense is well equipped to print those materials and meet with the defendant in person about it as they have been doing. They can certainly discuss those documents in the video conferences that they're having with the defendant. Our understanding is that this defense team has a large amount of access to video conferencing sessions with this defendant and so when the defense receives those materials, they're certainly free to review those with the defendant in real-time in their sessions. And so, we are taking every step that we can to ensure that the defense and the defendant have those materials but we think those steps are all that is required here and certainly more than is necessary to make sure the defendant is apprised of those materials in anticipation of trial. THE COURT: As to the steps, if you have a new submission we are talking about newly produced 3500 material, limited volume; correct, Ms. Moe? MS. MOE: Yes, your Honor. THE COURT: And you are going to send that by FedEx -- so overnight -- to the facility in each instance, correct? MS. MOE: Yes, your Honor. THE COURT: And you alert BOP counsel, MDC Legal counsel that something is coming for Ms. Maxwell so they can be on alert. Do you get indication back from legal counsel that it's been received and delivered? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007169",
+  "text_blocks": [
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+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 118 of 127 118 LB15max4",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "think the defense is well equipped to print those materials and meet with the defendant in person about it as they have been doing. They can certainly discuss those documents in the video conferences that they're having with the defendant. Our understanding is that this defense team has a large amount of access to video conferencing sessions with this defendant and so when the defense receives those materials, they're certainly free to review those with the defendant in real-time in their sessions. And so, we are taking every step that we can to ensure that the defense and the defendant have those materials but we think those steps are all that is required here and certainly more than is necessary to make sure the defendant is apprised of those materials in anticipation of trial.",
+      "position": "main content"
+    },
+    {
+      "type": "printed",
+      "content": "THE COURT: As to the steps, if you have a new submission we are talking about newly produced 3500 material, limited volume; correct, Ms. Moe? MS. MOE: Yes, your Honor. THE COURT: And you are going to send that by FedEx -- so overnight -- to the facility in each instance, correct? MS. MOE: Yes, your Honor. THE COURT: And you alert BOP counsel, MDC Legal counsel that something is coming for Ms. Maxwell so they can be on alert. Do you get indication back from legal counsel that it's been received and delivered?",
+      "position": "main content"
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+      "position": "footer"
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+  ],
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+      "Ms. Moe",
+      "Ms. Maxwell"
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+      "MDC Legal",
+      "SOUTHERN DISTRICT REPORTERS, P.C.",
+      "FedEx"
+    ],
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+    "dates": [
+      "11/15/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 465",
+      "3500 material",
+      "DOJ-OGR-00007169"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage to the document."
+}

results/IMAGES003/DOJ-OGR-00007170.json

@@ -0,0 +1,67 @@
+{
+  "document_metadata": {
+    "page_number": "119",
+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court transcript",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 119 of 127 119 LB15max4 MS. MOE: No, your Honor. We have not been asking to do that mindful of their obligations towards all of the other inmates at the facility but we appreciate the steps they have taken to be responsive to our alerts and about the defense's requests. For example, in some instances I think the defense has been e-mailing legal counsel noting certain tracking numbers and asking them to check at the particular warehouse. So that process seems to be working. I don't think we can create a system where the defendant is receiving, in jail, on a 24-hour basis, all disclosures. I don't think that is practical but I think especially because, in some instances, we may be uploading to the defense through a file sharing program certain disclosures on one day and they may be meeting with the defendant in person the very next day, they certainly have the ability to talk about those materials with the defendant, to provide her with paper copies if they wish, and I think that is more than sufficient. THE COURT: Well, you are not suggesting that instead of government sending the materials to the facility and working with the facility to facilitate timely movement of the materials to Ms. Maxwell, are you? MS. MOE: Of course, your Honor. Our view is in combination of the fact that, in the short-term, the defense has the opportunity to talk to the defendant immediately about it if they wish to, and in longer SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007170",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 119 of 127 119",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "LB15max4",
+      "position": "margin"
+    },
+    {
+      "type": "printed",
+      "content": "MS. MOE: No, your Honor. We have not been asking to do that mindful of their obligations towards all of the other inmates at the facility but we appreciate the steps they have taken to be responsive to our alerts and about the defense's requests. For example, in some instances I think the defense has been e-mailing legal counsel noting certain tracking numbers and asking them to check at the particular warehouse. So that process seems to be working. I don't think we can create a system where the defendant is receiving, in jail, on a 24-hour basis, all disclosures. I don't think that is practical but I think especially because, in some instances, we may be uploading to the defense through a file sharing program certain disclosures on one day and they may be meeting with the defendant in person the very next day, they certainly have the ability to talk about those materials with the defendant, to provide her with paper copies if they wish, and I think that is more than sufficient.",
+      "position": "main content"
+    },
+    {
+      "type": "printed",
+      "content": "THE COURT: Well, you are not suggesting that instead of government sending the materials to the facility and working with the facility to facilitate timely movement of the materials to Ms. Maxwell, are you?",
+      "position": "main content"
+    },
+    {
+      "type": "printed",
+      "content": "MS. MOE: Of course, your Honor. Our view is in combination of the fact that, in the short-term, the defense has the opportunity to talk to the defendant immediately about it if they wish to, and in longer",
+      "position": "main content"
+    },
+    {
+      "type": "printed",
+      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007170",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "MS. MOE",
+      "MS. MAXWELL"
+    ],
+    "organizations": [
+      "SOUTHERN DISTRICT REPORTERS, P.C."
+    ],
+    "locations": [],
+    "dates": [
+      "11/15/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 465",
+      "DOJ-OGR-00007170"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript with a clear and readable format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007171.json

@@ -0,0 +1,54 @@
+{
+  "document_metadata": {
+    "page_number": "120",
+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court transcript",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 120 of 127 120 LB15max4 term the defendant will have those materials in a reasonable time frame. I think in combination with those efforts, that's sufficient. THE COURT: So in your letter tomorrow you will indicate your understanding of the time frame including the specific 3500 material sent last week because, again, the representation I have is that you sent it to the defense on Monday and we are here a week later and Ms. Maxwell hasn't received it. You will find out what the story is with that and inquire as to whether there are any additional steps that can be taken in light of where we are in advance of trial to further facilitate the speedy transmission of the materials to Ms. Maxwell. MS. MOE: Yes, your Honor. THE COURT: Ms. Sternheim? MS. STERNHEIM: Judge, the procedure is such that even if I were to hand-deliver it myself she would not get it. If the government hand delivers it, she will get it. And we have requested that if they are going to do late-breaking disclosures, given that we are within weeks now of trial, that it be hand-delivered with a call to the MDC legal department to facilitate that. I can't just give her papers. As the Court well knows, even when I put them in the legal mail box, there is an issue as to when she gets that. And I know the government will SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007171",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 120 of 127 120",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "LB15max4 term the defendant will have those materials in a reasonable time frame. I think in combination with those efforts, that's sufficient. THE COURT: So in your letter tomorrow you will indicate your understanding of the time frame including the specific 3500 material sent last week because, again, the representation I have is that you sent it to the defense on Monday and we are here a week later and Ms. Maxwell hasn't received it. You will find out what the story is with that and inquire as to whether there are any additional steps that can be taken in light of where we are in advance of trial to further facilitate the speedy transmission of the materials to Ms. Maxwell. MS. MOE: Yes, your Honor. THE COURT: Ms. Sternheim? MS. STERNHEIM: Judge, the procedure is such that even if I were to hand-deliver it myself she would not get it. If the government hand delivers it, she will get it. And we have requested that if they are going to do late-breaking disclosures, given that we are within weeks now of trial, that it be hand-delivered with a call to the MDC legal department to facilitate that. I can't just give her papers. As the Court well knows, even when I put them in the legal mail box, there is an issue as to when she gets that. And I know the government will",
+      "position": "main"
+    },
+    {
+      "type": "printed",
+      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
+      "position": "footer"
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+      "content": "DOJ-OGR-00007171",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Ms. Maxwell",
+      "Ms. Moe",
+      "Ms. Sternheim"
+    ],
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+      "SOUTHERN DISTRICT REPORTERS, P.C.",
+      "MDC legal department"
+    ],
+    "locations": [],
+    "dates": [
+      "11/15/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 465",
+      "DOJ-OGR-00007171"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007172.json

@@ -0,0 +1,48 @@
+{
+  "document_metadata": {
+    "page_number": "121",
+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court transcript",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 121 of 127 121 LB15max4 respond to those issues tomorrow. But this is an issue -- and I will give the government the benefit of the doubt -- they do not know what we do when we have a conference with Ms. Maxwell so to assume what we are doing is erroneous. But, I will complete that topic and move on to another one. THE COURT: I want to understand the specific suggestion. So, presumably now, on a daily basis, the government may be meeting with witnesses and taking notes. I mean, I get those notes, an additional 3500 material during trial, it is one or two pages of chicken scratch, handwriting. So your proposal is that every day that one of those is produced it's hand delivered to the MDC by government staff? MS. STERNHEIM: That would be ideal but I'm not asking that and I don't think it comes that way, I think it comes more in these clumps. I'm not asking for every single page to be hand-delivered but if they know they are making a substantial production, that should be hand-delivered. THE COURT: And what do you mean by substantial? Over a hundred pages? What are we talking about? MS. STERNHEIM: Look. You know, it is not the quantity, it is what is in it that may have significance here. THE COURT: Ms. Sternheim, you have to be realistic on this. MS. STERNHEIM: I'm trying to be. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 121 of 127 121 LB15max4",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "respond to those issues tomorrow. But this is an issue -- and I will give the government the benefit of the doubt -- they do not know what we do when we have a conference with Ms. Maxwell so to assume what we are doing is erroneous. But, I will complete that topic and move on to another one. THE COURT: I want to understand the specific suggestion. So, presumably now, on a daily basis, the government may be meeting with witnesses and taking notes. I mean, I get those notes, an additional 3500 material during trial, it is one or two pages of chicken scratch, handwriting. So your proposal is that every day that one of those is produced it's hand delivered to the MDC by government staff? MS. STERNHEIM: That would be ideal but I'm not asking that and I don't think it comes that way, I think it comes more in these clumps. I'm not asking for every single page to be hand-delivered but if they know they are making a substantial production, that should be hand-delivered. THE COURT: And what do you mean by substantial? Over a hundred pages? What are we talking about? MS. STERNHEIM: Look. You know, it is not the quantity, it is what is in it that may have significance here. THE COURT: Ms. Sternheim, you have to be realistic on this. MS. STERNHEIM: I'm trying to be.",
+      "position": "main content"
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+      "type": "printed",
+      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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+      "Ms. Maxwell",
+      "Ms. Sternheim"
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+      "SOUTHERN DISTRICT REPORTERS, P.C.",
+      "MDC"
+    ],
+    "locations": [],
+    "dates": [
+      "11/15/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 465",
+      "Page 121 of 127"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript with a clear and readable format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007173.json

@@ -0,0 +1,54 @@
+{
+  "document_metadata": {
+    "page_number": "122 of 127",
+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court transcript",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 122 of 127 122 LB15max4\n\n1 THE COURT: I mean, you have made a lot of this noise\n2 about not having received it, not having received it in time.\n3 I am asking for a specific request that's realistic.\n4 MS. STERNHEIM: Every day I would like whatever\n5 they're producing to be hand-delivered.\n6 THE COURT: Well, I deny that request.\n7 MS. STERNHEIM: I understand that. That's why I\n8 didn't raise it but I think there needs to be some mechanism\n9 either if a FedEx comes to the facility that it be\n10 speed-delivered to Ms. Maxwell. Boxes of legal materials that\n11 have been sent to her, when we follow the tracking, they are\n12 left in a facility, they're not being picked up.\n13 I am not privy to what the mail operation is there.\n14 Perhaps the government can get some insight.\n15 THE COURT: When you say they're not being picked up\n16 you are saying that there are some that she has never received?\n17 You are saying she is not receiving it in the one to two to\n18 three-day time frame that you are asking for.\n19 MS. STERNHEIM: I submitted a letter to the Court the\n20 other day. In it there were four indications of items that\n21 were available for pickup. When I alerted the MDC to that,\n22 after the second request on Friday, they sent me back\n23 something, We are going to go pick them up. I shouldn't have\n24 to push them to go to the post office. I can't deliver the\n25 stuff myself because it's not going to be given to her. So you\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n\nDOJ-OGR-00007173",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 122 of 127 122 LB15max4",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "THE COURT: I mean, you have made a lot of this noise about not having received it, not having received it in time. I am asking for a specific request that's realistic. MS. STERNHEIM: Every day I would like whatever they're producing to be hand-delivered. THE COURT: Well, I deny that request. MS. STERNHEIM: I understand that. That's why I didn't raise it but I think there needs to be some mechanism either if a FedEx comes to the facility that it be speed-delivered to Ms. Maxwell. Boxes of legal materials that have been sent to her, when we follow the tracking, they are left in a facility, they're not being picked up. I am not privy to what the mail operation is there. Perhaps the government can get some insight. THE COURT: When you say they're not being picked up you are saying that there are some that she has never received? You are saying she is not receiving it in the one to two to three-day time frame that you are asking for. MS. STERNHEIM: I submitted a letter to the Court the other day. In it there were four indications of items that were available for pickup. When I alerted the MDC to that, after the second request on Friday, they sent me back something, We are going to go pick them up. I shouldn't have to push them to go to the post office. I can't deliver the stuff myself because it's not going to be given to her. So you",
+      "position": "main content"
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+    {
+      "type": "printed",
+      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
+      "position": "footer"
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+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007173",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Ms. Sternheim",
+      "Ms. Maxwell"
+    ],
+    "organizations": [
+      "SOUTHERN DISTRICT REPORTERS, P.C.",
+      "MDC"
+    ],
+    "locations": [],
+    "dates": [
+      "11/15/21",
+      "Friday"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 465",
+      "DOJ-OGR-00007173"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript with a clear and readable format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007174.json

@@ -0,0 +1,49 @@
+{
+  "document_metadata": {
+    "page_number": "123",
+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court transcript",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 123 of 127 123 LB15max4\ndo it through the United States post office, I don't know what the situation is how the MDC receives its packages, but if the tracking information says available for pick up and days go by and it's not picked up, what am I to do to put a candle under the MDC to get those packages?\nTHE COURT: I guess I'm still trying to understand what it is that you are asking the Court to do.\nMS. STERNHEIM: I'm asking the Court to have the MDC retrieve its mail in a timely manner. I will notify them if a next-day delivery is on the way, and that it be picked up for next-day and not languish in the post office.\nTHE COURT: Ms. Moe?\nMS. MOE: Your Honor, we will confer with MDC legal about this issue and their practices and happy to provide the Court with additional information about our disclosures last week and the ongoing practices.\nI can't speak to the particular mail sorting practices of the MDC, but I want to assure the Court we have been working diligently with the defense and with MDC legal on this issue and have been taking extraordinary efforts to make sure the disclosures are produced promptly and that they're sent to the defendant quickly and we will continue to do so. And if we learn of a practical way of expediting this, we would certainly be open to exploring that but that's all the information that I have at this point.\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007174",
+  "text_blocks": [
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+      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 123 of 127 123 LB15max4",
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+    {
+      "type": "printed",
+      "content": "do it through the United States post office, I don't know what the situation is how the MDC receives its packages, but if the tracking information says available for pick up and days go by and it's not picked up, what am I to do to put a candle under the MDC to get those packages?\nTHE COURT: I guess I'm still trying to understand what it is that you are asking the Court to do.\nMS. STERNHEIM: I'm asking the Court to have the MDC retrieve its mail in a timely manner. I will notify them if a next-day delivery is on the way, and that it be picked up for next-day and not languish in the post office.\nTHE COURT: Ms. Moe?\nMS. MOE: Your Honor, we will confer with MDC legal about this issue and their practices and happy to provide the Court with additional information about our disclosures last week and the ongoing practices.\nI can't speak to the particular mail sorting practices of the MDC, but I want to assure the Court we have been working diligently with the defense and with MDC legal on this issue and have been taking extraordinary efforts to make sure the disclosures are produced promptly and that they're sent to the defendant quickly and we will continue to do so. And if we learn of a practical way of expediting this, we would certainly be open to exploring that but that's all the information that I have at this point.",
+      "position": "main content"
+    },
+    {
+      "type": "printed",
+      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007174",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "MS. STERNHEIM",
+      "MS. MOE"
+    ],
+    "organizations": [
+      "United States post office",
+      "MDC",
+      "SOUTHERN DISTRICT REPORTERS, P.C."
+    ],
+    "locations": [],
+    "dates": [
+      "11/15/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 465",
+      "DOJ-OGR-00007174"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007175.json

@@ -0,0 +1,53 @@
+{
+  "document_metadata": {
+    "page_number": "124",
+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court transcript",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 124 of 127 124 LB15max4\n\n1 THE COURT: Thank you.\n2 Can I ask the government, if you have a substantial\n3 production, let's say over 50 pages of documents to review, can\n4 the government have those hand-delivered to the facility?\n5 MS. MOE: No, your Honor.\n6 Respectfully, that is extremely resource intensive, it\n7 requires asking either a member of the prosecution team or\n8 their colleagues who are also working on cases to, instead of\n9 pursuing law enforcement activities or preparing for trial,\n10 spend the day driving to the MDC to hand deliver a drive to the\n11 defendant personally which is a remedy that I'm not aware of\n12 being implemented in any other case and would be sort of an\n13 extraordinary step for this defendant that would be out of step\n14 with the ordinary practice.\n15 THE COURT: We are a month away from trial but if we\n16 are a few days away from trial and suddenly the government has\n17 a substantial production of material for some reason, 50 pages,\n18 a hundred pages, would the government take those steps?\n19 MS. MOE: Your Honor, without having a sense of what\n20 those materials are, what their sensitivities are, whether it\n21 is sort of a relevant matter that we are producing in an\n22 abundance of caution or something that is sensitive that is\n23 urgent that is hard to troubleshoot that issue in advance but\n24 we are mindful of Court's concern and that, even as we approach\n25 trial, that the issue of timing is of particular concern and so\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00007175",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 124 of 127 124 LB15max4",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "1 THE COURT: Thank you.\n2 Can I ask the government, if you have a substantial\n3 production, let's say over 50 pages of documents to review, can\n4 the government have those hand-delivered to the facility?\n5 MS. MOE: No, your Honor.\n6 Respectfully, that is extremely resource intensive, it\n7 requires asking either a member of the prosecution team or\n8 their colleagues who are also working on cases to, instead of\n9 pursuing law enforcement activities or preparing for trial,\n10 spend the day driving to the MDC to hand deliver a drive to the\n11 defendant personally which is a remedy that I'm not aware of\n12 being implemented in any other case and would be sort of an\n13 extraordinary step for this defendant that would be out of step\n14 with the ordinary practice.\n15 THE COURT: We are a month away from trial but if we\n16 are a few days away from trial and suddenly the government has\n17 a substantial production of material for some reason, 50 pages,\n18 a hundred pages, would the government take those steps?\n19 MS. MOE: Your Honor, without having a sense of what\n20 those materials are, what their sensitivities are, whether it\n21 is sort of a relevant matter that we are producing in an\n22 abundance of caution or something that is sensitive that is\n23 urgent that is hard to troubleshoot that issue in advance but\n24 we are mindful of Court's concern and that, even as we approach\n25 trial, that the issue of timing is of particular concern and so",
+      "position": "main content"
+    },
+    {
+      "type": "printed",
+      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
+      "position": "footer"
+    },
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+      "type": "printed",
+      "content": "DOJ-OGR-00007175",
+      "position": "footer"
+    }
+  ],
+  "entities": {
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+      "MS. MOE"
+    ],
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+    ],
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+      "MDC"
+    ],
+    "dates": [
+      "11/15/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 465",
+      "DOJ-OGR-00007175"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007176.json

@@ -0,0 +1,55 @@
+{
+  "document_metadata": {
+    "page_number": "125 of 127",
+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court transcript",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 125 of 127 125 LB15max4\n1 would be attentive to that issue in those circumstances but I think it is difficult assess that in a hypothetical.\n2\n3 THE COURT: OK. I will wait for the government's letter.\n4\n5 Ms. Sternheim.\n6 MS. STERNHEIM: One other issue, Judge; it has to do going forward with the production of Ms. Maxwell to the court house.\n7\n8 She is woken up at approximately 3:45. She is taken here and this morning she arrived at 5:38. She sits in a cellblock, very cold, she cannot bring any warmer garments.\n9\n10 She is not allowed to look at her legal materials. She is given very little food and whatever she is given doesn't even have a utensil for her to use. And, she is shackled. Today she had to get on her hands and knees to climb into the van because her leg shackles would not permit her to step up. This is just not the right thing. The wear and tear on her going forward to trial five days a week --\n11\n12 THE COURT: What is the application, Ms. Sternheim?\n13\n14 MS. STERNHEIM: The application is for her to be brought here later. The real application, obviously, is for her to be let out on bail but I'm not going to make that application right here, I will make it in writing, but these conditions are just terrible. And today, when she was nodding out, she was poked to be woken up just because she's the only\n15\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007176",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 125 of 127 125 LB15max4",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "1 would be attentive to that issue in those circumstances but I think it is difficult assess that in a hypothetical.\n2\n3 THE COURT: OK. I will wait for the government's letter.\n4\n5 Ms. Sternheim.\n6 MS. STERNHEIM: One other issue, Judge; it has to do going forward with the production of Ms. Maxwell to the court house.\n7\n8 She is woken up at approximately 3:45. She is taken here and this morning she arrived at 5:38. She sits in a cellblock, very cold, she cannot bring any warmer garments.\n9\n10 She is not allowed to look at her legal materials. She is given very little food and whatever she is given doesn't even have a utensil for her to use. And, she is shackled. Today she had to get on her hands and knees to climb into the van because her leg shackles would not permit her to step up. This is just not the right thing. The wear and tear on her going forward to trial five days a week --\n11\n12 THE COURT: What is the application, Ms. Sternheim?\n13\n14 MS. STERNHEIM: The application is for her to be brought here later. The real application, obviously, is for her to be let out on bail but I'm not going to make that application right here, I will make it in writing, but these conditions are just terrible. And today, when she was nodding out, she was poked to be woken up just because she's the only\n15",
+      "position": "main content"
+    },
+    {
+      "type": "printed",
+      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007176",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Ms. Sternheim",
+      "Ms. Maxwell",
+      "Judge"
+    ],
+    "organizations": [
+      "SOUTHERN DISTRICT REPORTERS, P.C."
+    ],
+    "locations": [
+      "court house"
+    ],
+    "dates": [
+      "11/15/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 465",
+      "DOJ-OGR-00007176"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007177.json

@@ -0,0 +1,56 @@
+{
+  "document_metadata": {
+    "page_number": "126 of 127",
+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court transcript",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 126 of 127 126 LB15max4\n1 person sitting in a cell. That's not necessary.\n2 Nutrition is important, sleep is important. We all\n3 are going to be fatigued but we all get to go home, and\n4 something needs to be done to ensure that she is not\n5 debilitated during the trial.\n6 THE COURT: Are you making any allegations of\n7 differential treatment as to Ms. Maxwell?\n8 MS. STERNHEIM: Yes. I don't know any other client I\n9 have ever had who has been woken up every 15 minutes at night\n10 and then --\n11 THE COURT: No, I'm talking about what you are talking\n12 about which is the transport to the court house for\n13 proceedings.\n14 MS. STERNHEIM: I don't know any clients who have ever\n15 arrived that early. I can't speak to that. They've never been\n16 taken individually as she has so I don't have a big history\n17 about that. In other cases that I have had in this court house\n18 either the clients come from the MCC, which is no longer here\n19 and they're transported one way, or when I come here in the\n20 morning for a court proceeding or trial, and I will get here at\n21 9:00, I'm told they haven't arrived yet. So, the differential\n22 between getting here at 5:38 and not being here at 9:00 for\n23 another defendant seems extraordinary.\n24 THE COURT: Ms. Moe?\n25 MS. MOE: Your Honor, the government is learning of\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00007177",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 126 of 127 126 LB15max4",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "1 person sitting in a cell. That's not necessary.\n2 Nutrition is important, sleep is important. We all\n3 are going to be fatigued but we all get to go home, and\n4 something needs to be done to ensure that she is not\n5 debilitated during the trial.\n6 THE COURT: Are you making any allegations of\n7 differential treatment as to Ms. Maxwell?\n8 MS. STERNHEIM: Yes. I don't know any other client I\n9 have ever had who has been woken up every 15 minutes at night\n10 and then --\n11 THE COURT: No, I'm talking about what you are talking\n12 about which is the transport to the court house for\n13 proceedings.\n14 MS. STERNHEIM: I don't know any clients who have ever\n15 arrived that early. I can't speak to that. They've never been\n16 taken individually as she has so I don't have a big history\n17 about that. In other cases that I have had in this court house\n18 either the clients come from the MCC, which is no longer here\n19 and they're transported one way, or when I come here in the\n20 morning for a court proceeding or trial, and I will get here at\n21 9:00, I'm told they haven't arrived yet. So, the differential\n22 between getting here at 5:38 and not being here at 9:00 for\n23 another defendant seems extraordinary.\n24 THE COURT: Ms. Moe?\n25 MS. MOE: Your Honor, the government is learning of",
+      "position": "main content"
+    },
+    {
+      "type": "printed",
+      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007177",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Ms. Maxwell",
+      "Ms. Sternheim",
+      "Ms. Moe"
+    ],
+    "organizations": [
+      "SOUTHERN DISTRICT REPORTERS, P.C."
+    ],
+    "locations": [
+      "MCC",
+      "court house"
+    ],
+    "dates": [
+      "11/15/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 465",
+      "DOJ-OGR-00007177"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007178.json

@@ -0,0 +1,102 @@
+{
+  "document_metadata": {
+    "page_number": "127",
+    "document_number": "465",
+    "date": "11/15/21",
+    "document_type": "court transcript",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 127 of 127 127 LB15max4\n1 this concern for the first time at this conference. I would be happy to reach out to both the MDC and the Deputy U.S. Marshal assigned to this particular trial to ask, as a general matter, what time they anticipate producing the defendant on trial days and can provide the defense with that information.\n2\n3\n4\n5\n6 THE COURT: Yes; and whether there is any differential treatment between Ms. Maxwell and other defendants being produced from the MDC to the court house under COVID protocols and currently. You will inquire as to that.\n7\n8\n9\n10 MS. MOE: Yes, your Honor.\n11\n12 THE COURT: As well as differential or not, what the timing issue is, availability of food and comfort items, as necessary, and the like.\n13\n14 MS. MOE: Certainly, your Honor.\n15\n16 THE COURT: Ms. Sternheim, anything further?\n17 MS. STERNHEIM: Thank you, Judge. No.\n18\n19 THE COURT: Anything, Ms. Moe?\n20 MS. MOE: No, your Honor. Thank you.\n21\n22 THE COURT: We are adjourned.\n23\n24 ooo\n25\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007178",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 127 of 127 127 LB15max4",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "this concern for the first time at this conference. I would be happy to reach out to both the MDC and the Deputy U.S. Marshal assigned to this particular trial to ask, as a general matter, what time they anticipate producing the defendant on trial days and can provide the defense with that information.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "THE COURT: Yes; and whether there is any differential treatment between Ms. Maxwell and other defendants being produced from the MDC to the court house under COVID protocols and currently. You will inquire as to that.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "MS. MOE: Yes, your Honor.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "THE COURT: As well as differential or not, what the timing issue is, availability of food and comfort items, as necessary, and the like.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "MS. MOE: Certainly, your Honor.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "THE COURT: Ms. Sternheim, anything further?",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "MS. STERNHEIM: Thank you, Judge. No.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "THE COURT: Anything, Ms. Moe?",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "MS. MOE: No, your Honor. Thank you.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "THE COURT: We are adjourned.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "ooo",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007178",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Ms. Maxwell",
+      "Ms. Moe",
+      "Ms. Sternheim"
+    ],
+    "organizations": [
+      "MDC",
+      "U.S. Marshal",
+      "SOUTHERN DISTRICT REPORTERS, P.C."
+    ],
+    "locations": [
+      "court house"
+    ],
+    "dates": [
+      "11/15/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 465",
+      "DOJ-OGR-00007178"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007179.json

@@ -0,0 +1,98 @@
+{
+  "document_metadata": {
+    "page_number": "1",
+    "document_number": "466",
+    "date": "11/15/21",
+    "document_type": "NOTICE OF FILING OF OFFICIAL TRANSCRIPT",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 466 Filed 11/15/21 Page 1 of 1\nIN THE UNITED STATES DISTRICT COURT\nFOR THE SOUTHERN DISTRICT OF NEW YORK\nUNITED STATES OF AMERICA,\nPlaintiff,\nv.\nGHISLAINE MAXWELL,\nDefendant.\nCase No.: 20 CR 330\nNOTICE OF FILING OF OFFICIAL TRANSCRIPT\nNotice is hereby given that an official transcript of a CONFERENCE held on 11/1/21 has been filed by the court reporter/transcriber in the above-captioned matter.\nRedaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting the transcript is a judge or a member of the public or media.\nThe parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically available to the public without redaction after ninety (90) calendar days.\nThis process may only be used to redact the following personal data identifiers: Social Security numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information may proceed by motion.\nI (we) certify that the foregoing is a correct transcript from the record of proceedings in the above-entitled matter.\nmcDaniel\nCourt Reporter/Transcriber\nDate\nDOJ-OGR-00007179",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 466 Filed 11/15/21 Page 1 of 1",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "IN THE UNITED STATES DISTRICT COURT\nFOR THE SOUTHERN DISTRICT OF NEW YORK",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "UNITED STATES OF AMERICA,\nPlaintiff,\nv.\nGHISLAINE MAXWELL,\nDefendant.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "Case No.: 20 CR 330",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "NOTICE OF FILING OF OFFICIAL TRANSCRIPT",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Notice is hereby given that an official transcript of a CONFERENCE held on 11/1/21 has been filed by the court reporter/transcriber in the above-captioned matter.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting the transcript is a judge or a member of the public or media.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically available to the public without redaction after ninety (90) calendar days.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "This process may only be used to redact the following personal data identifiers: Social Security numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information may proceed by motion.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "I (we) certify that the foregoing is a correct transcript from the record of proceedings in the above-entitled matter.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "mcDaniel\nCourt Reporter/Transcriber\nDate",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007179",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "GHISLAINE MAXWELL",
+      "mcDaniel"
+    ],
+    "organizations": [
+      "UNITED STATES OF AMERICA",
+      "UNITED STATES DISTRICT COURT",
+      "SOUTHERN DISTRICT OF NEW YORK"
+    ],
+    "locations": [
+      "NEW YORK"
+    ],
+    "dates": [
+      "11/15/21",
+      "11/1/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 466",
+      "20 CR 330",
+      "DOJ-OGR-00007179"
+    ]
+  },
+  "additional_notes": "The document appears to be a formal court filing with no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007180.json

@@ -0,0 +1,75 @@
+{
+  "document_metadata": {
+    "page_number": "1",
+    "document_number": "467",
+    "date": "11/15/21",
+    "document_type": "Court Document",
+    "has_handwriting": false,
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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 1 of 158 1 LBAAMAX1ps UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -------------------------------x UNITED STATES OF AMERICA, v. 20-cr-330 (AJN) GHISLAINE MAXWELL, Defendant. Hearing -------------------------------x New York, N.Y. November 10, 2021 9:20 a.m. Before: HON. ALISON J. NATHAN District Judge APPEARANCES DAMIAN WILLIAMS United States Attorney for the Southern District of New York BY: MAURENE COMEY ALISON MOE LARA POMERANTZ ANDREW ROHRBACH Assistant United States Attorneys HADDON MORGAN AND FOREMAN Attorneys for Defendant BY: JEFFREY S. PAGLIUCA CHRISTIAN R. EVERDELL LAURA A. MENNINGER -and- Bobbi C. Sternheim Attorney for Defendant Also Present: Sarah Drescher Paralegal, U.S. Attorney's Office Camille Delgado Paralegal, Haddon Morgan and Foreman SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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+      "content": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -------------------------------x UNITED STATES OF AMERICA, v. 20-cr-330 (AJN) GHISLAINE MAXWELL, Defendant. Hearing -------------------------------x New York, N.Y. November 10, 2021 9:20 a.m. Before: HON. ALISON J. NATHAN District Judge APPEARANCES",
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+      "content": "DAMIAN WILLIAMS United States Attorney for the Southern District of New York BY: MAURENE COMEY ALISON MOE LARA POMERANTZ ANDREW ROHRBACH Assistant United States Attorneys HADDON MORGAN AND FOREMAN Attorneys for Defendant BY: JEFFREY S. PAGLIUCA CHRISTIAN R. EVERDELL LAURA A. MENNINGER -and- Bobbi C. Sternheim Attorney for Defendant",
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+    },
+    {
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+      "content": "Also Present: Sarah Drescher Paralegal, U.S. Attorney's Office Camille Delgado Paralegal, Haddon Morgan and Foreman",
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+      "1:20-cr-00330-PAE",
+      "Document 467",
+      "20-cr-330 (AJN)"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript from a hearing in the United States District Court for the Southern District of New York. The document is well-formatted and legible, with no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007181.json

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+{
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+    "document_number": "467",
+    "date": "11/15/21",
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+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 2 of 158 2 LBAAMAX1ps\n\n(Case called)\n\nTHE CLERK: Counsel, please state your name for the record, starting with the government.\n\nMS. POMERANTZ: Good morning, your Honor. Lara Pomerantz, Andrew Rohrbach, Alison Moe, and Maureen Comey for the government.\n\nTHE COURT: Good morning.\n\nFor the defendant.\n\nMS. STERNHEIM: Good morning, Judge. Bobbi C. Sternheim appearing with Ghislaine Maxwell at counsel table, along with Jeffery Pagliuca, Laura Menninger, Christian Everdell. And we're assisted by Camille Delgado.\n\nTHE COURT: Good morning, everyone. Thank you. Please be seated.\n\nAll right. We are here for a number of things. Let me just get myself organized.\n\nThis is a pretrial conference. Our jury selection process began on November 4th with the questionnaires, trial to commence on November 29th.\n\nToday, we will address the defendant's motion under Federal Rule of Evidence 412, the defendant's motion in limine to exclude under Federal Rule of Evidence 702 and Daubert, and the other outstanding issues that overlap with these motions, as we discussed at our last conference on November 1st.\n\nJust for clarity, I explained this in my order\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n\nDOJ-OGR-00007181",
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+      "content": "(Case called)\n\nTHE CLERK: Counsel, please state your name for the record, starting with the government.\n\nMS. POMERANTZ: Good morning, your Honor. Lara Pomerantz, Andrew Rohrbach, Alison Moe, and Maureen Comey for the government.\n\nTHE COURT: Good morning.\n\nFor the defendant.\n\nMS. STERNHEIM: Good morning, Judge. Bobbi C. Sternheim appearing with Ghislaine Maxwell at counsel table, along with Jeffery Pagliuca, Laura Menninger, Christian Everdell. And we're assisted by Camille Delgado.\n\nTHE COURT: Good morning, everyone. Thank you. Please be seated.\n\nAll right. We are here for a number of things. Let me just get myself organized.\n\nThis is a pretrial conference. Our jury selection process began on November 4th with the questionnaires, trial to commence on November 29th.\n\nToday, we will address the defendant's motion under Federal Rule of Evidence 412, the defendant's motion in limine to exclude under Federal Rule of Evidence 702 and Daubert, and the other outstanding issues that overlap with these motions, as we discussed at our last conference on November 1st.\n\nJust for clarity, I explained this in my order",
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+      "Document 467",
+      "DOJ-OGR-00007181"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript with clear and legible text. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007182.json

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+{
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+    "page_number": "3",
+    "document_number": "467",
+    "date": "11/15/21",
+    "document_type": "court transcript",
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+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 3 of 158 3 LBAAMAX1ps regarding public access yesterday: The 412 piece of these proceedings will be sealed, as is expressly required by Federal Rule of Evidence 412. That rule requires certain categories of evidence to be discussed at a sealed, in camera hearing. My plan is to hold that part of the hearing last, do what we need to do with respect to logistical issues and Daubert here first, and then seal the courtroom, having everyone who is a nonparticipant leave and shutting down the overflow access at that point, as required by law. Given this, I want to address a few logistical issues at the outset, and then we'll move into Daubert. I should say, to the extent we run into any overlap during the Daubert hearing on any 412 issues, we have arranged space to do the equivalent of a sealed sidebar in the jury room, I believe. But, again, we can bifurcate. OK. Before I turn to the logistical issues, any matters I should take up with what I have indicated, Ms. Pomerantz? MS. POMERANTZ: Not from the government. Thank you. THE COURT: Ms. Sternheim? MS. STERNHEIM: No. Thank you. THE COURT: OK. First, on logistics, as you know, counsel, we had a very successful return rate on the jury summons, and in the two days that the questionnaire has been filled out we had 565 prospective jurors fill it out. Given SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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+    {
+      "type": "printed",
+      "content": "regarding public access yesterday: The 412 piece of these proceedings will be sealed, as is expressly required by Federal Rule of Evidence 412. That rule requires certain categories of evidence to be discussed at a sealed, in camera hearing. My plan is to hold that part of the hearing last, do what we need to do with respect to logistical issues and Daubert here first, and then seal the courtroom, having everyone who is a nonparticipant leave and shutting down the overflow access at that point, as required by law. Given this, I want to address a few logistical issues at the outset, and then we'll move into Daubert. I should say, to the extent we run into any overlap during the Daubert hearing on any 412 issues, we have arranged space to do the equivalent of a sealed sidebar in the jury room, I believe. But, again, we can bifurcate. OK. Before I turn to the logistical issues, any matters I should take up with what I have indicated, Ms. Pomerantz? MS. POMERANTZ: Not from the government. Thank you. THE COURT: Ms. Sternheim? MS. STERNHEIM: No. Thank you. THE COURT: OK. First, on logistics, as you know, counsel, we had a very successful return rate on the jury summons, and in the two days that the questionnaire has been filled out we had 565 prospective jurors fill it out. Given",
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+  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007183.json

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+{
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+    "page_number": "4",
+    "document_number": "467",
+    "date": "11/15/21",
+    "document_type": "court transcript",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 4 of 158 4 LBAAMAX1ps that, my plan is to just do the morning session on Friday, which would give us about another hundred or so people filling out the questionnaire, which is what the target was in the 6 to 7 hundred range, presumably about 650 or so. And that will give additional time for the parties to confer after they have reviewed and a fewer number of questionnaires to review, given that we got there sooner. Any concerns with that, Ms. Pomerantz? MS. POMERANTZ: No. Thank you, your Honor. THE COURT: Ms. Sternheim? MS. STERNHEIM: No. THE COURT: Great. Thank you. I did previously set a tentative hearing for November 15th, which is Monday, at 9:30. So that's firm. We'll have that hearing, to the extent we need to, to go over any pre voir dire process resolution of disputed questionnaires and the like if we need to, and talk about that process more. I'll also use it to address any outstanding motions in limine if I can. In particular I think I will then have full briefing, and hopefully be able to address defense motion 1, on co-conspirator statements; defense motion 4, regarding alleged victim 3; and defense motion 7, on Exhibit 52. If I'm able to, I'll also address the government's motions regarding exclusion of at least some testimony of Dr. Loftus and Dr. Dietz. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007183",
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+      "content": "that, my plan is to just do the morning session on Friday, which would give us about another hundred or so people filling out the questionnaire, which is what the target was in the 6 to 7 hundred range, presumably about 650 or so. And that will give additional time for the parties to confer after they have reviewed and a fewer number of questionnaires to review, given that we got there sooner. Any concerns with that, Ms. Pomerantz? MS. POMERANTZ: No. Thank you, your Honor. THE COURT: Ms. Sternheim? MS. STERNHEIM: No. THE COURT: Great. Thank you. I did previously set a tentative hearing for November 15th, which is Monday, at 9:30. So that's firm. We'll have that hearing, to the extent we need to, to go over any pre voir dire process resolution of disputed questionnaires and the like if we need to, and talk about that process more. I'll also use it to address any outstanding motions in limine if I can. In particular I think I will then have full briefing, and hopefully be able to address defense motion 1, on co-conspirator statements; defense motion 4, regarding alleged victim 3; and defense motion 7, on Exhibit 52. If I'm able to, I'll also address the government's motions regarding exclusion of at least some testimony of Dr. Loftus and Dr. Dietz.",
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+      "Document 467",
+      "Exhibit 52",
+      "DOJ-OGR-00007183"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage to the document."
+}

results/IMAGES003/DOJ-OGR-00007184.json

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+{
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+    "document_number": "467",
+    "date": "11/15/21",
+    "document_type": "court transcript",
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+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 5 of 158 5 LBAAMAX1ps\n1    And as I said, we'll discuss voir dire and take up questionnaire issues as needed.\n2    So that's Monday, November 15th.\n3    I would also like to just go ahead and schedule what\n4    will be our final pretrial conference for November 23rd, is\n5    what I propose, in the afternoon. I still need to work through\n6    the logistics and space and timing on that, use that to clear\n7    out any remaining issues or motions in advance of trial.\n8    Ms. Pomerantz, how does that sound to the government?\n9    MS. POMERANTZ: That all sounds fine. Thank you.\n10   THE COURT: Ms. Sternheim?\n11   MS. STERNHEIM: That sounds fine. I just have a\n12   question with regard to the commencement --\n13   THE COURT: Could you pull up the mike.\n14   MS. STERNHEIM: Oh. Sorry.\n15   With regard to the commencement of voir dire, what\n16   time will we begin on the 16th?\n17   THE COURT: I believe 9, but I will confirm and see\n18   what time I believe -- what time we think the jurors will\n19   actually be ready to go, checked in and ready to go, and I'll\n20   work backwards from that, give us time to get set up and\n21   address any preliminary issues. So let's assume 9 and I'll\n22   confer with the jury department.\n23   MS. STERNHEIM: Thank you.\n24   Just a moment.\n25   SOUTHERN DISTRICT REPORTERS, P.C.\n      (212) 805-0300\nDOJ-OGR-00007184",
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+      "content": "And as I said, we'll discuss voir dire and take up questionnaire issues as needed.\nSo that's Monday, November 15th.\nI would also like to just go ahead and schedule what\nwill be our final pretrial conference for November 23rd, is\nwhat I propose, in the afternoon. I still need to work through\nthe logistics and space and timing on that, use that to clear\nout any remaining issues or motions in advance of trial.\nMs. Pomerantz, how does that sound to the government?\nMS. POMERANTZ: That all sounds fine. Thank you.\nTHE COURT: Ms. Sternheim?\nMS. STERNHEIM: That sounds fine. I just have a\nquestion with regard to the commencement --\nTHE COURT: Could you pull up the mike.\nMS. STERNHEIM: Oh. Sorry.\nWith regard to the commencement of voir dire, what\ntime will we begin on the 16th?\nTHE COURT: I believe 9, but I will confirm and see\nwhat time I believe -- what time we think the jurors will\nactually be ready to go, checked in and ready to go, and I'll\nwork backwards from that, give us time to get set up and\naddress any preliminary issues. So let's assume 9 and I'll\nconfer with the jury department.\nMS. STERNHEIM: Thank you.\nJust a moment.",
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+      "Document 467",
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+  "additional_notes": "The document appears to be a court transcript with a clear and readable format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007185.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 6 of 158 6 LBAAMAX1ps\n\n1 Your Honor, Mr. Pagliuca has a hearing in Colorado.\n2 Would it be permissible for him not to appear at the final\n3 pretrial conference? Ms. Menninger, Mr. Everdell, and I will\n4 be present.\n5 THE COURT: That's fine with me.\n6 MS. STERNHEIM: Thank you\n7 THE COURT: And I do plan to put out a logistics order\n8 after today that confirms the details of the conferences I've\n9 just discussed and rooms and the like.\n10 Do the parties have any other logistical matters or\n11 questions to raise before we return to the motions?\n12 MS. POMERANTZ: No, your Honor.\n13 MS. STERNHEIM: No. Thank you.\n14 THE COURT: OK. So we can proceed to the Daubert with\n15 respect to the government's proposed expert. Ms. Pomerantz.\n16 MS. POMERANTZ: Yes, your Honor. The government calls\n17 Dr. Lisa Rocchio.\n18 THE COURT: I didn't catch -- I have been saying row\n19 \"Rodocchio\" in my head, but it sounds like that's not right.\n20 Could you say the name again?\n21 MS. POMERANTZ: It's \"ROCK-ee-oh,\" your Honor.\n22 THE COURT: Rocchio.\n23 And I will ask everyone, please speak into the\n24 microphones, because that's the only way we can all hear you.\n25 Counsel can question from the podium and remove masks.\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00007185",
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+      "content": "1 Your Honor, Mr. Pagliuca has a hearing in Colorado.\n2 Would it be permissible for him not to appear at the final\n3 pretrial conference? Ms. Menninger, Mr. Everdell, and I will\n4 be present.\n5 THE COURT: That's fine with me.\n6 MS. STERNHEIM: Thank you\n7 THE COURT: And I do plan to put out a logistics order\n8 after today that confirms the details of the conferences I've\n9 just discussed and rooms and the like.\n10 Do the parties have any other logistical matters or\n11 questions to raise before we return to the motions?\n12 MS. POMERANTZ: No, your Honor.\n13 MS. STERNHEIM: No. Thank you.\n14 THE COURT: OK. So we can proceed to the Daubert with\n15 respect to the government's proposed expert. Ms. Pomerantz.\n16 MS. POMERANTZ: Yes, your Honor. The government calls\n17 Dr. Lisa Rocchio.\n18 THE COURT: I didn't catch -- I have been saying row\n19 \"Rodocchio\" in my head, but it sounds like that's not right.\n20 Could you say the name again?\n21 MS. POMERANTZ: It's \"ROCK-ee-oh,\" your Honor.\n22 THE COURT: Rocchio.\n23 And I will ask everyone, please speak into the\n24 microphones, because that's the only way we can all hear you.\n25 Counsel can question from the podium and remove masks.",
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+  "additional_notes": "The document appears to be a court transcript with clear and legible text. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007186.json

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+    "page_number": "7",
+    "document_number": "467",
+    "date": "11/15/21",
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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 7 of 158 7 LBAAMAX1ps Rocchio - Direct 1 And the witness can come into the witness box and remove her mask as well. 2 3 Dr. Rocchio may come forward. 4 MS. POMERANTZ: Thank you, your Honor. 5 LISA ROCCHIO, 6 called as a witness by the government, 7 having been duly sworn, testified as follows: 8 THE COURT: And Dr. Rocchio, I know it's a little 9 awkward; to the extent you can speak directly into the 10 microphone, we can hear you. And I apologize if I have to 11 remind you of that as we go, because the acoustics are 12 challenging. 13 THE WITNESS: OK. 14 THE COURT: Thank you. 15 Ms. Pomerantz. 16 MS. POMERANTZ: Thank you, your Honor. 17 THE COURT: And, Ms. Pomerantz, you need that mike in 18 front of you. 19 MS. POMERANTZ: Thank you. 20 Is this all right, your Honor? 21 THE COURT: Yes, but point it directly at you. 22 MS. POMERANTZ: OK. Thank you. 23 DIRECT EXAMINATION 24 BY MS. POMERANTZ: 25 Q. Good morning, Dr. Rocchio. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007186",
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results/IMAGES003/DOJ-OGR-00007193.json

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results/IMAGES003/DOJ-OGR-00007195.json

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results/IMAGES003/DOJ-OGR-00007196.json

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results/IMAGES003/DOJ-OGR-00007197.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 18 of 158 18 LBAAMAX1ps Rocchio - Direct either reported to me that they've been sexually abused or have been referred to me after criminal proceedings have convicted a perpetrator. So those would be cases where it's been established that they've been abused. Q. During the course of your career, how old are the patients you've treated and evaluated who experienced childhood sexual abuse? A. I've treated, over the course of my career, individuals ages 13 and up. Q. And if this -- in your current practice, how old are the patients you treat? A. I'm currently working with individuals predominantly who are 18 and older. Q. In addition -- THE COURT: Sorry. What you're describing generally, is there a distinction to be made here in terms of your practice regarding childhood sexual abuse between your clinical side of your work and the forensic side? You're talking about your clinical work, I presume. THE WITNESS: I'm talking about my clinical work, but it is true that in both my clinical and forensic practice I have done a fair amount of work with adolescents as well as adults and that currently I am predominantly working in both settings with the evaluation of adults. THE COURT: OK. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007197",
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results/IMAGES003/DOJ-OGR-00007198.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 19 of 158 19 LBAAMAX1ps Rocchio - Direct\n\nBY MS. POMERANTZ:\nQ. In addition to your group practice, do you work anywhere else?\nA. I do.\nQ. Where do you work?\nA. I'm on the voluntary faculty at Brown University, Alpert School of Medicine, in the department of psychiatry.\nQ. What is your title?\nA. I'm a clinical assistant professor.\nQ. How long have you been at the Alpert Medical School of Brown University?\nA. Since July 2020.\nQ. What are your current responsibilities in your employment there?\nA. I supervise psychiatry fellows in their efforts to learn how to conduct adult psychotherapy, and I also teach at some of the seminars that the psychiatry fellows attend.\nQ. What sorts of things do you teach on?\nA. When I'm asked to teach, I teach on areas related to traumatic stress and interpersonal violence.\nQ. Dr. Rocchio, I'd like to show you Government Exhibit 1.\nMS. POMERANTZ: Ms. Durocher, can you pull that up.\nQ. Dr. Rocchio, what is that?\nA. My curriculum vitae.\nQ. Does it accurately describe your education and\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n\nDOJ-OGR-00007198",
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results/IMAGES003/DOJ-OGR-00007199.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 20 of 158\nLBAAMAX1ps Rocchio - Direct\n1 qualifications?\n2 A. It does, although it doesn't reflect my recent promotion at\n3 Brown from clinical instructor to clinical assistant professor.\n4 MS. POMERANTZ: Your Honor, the government would offer\n5 Government Exhibit 1.\n6 THE COURT: No objection?\n7 MR. PAGLIUCA: No objection for purposes of this\n8 hearing, your Honor.\n9 THE COURT: OK. For the purposes of this hearing,\n10 Government Exhibit 1 is admitted. Thank you.\n11 (Government's Exhibit 1 received in evidence)\n12 Q. Turning to page 4, what is listed there?\n13 A. Publications and professional presentations.\n14 Q. Can you summarize the subject of some of your published\n15 work.\n16 A. My published work generally deals in some way with\n17 traumatic stress, ethics, and professional practice issues. So\n18 a recent article was looking at the forensic assessment of\n19 individuals who have experienced complex trauma, childhood\n20 trauma, severe and repeated childhood trauma. I've also\n21 written issues related to ethics as part of a public service\n22 for education of junior members in the newsletter for the Rhode\n23 Island Psychological Association.\n24 Q. Have you had any public articles published in a\n25 peer-reviewed journal?\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00007199",
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+      "content": "1 qualifications?\n2 A. It does, although it doesn't reflect my recent promotion at\n3 Brown from clinical instructor to clinical assistant professor.\n4 MS. POMERANTZ: Your Honor, the government would offer\n5 Government Exhibit 1.\n6 THE COURT: No objection?\n7 MR. PAGLIUCA: No objection for purposes of this\n8 hearing, your Honor.\n9 THE COURT: OK. For the purposes of this hearing,\n10 Government Exhibit 1 is admitted. Thank you.\n11 (Government's Exhibit 1 received in evidence)\n12 Q. Turning to page 4, what is listed there?\n13 A. Publications and professional presentations.\n14 Q. Can you summarize the subject of some of your published\n15 work.\n16 A. My published work generally deals in some way with\n17 traumatic stress, ethics, and professional practice issues. So\n18 a recent article was looking at the forensic assessment of\n19 individuals who have experienced complex trauma, childhood\n20 trauma, severe and repeated childhood trauma. I've also\n21 written issues related to ethics as part of a public service\n22 for education of junior members in the newsletter for the Rhode\n23 Island Psychological Association.\n24 Q. Have you had any public articles published in a\n25 peer-reviewed journal?",
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+}

results/IMAGES003/DOJ-OGR-00007200.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 21 of 158 21 LBAAMAX1ps Rocchio - Direct 1 A. I have. 2 Q. What does it mean to be in a peer-reviewed journal generally? 3 A. So the peer-review process in my field involves generally people would either solicit or send -- either the journal would solicit requests for articles or people would submit articles to a journal for publication. The journal would -- editors would then take those articles and send them out to professionals in the field who have agreed to serve as reviewers, who have some sort of expertise related to the topic of the particular article. Generally in that process it's known as a blind review -- that is, the reviewers don't know who the author is, to help protect from bias. They then are asked to review and comment on the article, and then to make a recommendation regarding whether the article should be accepted, whether it should be -- whether the author should be asked to make either minor or major revisions to the article and then resubmit, or whether the article should be declined. 19 Q. You also mentioned professional presentations. 20 A. Yes. 21 Q. Have you given any professional presentations? 22 A. Yes, I have. 23 Q. Focusing on pages -- sorry. Just let me back up one moment. What is a professional presentation? 24 A. It's a presentation that is given at a professional SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007200",
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results/IMAGES003/DOJ-OGR-00007201.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 22 of 158 22 LBAAMAX1ps Rocchio - Direct conference, where I'm providing either information and knowledge in the course of a presentation or I'm conducting a workshop, either by myself or as part of a symposium, a panel of presenters, on a given topic. Q. Are your professional presentations peer reviewed? A. Yes, they are. Q. What does it mean for a professional presentation to be peer reviewed? A. So it's the same peer-review process or it's analogous to the process I described for publication. In other words, people will submit, I would submit a presentation. There's a call for proposals. I would provide a proposal of what it is I would like to present to the program coordinator. They typically would have a team of individuals who then review all of the submissions and rate them. And then they would select those that they feel are most relevant and worthy and professional to present. Q. Focus on page 7 of Government Exhibit 1, have any of your professional presentations focused on trauma psychology or interpersonal violence? A. The vast majority of them have, yes. Q. Then turning to pages 7 and 8, have you given any invited addresses? A. I have. Q. What are invited addresses? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007201",
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+      "content": "conference, where I'm providing either information and knowledge in the course of a presentation or I'm conducting a workshop, either by myself or as part of a symposium, a panel of presenters, on a given topic. Q. Are your professional presentations peer reviewed? A. Yes, they are. Q. What does it mean for a professional presentation to be peer reviewed? A. So it's the same peer-review process or it's analogous to the process I described for publication. In other words, people will submit, I would submit a presentation. There's a call for proposals. I would provide a proposal of what it is I would like to present to the program coordinator. They typically would have a team of individuals who then review all of the submissions and rate them. And then they would select those that they feel are most relevant and worthy and professional to present. Q. Focus on page 7 of Government Exhibit 1, have any of your professional presentations focused on trauma psychology or interpersonal violence? A. The vast majority of them have, yes. Q. Then turning to pages 7 and 8, have you given any invited addresses? A. I have. Q. What are invited addresses?",
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results/IMAGES003/DOJ-OGR-00007202.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 23 of 158 23 LBAAMAX1ps Rocchio - Direct 1 A. Those talks where, rather than my submitting to a peer-review process, individuals or organizations and institutions have requested that I give a presentation within my areas of expertise. 2 Q. Have any of your invited addresses focused on trauma psychology and interpersonal violence? 3 A. The vast majority, yes. 4 Q. You testified about the peer-review process. Have you ever served as a peer reviewer for publications? 5 A. Yes. I serve as a peer reviewer for several. 6 Q. What types of publications? 7 A. I'm on the editorial board for the journal for the Division of Trauma psychology, so it's a trauma psychology journal, and my role there is to conduct regular peer reviews for that journal. I also serve as a peer reviewer, kind of as a guest peer reviewer, for a variety of other journals, when it's related to my topic matter. So I believe I've done that for psychological injury and the law as well as the journal of professional practice, recent -- journal -- professional journal research and practice, for example. 8 Q. When did you start serving as a peer reviewer for publications? 9 A. I've served as a peer reviewer for either professional presentations or publications for much of my career. I'm not sure when I first started doing it for journals, but I know SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007202",
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+}

results/IMAGES003/DOJ-OGR-00007203.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 24 of 158 24 LBAAMAX1ps Rocchio - Direct 1 I've been doing it for conferences from, you know, 20, 25 years minimally. 2 3 Q. Do you have any other involvement in professional publications? 4 5 A. I, apart from serving on the editorial board for the journal of trauma psychology, not at the moment, no. 6 7 Q. Do you hold -- 8 A. Oh, can I actually correct that answer? 9 Yes. Actually, the other thing is that for the publication I recently had, in addition to submitting articles for peer review, I was an invited guest editor in that particular edition -- special issue of that journal, so that meant that I had to, with my co-editor, solicit articles and then review them for publication. 10 11 12 13 14 15 Q. Do you belong to any professional organizations? 16 A. I do. 17 Q. Do you hold any leadership positions with those organizations? 18 19 A. I do. 20 Q. What are those leadership positions that you hold? 21 A. I'm currently the president-elect for the division of trauma psychology for the American Psychological Association. 22 I am also a member of the ethics committee for the American Psychological Association. I serve as a -- on the executive board of the Rhode Island Psychological Association, where I am 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007203",
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results/IMAGES003/DOJ-OGR-00007204.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 25 of 158 25 LBAAMAX1ps Rocchio - Direct their counsel representative to the National American Psychological Association. I believe those are my current leadership roles. I've held others in the past. Q. What do you do in your capacity as the president-elect of the division of trauma psychology? THE COURT: Ms. Pomerantz, you've gotten a little quieter, so into the mike and speak up. MS. POMERANTZ: Yes, your Honor. Q. What do you do in your capacity as president-elect of the division of trauma psychology? A. So I was elected to the position. It's a three-year term. I serve as part of what's called the presidential trio, which consists of the past president, the current president, and the president-elect. So I'll begin my term as president next year. And then, during my presidential year, I'm responsible for planning the topic and organizing and -- the theme of the program -- our division's program at the annual conference for the American Psychological Association. I sit on the executive board. I work closely with the executive director, overseeing, managing things related to finance, policy, particular outstanding projects or projects that -- ad hoc projects that I wish to execute during my presidential year. (Continued on next page) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007204",
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+      "content": "their counsel representative to the National American Psychological Association. I believe those are my current leadership roles. I've held others in the past. Q. What do you do in your capacity as the president-elect of the division of trauma psychology? THE COURT: Ms. Pomerantz, you've gotten a little quieter, so into the mike and speak up. MS. POMERANTZ: Yes, your Honor. Q. What do you do in your capacity as president-elect of the division of trauma psychology? A. So I was elected to the position. It's a three-year term. I serve as part of what's called the presidential trio, which consists of the past president, the current president, and the president-elect. So I'll begin my term as president next year. And then, during my presidential year, I'm responsible for planning the topic and organizing and -- the theme of the program -- our division's program at the annual conference for the American Psychological Association. I sit on the executive board. I work closely with the executive director, overseeing, managing things related to finance, policy, particular outstanding projects or projects that -- ad hoc projects that I wish to execute during my presidential year.",
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+}

results/IMAGES003/DOJ-OGR-00007205.json

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+}

results/IMAGES003/DOJ-OGR-00007206.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 28 of 158 28 LBAGmax2 Rocchio - Direct basis to consult with them on my area of expertise. A recent colleague who is a forensic psychologist, but not a forensic expert, contacted me to ask to teach her and talk with her about some of the traumatic stress issues that were involved in her case. Q. What types of training and presentations have you given in the area of childhood sexual abuse? A. I've given a number of trainings on complex trauma. And complex trauma refers to repeated abuse that occurs during childhood perpetrated generally by caregivers of the individual. I've also given -- so I've given trainings on -- for general clinicians -- on how to assess trauma and that may include assessing for a history of childhood sexual abuse. And I have given trainings, for example, at the Department of DCYF to investigators on how to manage the effects of being exposed to details related to traumatic stress in the course of their work. Those would be some examples of trainings I have done. Q. How do you keep up with the scientific literature in your field? A. So from my membership in a number of different divisions and, of course, international and national traumatic stress organizations, most of those journals have some combination -- most of those organizations have professional journals, in which they publish literature, scientific peer review literature, or they also have newsletters. They also have SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007207",
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results/IMAGES003/DOJ-OGR-00007208.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 30 of 158 30 LBAGmax2 Rocchio - Direct\n1 familiar with the term grooming?\n2 A. I am.\n3 Q. What is grooming?\n4 A. Grooming is a term that is used in the professional\n5 literature and in the field to refer to a series of tactics and\n6 strategies that are commonly experienced by victims and\n7 utilized by offenders in the course of deceiving the child,\n8 building a relationship of trust, and then eventually sexually\n9 abusing the child.\n10 Q. Can you please describe specific grooming strategies?\n11 A. So various researchers have identified grooming strategies\n12 involving a series of tactics that typically fit into several\n13 stages. They typically involve strategies to identify a\n14 victim, strategies to have access and to isolate the victim.\n15 So for example, many offenders put themselves purposefully in\n16 situations where they're going to have a great deal of access,\n17 whether that's a boy scout troop or a school setting or that\n18 type of thing, a coach. And then there are various coercive\n19 and manipulative strategies that are utilized to develop a\n20 relationship of trust, prosocial behaviors, things that might\n21 be gift giving or letting the child know how special they are,\n22 showering the child with affection. There's been some\n23 comparison in the literature, a significant amount of\n24 comparison to strategies that are basically akin to what two\n25 adults might do in a courtship process. But basically the\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007209",
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results/IMAGES003/DOJ-OGR-00007210.json

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results/IMAGES003/DOJ-OGR-00007211.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 32 of 158 32 LBAGmax2 Rocchio - Direct 1 Q. What is that term? 2 A. Attachment basically refers to the relationship between one person, one individual and another. The original research was conducted looking at the attachment as a connection between an infant and a caregiver, her mother. But since has expanded into talking about the relational dynamics between either children and caregivers, children and family members or, for example, two intimate partners as adults. 9 Q. Can you please explain the relationship, if any, between attachment and grooming? 10 A. So when I talked about some of the strategies that are utilized, tactics, modus operandi in order to build that relationship within the context of childhood sexual abuse, the function and end result of that is to create a relationship or attachment and connection between the perpetrator and the child, whereby the child trusts and becomes dependent upon the perpetrator. 18 Q. Based on your experience, research and training are you familiar with the term coercive control? 19 A. I am. 21 Q. What is coercive control? 22 A. Coercive control refers to a strategic pattern of behavior that's designed to attain and maintain control in a relationship. So coercion means getting somebody to either do or not do something that they wouldn't ordinarily do otherwise. 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007211",
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results/IMAGES003/DOJ-OGR-00007212.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 33 of 158 33 LBAGmax2 Rocchio - Direct 1 And it is combined with control tactics like isolation or 2 building access to resources so that the power in the 3 relational dynamic lies with the person who is using coercive 4 control. 5 It was initially developed and conceptualized to help 6 understand part of intimate partner violent relationships, but 7 has since been found to exist in multiple forms of 8 victimization. 9 Q. You mentioned specific grooming strategies earlier. Can 10 you give examples or specific examples of specific grooming 11 strategies? 12 A. Gift giving, spending time alone, giving hugs, giving 13 massages that gradually escalate to disrobing or more overtly 14 sexualized behavior, talking about sex. Basically, normalizing 15 behaviors and then over time -- normalizing sexualized 16 behaviors and then over time moving that line of what's normal, 17 what's appropriate, what's happening within this relationship 18 closer and closer to sexual abuse. 19 But the strategies that are utilized for the building 20 of relationship are the same types of things that anyone might 21 do to build trust and attachment. Again, giving attention, 22 making the child feel special, gift giving, spending -- taking 23 them out to special places, purchasing things for them. Also 24 things that make them perhaps more dependent upon you. So if 25 you are offering to pay for things and this person is in need  SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007212",
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+      "content": "1 And it is combined with control tactics like isolation or 2 building access to resources so that the power in the 3 relational dynamic lies with the person who is using coercive 4 control. 5 It was initially developed and conceptualized to help 6 understand part of intimate partner violent relationships, but 7 has since been found to exist in multiple forms of 8 victimization. 9 Q. You mentioned specific grooming strategies earlier. Can 10 you give examples or specific examples of specific grooming 11 strategies? 12 A. Gift giving, spending time alone, giving hugs, giving 13 massages that gradually escalate to disrobing or more overtly 14 sexualized behavior, talking about sex. Basically, normalizing 15 behaviors and then over time -- normalizing sexualized 16 behaviors and then over time moving that line of what's normal, 17 what's appropriate, what's happening within this relationship 18 closer and closer to sexual abuse. 19 But the strategies that are utilized for the building 20 of relationship are the same types of things that anyone might 21 do to build trust and attachment. Again, giving attention, 22 making the child feel special, gift giving, spending -- taking 23 them out to special places, purchasing things for them. Also 24 things that make them perhaps more dependent upon you. So if 25 you are offering to pay for things and this person is in need",
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results/IMAGES003/DOJ-OGR-00007213.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 34 of 158 34 LBAGmax2 Rocchio - Direct of money, and if you are giving them something that will increase their dependency. Also the adult-child relationship, the power differential. THE COURT: The specific examples you are mentioning, are those found in the literature? THE WITNESS: They are. THE COURT: So you derive your views as to those specific examples from -- not from your clinical work or your forensic work or maybe both -- but the ones you have cited just now, you find in peer-reviewed literature? THE WITNESS: Yes. It's an interaction. So everything I'm talking about today is derived from my education and experience, as well as my knowledge of the literature. But yes, for many years, those specific tactics and strategies have been described in numerous peer-reviewed articles. And your Honor, if I may, it's also, I believe important to know that those are articles that have studied reports and behaviors that offenders talk about doing as well as things that victims have talked about experiencing. THE COURT: Thank you. BY MS. POMERANTZ: Q. Dr. Rocchio, you gave an example of gift giving, how can you tell if that is grooming or innocent behavior? A. As I said, it depends on the context in which the gift giving is happening. And you have to look at the entire SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007213",
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results/IMAGES003/DOJ-OGR-00007214.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 35 of 158 35 LBAGmax2 Rocchio - Direct relationship. As I said, child sexual abuse is a process. It's not an isolated event. To the extent that gift giving is being done in the service of increasing someone's dependency on you for the purposes of increasing your ability to coerce and control them, ultimately, for sexual abuse, then that gift giving would be considered part of -- to be part of the grooming process. Q. How long has the concept of grooming been in the scientific literature? A. Grooming itself has been in the scientific literature at least since the 80s. But the scientific literature that has looked at the relational components of child sexual abuse and the ways in which victims become coerced into, quote, unquote, complying with sexual activity by an adult has been well established in the study of child sexual abuse for quite some time. Q. At a high level, what are your opinions on grooming based on? A. They're based on the interaction between my education, my training, the skills I have developed over time, certainly my ongoing review of the scientific literature and my practice. Q. In your education, how did you learn about the concept of grooming? A. So again, in my education part of how I learned that, it was from my study of the process of child sexual abuse and both SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007214",
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results/IMAGES003/DOJ-OGR-00007215.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 36 of 158 36 LBAGmax2 Rocchio - Direct what that typically entails, not just the sexual components, but also the psychological and emotional components and their effects. And also, certainly, in my reviews of the literature and things that we talked about in graduate school and in other trainings, what sorts of behaviors offenders commonly use in order to engage children in that relationship. Q. In your clinical practice, have you treated and evaluated patients who have reported being groomed in connection with sexual abuse? A. I have. Although they don't typically use that word. As I said, most patients, including patients I treat, who have been abused as children, have had abuse happen in the context of a relationship. The abuse hasn't involved explicit force. So to the extent that they talk about the ways that they came to know, love and depend upon the perpetrator, yes, they talk and describe at length the types of behaviors that would meet the definition of grooming. Q. Approximately how many patients have you treated, evaluated who have reported behaviors consistent with grooming? A. I would say the vast majority of patients I have treated who have reported childhood sexual abuse, again, that would be hundreds upon hundreds. Q. What are the ages of the patients you have treated who have reported behaviors consistent with grooming? A. I have treated patients who are adolescents and patients SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007215",
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results/IMAGES003/DOJ-OGR-00007216.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 37 of 158 37 LBAGmax2 Rocchio - Direct 1 who are adults. 2 Q. Are you aware of other psychologists treating and evaluating patients that reported behaviors consistent with grooming? 3 A. Absolutely. It's common in the field. 4 Q. How do you know that? 5 A. Through my review of the clinical research, it's something that's well documented in articles or books, chapters that have been written, for example, about how to provide treatment to patients. It's written in the literature around what sorts of symptoms might patients present with and why, what are some of the common difficulties. Of course, it's written in case studies. And then through my conversations with peers and, of course, trainings I have attended conducted by experts in the field. 6 Q. In your forensic practice, have you evaluated survivors of childhood sexual abuse? 7 A. I have. 8 Q. What does forensic evaluation of someone who has reported childhood sexual abuse entail? 9 A. So in general, a forensic evaluation is a multistep process. As I mentioned before, it's not just talking to someone. So a forensic evaluation, as I conduct it, involves first reading all of the relevant external collateral information relevant to the case. So if it's a criminal case, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007216",
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+      "content": "1 who are adults. 2 Q. Are you aware of other psychologists treating and evaluating patients that reported behaviors consistent with grooming? 3 A. Absolutely. It's common in the field. 4 Q. How do you know that? 5 A. Through my review of the clinical research, it's something that's well documented in articles or books, chapters that have been written, for example, about how to provide treatment to patients. It's written in the literature around what sorts of symptoms might patients present with and why, what are some of the common difficulties. Of course, it's written in case studies. And then through my conversations with peers and, of course, trainings I have attended conducted by experts in the field. 6 Q. In your forensic practice, have you evaluated survivors of childhood sexual abuse? 7 A. I have. 8 Q. What does forensic evaluation of someone who has reported childhood sexual abuse entail? 9 A. So in general, a forensic evaluation is a multistep process. As I mentioned before, it's not just talking to someone. So a forensic evaluation, as I conduct it, involves first reading all of the relevant external collateral information relevant to the case. So if it's a criminal case,",
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results/IMAGES003/DOJ-OGR-00007217.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 38 of 158 38 LBAGmax2 Rocchio - Direct 1 that might be crime scene photos, autopsy photos, that might be transcripts of grand jury testimony, state police interviews. 2 3 In a civil case, I might also look at things like medical 4 records and psychotherapy records. So any and all documents 5 relevant to the case. 6 7 Then I typically do somewhere between eight and ten 8 hours of face-to-face evaluation, that involves both 9 psychological testing and clinical interviewing. I also 10 conduct collateral interviews with others who have information 11 that's relevant to the case and to the issues at hand. 12 13 And then I synthesize all of that information. And if 14 requested will prepare a report. Most cases don't end up going 15 to trial. But if they do and I'm asked to testify, I would 16 then testify in those cases. 17 18 Q. Do you evaluate issues of grooming in connection with your 19 forensic practice? 20 A. Yes, I have. 21 Q. Can you give me an example of a forensic evaluation that 22 has involved grooming-related issues? 23 A. Sure. So for example, in the civil arena where I am asked 24 to -- say somebody has alleged that they've been sexually 25 abused as a child or maybe we know that they have been sexually 26 abused as a child because the perpetrator has been criminally 27 convicted, I may be asked to assess, does this individual at 28 the present time have any current psychiatric difficulties or 29 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007217",
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results/IMAGES003/DOJ-OGR-00007218.json

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+}

results/IMAGES003/DOJ-OGR-00007219.json

@@ -0,0 +1,49 @@
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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 40 of 158 40 LBAGmax2 Rocchio - Direct you assume everything a victim reports is true? A. No, I do not. Q. Can you explain? A. So in a clinical setting, it is not my role to determine whether something is or is not true. Of course, when someone is telling me something, I'm using my skill and experience to take that information in and also to inquire, as I communicate to that individual and provide treatment. But as I mentioned earlier, I don't go out and try to see, well, this person is having trauma related to a motor vehicle accident or a shooting on the job, I don't go and ask them to provide me with newspaper articles to verify whether that event happened. Q. How do the grooming that you have seen in your forensic practice compare to what you have seen in your clinical practice? A. There's remarkable consistency in what I see in my work over time in my forensic practice, my clinical practice and what I have been trained and what's in the literature. Q. Can you describe at a high level the scientific literature upon which your opinions on grooming are based? A. So there have been a number of studies over time that have looked at the tactics, modus operandi, skill, manipulative techniques that have been used by perpetrators. And those studies have been published in peer-review journals. So there are studies that have done interviews with offenders, who have SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007219",
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+}

results/IMAGES003/DOJ-OGR-00007220.json

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+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 41 of 158 41 LBAGmax2 Rocchio - Direct been convicted and who admit to their crimes, asking them what sorts of techniques they utilized in order to perpetuate the sexual abuse. There have been studies that have been done with victims, in terms of asking them what sorts of experiences they had. There have also been studies that have been conducted with professionals in various fields; law and human services and psychology about the types of tactics and strategies that have been used. Q. How do the results of those studies compare? A. There's remarkable consistency. And even though definitions may vary in studies, as they always do, there are common -- a clear set of common strategies, techniques and behaviors that have been identified in the literature across time and across various samples. Q. When you review articles about grooming, what sorts of things are you looking for to determine the quality of articles you are relying on? A. I'm looking at whether or not it's in a peer review journal. I'm looking at how a particular study was conducted. So for example, if they're doing content analysis of an interview, are they making sure that ways that that interview has been coded by multiple individuals to get some sort of consistency there. I'm looking at how they chose the sample size. I'm looking at if it's a review that summarizes the state of the literature, is the literature review SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007220",
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+      "content": "been convicted and who admit to their crimes, asking them what sorts of techniques they utilized in order to perpetuate the sexual abuse. There have been studies that have been done with victims, in terms of asking them what sorts of experiences they had. There have also been studies that have been conducted with professionals in various fields; law and human services and psychology about the types of tactics and strategies that have been used.",
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+  "additional_notes": "The document appears to be a court transcript with a clear structure and formatting. The text is mostly printed, with no visible handwriting or stamps. The content discusses studies on sexual abuse and the methods used by perpetrators."
+}

results/IMAGES003/DOJ-OGR-00007221.json

@@ -0,0 +1,49 @@
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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 42 of 158 42 LBAGmax2 Rocchio - Direct comprehensive. I might go back to some of the original sources cited in the reference list, for example, and look at those articles to see if in the article I'm reading, when they describe article X, when I read article X, is that actually what article X is saying. Also, there are researchers who have come to be known in a particular field, so I might look at who the authors are and where the research is being conducted. Q. Beyond what you have already described, can you give any examples of how studies are conducted? A. They're conducted in a variety of ways. So for example -- I think I may have already described it -- but there are a variety of ways people might interview offenders and ask them what they do, what strategies and tactics they use. There might be studies that look at victims reporting what their experiences are. Or there might be studies where you're looking at treatment of victims and what are some of the issues that patients are bringing to treatment that need to be addressed, so the strategies that they experienced might come out that way. Certainly, studies have been done interviewing various experts, asking them what are strategies. And then looking for what are the strategies that experts from a variety of different fields agree upon, to a degree of certainty, and what do these professionals agree are part of what they see. Q. Do studies use the same or different definitions of grooming? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007221",
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+      "content": "LBAGmax2 Rocchio - Direct comprehensive. I might go back to some of the original sources cited in the reference list, for example, and look at those articles to see if in the article I'm reading, when they describe article X, when I read article X, is that actually what article X is saying. Also, there are researchers who have come to be known in a particular field, so I might look at who the authors are and where the research is being conducted. Q. Beyond what you have already described, can you give any examples of how studies are conducted? A. They're conducted in a variety of ways. So for example -- I think I may have already described it -- but there are a variety of ways people might interview offenders and ask them what they do, what strategies and tactics they use. There might be studies that look at victims reporting what their experiences are. Or there might be studies where you're looking at treatment of victims and what are some of the issues that patients are bringing to treatment that need to be addressed, so the strategies that they experienced might come out that way. Certainly, studies have been done interviewing various experts, asking them what are strategies. And then looking for what are the strategies that experts from a variety of different fields agree upon, to a degree of certainty, and what do these professionals agree are part of what they see. Q. Do studies use the same or different definitions of grooming?",
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+}

results/IMAGES003/DOJ-OGR-00007222.json

@@ -0,0 +1,84 @@
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+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 43 of 158 43 LBAGmax2 Rocchio - Direct\n\n1 A. So the definitions can vary. They're all generally referring to the same process. But the specific definition may vary in different studies. So you have to be sure that the literature, when reviewing it, you have to understand what definition they're using.\n\n6 Q. How can you rely on the empirical studies when there is variance across the different definitions of grooming used in those studies?\n\n9 A. To the extent they're talking about the same kind of process in the context of childhood sexual abuse. And again, grooming, not only may there be variances in definition of grooming, but the same patterns and behavior are sometimes referred to by different names. But what you really want to look for are the commonalities. So for example, are what offenders tell us they do, does that -- to what degree of overlap is there between that and what victims tell us that they have experienced. When professionals talk about the kinds of behaviors, how much overlap and agreement is there between professionals, say, in similar fields, but also in different fields in characterizing these common phenomenon, the common phenomenon.\n\n22 Q. Do studies look at samples of substantiated cases of abuse?\n\n23 A. Yes.\n\n24 Q. What does that mean?\n\n25 A. So some of the research has been done that has looked at\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n\nDOJ-OGR-00007222",
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+      "content": "1 A. So the definitions can vary. They're all generally referring to the same process. But the specific definition may vary in different studies. So you have to be sure that the literature, when reviewing it, you have to understand what definition they're using.",
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+      "content": "9 A. To the extent they're talking about the same kind of process in the context of childhood sexual abuse. And again, grooming, not only may there be variances in definition of grooming, but the same patterns and behavior are sometimes referred to by different names. But what you really want to look for are the commonalities. So for example, are what offenders tell us they do, does that -- to what degree of overlap is there between that and what victims tell us that they have experienced. When professionals talk about the kinds of behaviors, how much overlap and agreement is there between professionals, say, in similar fields, but also in different fields in characterizing these common phenomenon, the common phenomenon.",
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+}

results/IMAGES003/DOJ-OGR-00007223.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 44 of 158 44 LBAGmax2 Rocchio - Direct and interviewed individuals where the abuse has been known, either because the perpetrator has offended -- has admitted -- I apologize -- or has been found guilty. So that would be an example of a legally substantiated case. Other times, they find studies where it's been substantiated in other ways; there have been interviews done with children who presented in medical settings with gonorrhea and talking with them about sexual abuse or abuse with kids in real time. MS. POMERANTZ: Can you pull up Government Exhibit 2, please. Q. Dr. Rocchio, do you recognize this? A. I do. Q. What is it? A. It's an article about coercive control. Q. Who is the author? A. Jacquelynn Duron, Laura Johnson, Gretchen Hoge and Judy Postmus. MR. ROHRBACH: Your Honor, the government would offer Government Exhibit 2. THE COURT: Any objection? MR. PAGLIUCA: Not for purposes of this hearing, your Honor. THE COURT: Government Exhibit 2 is admitted for the hearing. (Government's Exhibit 2 received in evidence) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007223",
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+}

results/IMAGES003/DOJ-OGR-00007224.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 45 of 158 45\n\nBY MS. POMERANTZ:\nQ. Dr. Rocchio, to prepare for this hearing, did you provide the government with samples of literature?\nA. I did.\nQ. Is this one of the samples you provided?\nA. Yes.\nQ. Is this article peer-reviewed?\nA. Yes.\nQ. At a high level, can you describe this article?\nA. So what this article did, it reviewed information provided by a variety of professionals who had expertise, specifically in offender behavior and tactics that are utilized by offenders in sexual abuse, professionals from a variety of fields. And it asked them to talk about some of the tactics used in furthering the relationship and developing a dynamic of coercive control.\nWhat was significant in particular about this article is not only did they look at coercive control as it applies to childhood sexual abuse, but they also looked at how coercive control, patterns of behavior play out in multiple forms of victimization; trafficking, elder abuse or pimp and sex worker relationships, intimate partner violence, rape, sexual assault, that sort of thing.\nQ. Does this article talk about grooming?\nA. It does.\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00007224",
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+      "content": "BY MS. POMERANTZ:\nQ. Dr. Rocchio, to prepare for this hearing, did you provide the government with samples of literature?\nA. I did.\nQ. Is this one of the samples you provided?\nA. Yes.\nQ. Is this article peer-reviewed?\nA. Yes.\nQ. At a high level, can you describe this article?\nA. So what this article did, it reviewed information provided by a variety of professionals who had expertise, specifically in offender behavior and tactics that are utilized by offenders in sexual abuse, professionals from a variety of fields. And it asked them to talk about some of the tactics used in furthering the relationship and developing a dynamic of coercive control.\nWhat was significant in particular about this article is not only did they look at coercive control as it applies to childhood sexual abuse, but they also looked at how coercive control, patterns of behavior play out in multiple forms of victimization; trafficking, elder abuse or pimp and sex worker relationships, intimate partner violence, rape, sexual assault, that sort of thing.\nQ. Does this article talk about grooming?\nA. It does.",
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+}

results/IMAGES003/DOJ-OGR-00007225.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 46 of 158 46 LBAGmax2 Rocchio - Direct\n1 Q. Does this article use any particular sampling?\n2 A. The sampling was of professionals from a variety of fields.\n3 And it looked for content analysis and commonalities in what\n4 these professionals reported were common behaviors and tactics\n5 that were used across types of victimization.\n6 Q. How, if at all, does that impact your assessment of the\n7 study and article?\n8 A. It impacts it significantly. Because what this article is\n9 doing is not only is it replicating what has previously been\n10 found about tactics that are used, it's extending that\n11 literature and saying that these are common patterns of\n12 behavior that are used in the service of coercive control in a\n13 variety of types of victimization. So it's identifying a\n14 common tactic that's used in a number of settings to gain and\n15 maintain power and to coerce a victim into some form of\n16 behavior.\n17 THE COURT: Let me ask on that, one of the examples\n18 you gave was the pimp and sex worker relationship. In some of\n19 the literature and in the cases, trauma bonding is the phrase\n20 that's used?\n21 THE WITNESS: Yes.\n22 THE COURT: What's your understanding of the\n23 similarity, the overlap and prevalence of understanding of\n24 these two concepts in the field?\n25 THE WITNESS: In the field, there's significant -- so\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00007225",
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results/IMAGES003/DOJ-OGR-00007226.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 47 of 158 47 LBAGmax2 Rocchio - Direct trauma bonding is typically referring to a relationship of attachment and connection between the pimp and the sex worker. We know that the majority of sex workers are under some third-party control. And we know that the trauma bonding is often the means by which the pimp has coerced the sex worker to get them to do their bidding, similar to the kinds of techniques that traffickers might use. So there's a significant amount of overlap. And there has been actually some recent research -- this is one example -- but others have specifically looked at grooming as it applies to trafficking, for example. THE COURT: Thank you. BY MS. POMERANTZ: Q. Dr. Rocchio -- withdrawn. MS. POMERANTZ: Can we pull up Government Exhibit 3, please. BY MS. POMERANTZ: Q. Dr. Rocchio, do you recognize this? A. I do. Q. What is it? A. It's an article validating a model of child sexual abusers. Q. Who wrote this? A. Georgia Winters, Elizabeth Jeglic and Leah Kaylor. MS. POMERANTZ: The government offers Government Exhibit 3. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007226",
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+}

results/IMAGES003/DOJ-OGR-00007227.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 48 of 158 48 LBAGmax2 Rocchio - Direct 1 MR. PAGLIUCA: No objection. 2 THE COURT: Government Exhibit 3 is admitted to the 3 hearing record. 4 (Government's Exhibit 3 received in evidence) 5 BY MS. POMERANTZ: 6 Q. Dr. Rocchio, is this one of the articles you provided to 7 the government? 8 A. It is. 9 Q. When was this article published? 10 A. 2020 or 2021. I can't read the date right now. I think it 11 was 2020. 12 Q. Is this article peer reviewed? 13 A. It is. 14 It was published in October 2020. Thanks. I don't 15 have my glasses on. 16 Q. What was the conclusion of this study? 17 A. So what these authors did is a two-part study. So the 18 first thing that they did is they did an extensive literature 19 review to look for commonalities in the literature about what 20 are the commonly described stages that a perpetrator engages in 21 and what are the behaviors that are associated with those 22 stages. So they did a very comprehensive literature review. 23 They identified a number of specific behavioral and observable 24 strategies that individuals have identified in the literature. 25 They then got a group of recognized individuals in SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007227",
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results/IMAGES003/DOJ-OGR-00007228.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 49 of 158 49 LBAGmax2 Rocchio - Direct various fields with a high level of expertise -- I believe there were about 18 professionals; 15 of them had doctoral degrees and they all had a significant number of publications having to do with offender behavior -- they did a scientific analysis, whereby they had the professionals rate the relevance of not only the stages of grooming to their understanding of tactics and strategies utilized by offenders, but also the specific developments of very specific behaviors. So they had each of those behaviors rated on a four point scale by all of the professionals. And then they conducted analysis to see which of the items for which there was a high level, statistically significant level of agreement between the professionals, as to which of these behaviors were relevant. And they then went back and they asked, of those behaviors, where was their agreement on which stages that these specific behaviors belonged to. So I think they were able, through that analysis, to get a statistically significant agreement about behaviors. I think they narrowed it down to about 43 specific behaviors in this particular model. Q. I want to direct your attention to Page 3. A. Okay. Q. What is this table? A. So this is a table that, if you can see, there are five stages of the model; the first being the victim selection, then SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007228",
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results/IMAGES003/DOJ-OGR-00007229.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 50 of 158\nLBAGmax2 Rocchio - Direct\ngaining access and isolation, trust development, desensitization, sexual contact and physical contact. And then beneath each stage level, there is a list of the behavioral and the observable and measurable behaviors where there was a high level of statistical significance in agreement among varying professionals as to the relevance both to the grooming process and to the stages.\nQ. I want to direct your attention to Page 4. What is this table?\nA. So these, as I mentioned, there was an original list of about 77 specific behaviors that have been found associated with grooming in the literature fairly consistently. These are the behaviors that were part of that original list, where perhaps there were more differences of opinion, but the level of agreement among the professionals in this particular study did not reach the level of statistical significance.\nQ. What is your takeaway from the study in the article?\nA. I think this is a study that has really done a good job of integrating what we know and pulling together the literature, and then putting it to an empirical test. There have been other ways to empirically understand and test what is referred to as grooming. I think this is another way that provides some validation of a proposed model of the ways in which grooming works.\nMS. POMERANTZ: You can pull that down. I'd like to\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00007229",
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+}

results/IMAGES003/DOJ-OGR-00007230.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 51 of 158 51 LBAGmax2 Rocchio - Direct 1 show Dr. Rocchio Exhibit 4. 2 BY MS. POMERANTZ: 3 Q. Do you recognize this? 4 A. I do. 5 Q. What is it? 6 A. It's an article on the construct of grooming in child sexual abuse that identifies both a summary of literature as well as some of the conceptual and measurement issues that were present at the time the article was written. 10 Q. Who wrote this article? 11 A. Natalie Bennett and William O'Donohue. 12 MS. POMERANTZ: The government offers Exhibit 4. 13 MR. PAGLIUCA: No objection. 14 THE COURT: Thank you. Government Exhibit 4 is 15 admitted into the hearing record. 16 (Government's Exhibit 4 received in evidence) 17 BY MS. POMERANTZ: 18 Q. Is this one of the articles that you provided the government? 19 A. It is. 20 Q. Why did you provide the government with this article? 21 A. I think that this article does a really good job of summarizing much of the previous literature that has been published and peer-reviewed sources about the grooming process. It identified some of the issues and varying definitions. It 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007230",
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results/IMAGES003/DOJ-OGR-00007231.json

@@ -0,0 +1,53 @@
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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 52 of 158 52 LBAGmax2 Rocchio - Direct provided data supporting that this is a process that is well known and well established in the literature, and then it pointed to directions that were needed for future work. It pointed to some of the concerns about definitions and things that -- suggestions, basically, for issues that needed to be addressed in future research. Q. Do you agree with all of the conclusions of this article? A. I do not. Q. I want to direct your attention to Page 959. And I want to zoom in on the paragraph above current definitions. It's about four lines down. It starts with \"Furthermore.\" A. Okay. MS. POMERANTZ: We can highlight those next two sentences. Q. Dr. Rocchio, could you review the highlighted text. A. Okay. MS. POMERANTZ: And for purposes of the record, your Honor, I'm happy to read that. THE COURT: The sentence beginning with \"Furthermore\" and ending with \"negatives.\" MS. POMERANTZ: Thank you, your Honor. BY MS. POMERANTZ: Q. Dr. Rocchio, what is your reaction to this? A. I think it's incomplete and I disagree with the conclusion. Q. Can you explain? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007231",
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results/IMAGES003/DOJ-OGR-00007232.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 53 of 158 53 LBAGmax2 Rocchio - Direct 1 A. Sure. I think that certain things -- some psychologists use clinical judgment on whether or not a perpetrator's 2 behaviors are considered grooming. But that certainly doesn't 3 at all reference the scientific literature to determine what is 4 and is not considered grooming. In addition, we also have data 5 that's been provided by offenders themselves. 6 7 In terms of reliability and validity of these 8 judgments, the validity in psychological science refers to the 9 degree to which you are measuring this particular thing, what 10 you think you're measuring. So for example, the degree to 11 which there is significant overlap between what victims say 12 they experience and what offenders say that they have done 13 provides us with a measure of validity. 14 15 The degree to which different groups of individuals, 16 whether that's groups of professionals or groups of victims 17 agree in studies what it is that -- the process, what kinds of 18 behaviors, what's been done to the victim, what kinds of 19 behaviors are associated with the grooming process, to the 20 extent those professionals agree, that's a measure of 21 reliability. Because you're getting different studies, 22 different groups, different samples where there's significant 23 overlap in what this dynamic and what this concept is. 24 MS. POMERANTZ: I want to turn to Page 974. 25 Q. I want you to focus on the section under conclusions and 26 the first two sentences, so \"Currently.\" 27 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007232",
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results/IMAGES003/DOJ-OGR-00007233.json

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results/IMAGES003/DOJ-OGR-00007234.json

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results/IMAGES003/DOJ-OGR-00007235.json

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results/IMAGES003/DOJ-OGR-00007236.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 57 of 158 57 LBAGmax2 Rocchio - Direct people as sexually abused and others not. So you have to look for other ways to assess acceptability within the scientific literature; peer review and general thoughts about concepts. And so that's where you look at the reliability as in what do the experts consistently agree to among themselves. You look at the degree of overlapping studies, perhaps studying it in different ways, but are they still coming up with the same clear description of the types of things that happen in the context of child sexual abuse. So for example, there was a content analysis done through interviews to pull out what some of those studies have found and to the degree that they're rated by multiple reviewers, and then compare the ratings of those reviewers, that's an indices of reliability. MS. POMERANTZ: I think we're done with Government Exhibit 4. Can we pull up Government Exhibit 5, please. Q. Dr. Rocchio, do you recognize this? A. I do. Q. What is it? A. It's an article describing the evolution of the word grooming and how it's been used, as well as the term seduction, to describe this commonly understood pattern of behavior and the strategies used by child perpetrators in the service of sexual exploitation and abuse. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007236",
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results/IMAGES003/DOJ-OGR-00007237.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 58 of 158 58 LBAGmax2 Rocchio - Direct 1 Q. Who wrote this article? 2 A. Park Dietz. 3 MS. POMERANTZ: Your Honor, we move to admit 4 Government Exhibit 5. 5 MR. PAGLIUCA: No objection. 6 THE COURT: Government Exhibit 5 is received. 7 (Government's Exhibit 5 received in evidence) 8 BY MS. POMERANTZ: 9 Q. Dr. Rocchio, did you provide the government with this article? 10 A. I did. 11 Q. Why did you provide the government with this article? 12 A. I was asked to provide examples to the government of 13 literature in the field that I thought might be helpful to the 14 court to understand the concepts that I'm talking about. This 15 does a really nice job of pointing to the part that the terms 16 grooming and seduction refer to a pattern of behavior that's 17 widely known and well established to be part of the dynamics of 18 sexual abuse. But in particular, I appreciated the author's 19 emphasis later on in the article of some of the problems with 20 the words seduction and some of the ways that much earlier 21 literature erroneously used terminology that could 22 inappropriately indicate a victim is blamed for the abuse that 23 they have been subjected to. 24 25 MS. POMERANTZ: Can you pull up Page 31, please. 26 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007237",
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results/IMAGES003/DOJ-OGR-00007238.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 59 of 158 59 LBAGmax2 Rocchio - Direct Q. I wanted to direct your attention to the use of the term grooming, so in that top paragraph. If you could review the section of the article that starts with \"If their use of the term grooming\" and all the way to the end of that paragraph and let me know when you have had a chance to review it, please. A. Okay. Q. Dr. Rocchio, what is your response, reaction to this passage? A. It's a bit confusing as to the point that's being made. I feel like they're trying to -- the author here seems to be mixing different applications of the term that they use grooming, so it looks like in part he's talking about what is true in the literature, which is that we're not particularly good as a field of taking, frankly, many behaviors at all and predicting future behaviors. So he's saying accurately that we can't look at specific behaviors alone as predictors. And certainly, the use of the term grooming, again, is used to describe a process, a pattern of behaviors. I'm not here today to say that if somebody engages in any one of these particular behaviors, yes, we know you're a child abuser. So he's making that point. But I don't think anybody -- I don't think that -- if that's his point, I wouldn't disagree with that. Except that he's then going on -- I disagree where he says that grooming then can't involve behaviors that might in fact be prosocial or normal. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007238",
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results/IMAGES003/DOJ-OGR-00007239.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 60 of 158\nLBAGmax2 Rocchio - Direct\n1 Again, we're talking about a use of a variety of strategies for the purpose of sexual abuse. So these are ways in which -- tactics, ways in which an offender might manipulate a child to developing a relationship of trust and attachment.\n2 Obviously, one can develop a relationship of trust and attachment in a variety of contexts. But when we're talking about grooming, the specific context, is when there's been coercive control and some form of organization.\n3 Q. Dr. Rocchio, taking a step back --\n4 MS. POMERANTZ: You can pull down Exhibit 5.\n5 Q. -- how have some of the behaviors you have seen in grooming literature compare to behaviors you have seen in your forensic practice and your clinical practice?\n6 A. Again, there's remarkable similarity in the impact of those behaviors. In my clinical practice victims talk about, I really trusted him, I thought he was a nice guy, he paid so much attention to me, he helped me out, he drove me places, he bought me sneakers when I didn't have any, he was the only person who cared about me. And that significantly -- in a clinical arena, that significantly impacts the individual's confusion and self-blame and often experiences of shame.\n7 Similarly, in a forensic setting, it can often contribute to an increase in the kinds of damage and harm that I need to assess that have stemmed from an incident.\n8 Q. In your view, is the concept of grooming generally accepted\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00007239",
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results/IMAGES003/DOJ-OGR-00007240.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 61 of 158 61 LBAGmax2 Rocchio - Direct within the scientific community? A. Yes, absolutely. Q. Based on your experience, research and training, are certain individuals at higher risk of being sexually abused as children? A. There are certain groups who are more vulnerable and there's a higher prevalence of child sexual abuse, yes. Q. What factors contribute to increased risk or higher vulnerabilities? A. So there are factors that have been studied and found in literature that have to do with the individual themselves. So for example, individuals who are particularly needy and vulnerable, individuals who have a prior history of victimization, you know, are at much higher risk of revictimization, individuals who are part of marginalized groups. For example, we know there's very high rates of sexual assault, childhood sexual abuse among especially minority children or among intellectually and cognitively disabled children. We know that individuals who come from certain types of family structures can be also at higher risk. For example, where there's only one parent, or children who come from home environments where there's abuse of other types going on in the home. So there might be other siblings who are being abused or the parents might be engaged -- one of the parents might be SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007240",
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results/IMAGES003/DOJ-OGR-00007241.json

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results/IMAGES003/DOJ-OGR-00007242.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 63 of 158 63 LBAAMAX3ps Rocchio - Direct\n1 Q. At a high level, what are your opinions on which individuals are at higher risk of child sexual abuse based on?\n2\n3 A. My training and my education, certainly my clinical and forensic experience, as well as my review of the clinical and scientific literature.\n4\n5 Q. In your education and training, did you learn about the concept of certain groups being at higher risk of childhood sexual abuse?\n6\n7 A. Yes, because, again, in the phenomenon of child sexual abuse in general, not -- we're looking at vulnerability factors, i.e., who's more at risk. So to the extent that I was learning about ways that you might want to target prevention, for example, where you might want to make those interventions,\n8\n9 but then also, we know that an individual's prior vulnerabilities interact with their subsequent experiences of victimization and have a profound effect on the outcome, the adverse outcomes of the abuse itself.\n10\n11 So it was covered in a number of different ways through the course of my education and training.\n12\n13 Q. In your clinical practice, have you treat and evaluated patients who belong to higher-risk groups?\n14\n15 A. Yes.\n16\n17 Q. Can you please explain.\n18\n19 A. In particular, we know that gender is a higher-risk group, and we know that women and girls are at higher risk for child\n20\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007242",
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results/IMAGES003/DOJ-OGR-00007243.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 64 of 158 64 LBAAMAX3ps Rocchio - Direct sexual abuse. So to the extent that more of my patients are women than men, certainly that's a vulnerability. But also, because, especially now, I'm working with adults, I'm working with people who have been repeatedly victimized at various points in time in their lives. And you can really clearly see the pattern, and it's something I often have to address with patients because they inquire about it, they don't understand. You know, why is it that this has happened to me so many times. And, again, we know from the revictimization literature that when someone is abused, they are at higher risk of being abused at later points in time. Also, you know, sometimes the clinical literature individuals will talk about the specific issues in their family that perhaps increase their vulnerability: They were always alone. They, you know, their mom was sick and this person had lots of opportunity to kind of befriend the family and, you know, therefore had greater access as a result of that vulnerability, or perhaps they were desperate for attention, care, love, and concern from another person because those are common childhood needs and maybe they weren't getting that at home. So those are all the kinds of things that would come up in, and have come up in, my over 30 years of treating patients. Q. In your forensic practice, do you examine the impact of SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007243",
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results/IMAGES003/DOJ-OGR-00007244.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 66 of 158 66 LBAAMAX3ps Rocchio - Direct\n1 A. Again, it's highly, high consistent, in both my criminal and civil, civil practices. Even if I'm not -- even if the issues specific to the sexual abuse are not the issue at hand, certainly when I'm doing a comprehensive evaluation, I'm taking a history and people are describing their prior experiences, the kinds of experiences they talk about in the context of having experienced childhood sexual abuse, the relationship they've had with the perpetrator, the kinds of things that the perpetrator has done to kind of engage them into that relationship for the purposes of sexual abuse are very consistent.\n12 Q. Is there empirical data to support your view that certain groups of children are at higher risk of being sexually abused?\n13 A. There is.\n14 Q. Can you explain?\n15 A. Sure. When we're studying any phenomenon, I want to look at the prevalence, which is, you know, how often does this thing, in this case child sexual abuse, occur. We can never have a perfect understanding, because some people will deny, you know, not everybody will report. But to the degree that we can look at national samples and, you know, on average how often does this occur in a national sample and then how often -- what is the rate of occurrence in other subgroups, so, you know, is the rate of sexual abuse higher, for example, from a prevalence perspective, in some marginalized individuals.\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00007245",
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results/IMAGES003/DOJ-OGR-00007246.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 67 of 158 67 LBAAMAX3ps Rocchio - Direct 1 When you look at who reports that they've been sexually abused, 2 is it reported more often by individuals who are members -- who 3 are women versus men. Is it reported, you know, more often or 4 found to have occurred more often, for example, in a group of 5 individuals who are cognitively or intellectually disabled. 6 MS. POMERANTZ: Ms. Durocher, can we pull up 7 Government Exhibit 3, please. Can we turn to page 3. 8 Q. Dr. Rocchio, we looked at this table before. Can you 9 please explain, what if anything does the table tell you about 10 particular vulnerabilities. 11 A. So the particular vulnerabilities in particular are most 12 relevant to the first stage of the grooming model, which is the 13 victim-selection model, in terms of looking at who are the 14 individuals that offenders choose to abuse or who end up 15 abusing. And, again, I think it's important to bear in mind 16 that this whole list was initially established from literature 17 looking at what offenders have told us they look for as well as 18 what kinds of prevalence rates have occurred in certain 19 populations. 20 And then these, in that top section of victim 21 selection, are the factors, vulnerability factors, that there 22 has been statistically significant agreement by professionals 23 factor into victim selection. 24 Q. And when you say \"the top section,\" you're referring to 25 the -- what part of the table are you referring to? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007246",
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results/IMAGES003/DOJ-OGR-00007247.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 68 of 158 68 LBAAMAX3ps Rocchio - Direct 1 A. I'm sorry. I'm referring to the list of behaviors specifically that are under the category entitled \"Victim Selection.\" 2 Q. Thank you. 3 4 MS. POMERANTZ: Can we turn to page 4. 5 6 Q. And directing your attention to the table on page 4, what does this table show and how does that impact your view on vulnerabilities? 7 8 A. So this table shows, again, specific behaviors that there's widespread agreement in this particular group of professionals 9 that are relevant to a particular stage of the grooming process. And, again, these are also behaviors that have been 10 commonly and repeatedly found to exist in the scientific 11 literature as being associated with the grooming process. 12 13 Q. And how does the information on this table compare to the table we were just looking at? 14 15 A. There are similar types of behaviors that can be done in 16 the service of building a relationship of trust and attachment, 17 and in -- and have been found to be utilized by offenders. But 18 there was not as much agreement among the professionals that 19 these specific behaviors -- about the relevance of these 20 specific behaviors and/or the stage to which they were part of. 21 22 MS. POMERANTZ: Thank you. Ms. Durocher, we can pull 23 that down. 24 25 Q. Dr. Rocchio, the defense has stated that your opinion that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007247",
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results/IMAGES003/DOJ-OGR-00007248.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 69 of 158 69 LBAAMAX3ps Rocchio - Direct individuals with particular vulnerabilities are often targeted by sexual abuse is a commonly accepted bit of clinical lore derived from the frequent observation of highly vulnerable children among those children who allege sexual abuse, but it is not based on empirical data regarding the likelihood of abuse among children with varying degrees of vulnerability. What's your response to that? A. I believe that's a false statement. Q. Can you explain. A. As I just indicated, there are a variety of ways that we can look at whether or not individuals with particular vulnerabilities are targeted and/or at higher risk for being sexually abused. We can look at the prevalence data, the rates in which these behaviors occur. You can look at both allegations as well as crimes that are reported. You can look at what offenders tell us. There has been extensive interviewing that's been done and studies that have been done with offenders about what they look for. And, again, this would not just be offenders of childhood sexual abuse but, you know, there have been studies done with pimps, for example, on what they look for. So in a variety of forms of victimization. So there are multiple data sources that exist in addition to clinical experience that can substantiate this phenomenon. Q. How does what you've observed in your review of the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007248",
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+      "content": "individuals with particular vulnerabilities are often targeted by sexual abuse is a commonly accepted bit of clinical lore derived from the frequent observation of highly vulnerable children among those children who allege sexual abuse, but it is not based on empirical data regarding the likelihood of abuse among children with varying degrees of vulnerability. What's your response to that? A. I believe that's a false statement. Q. Can you explain. A. As I just indicated, there are a variety of ways that we can look at whether or not individuals with particular vulnerabilities are targeted and/or at higher risk for being sexually abused. We can look at the prevalence data, the rates in which these behaviors occur. You can look at both allegations as well as crimes that are reported. You can look at what offenders tell us. There has been extensive interviewing that's been done and studies that have been done with offenders about what they look for. And, again, this would not just be offenders of childhood sexual abuse but, you know, there have been studies done with pimps, for example, on what they look for. So in a variety of forms of victimization. So there are multiple data sources that exist in addition to clinical experience that can substantiate this phenomenon. Q. How does what you've observed in your review of the",
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results/IMAGES003/DOJ-OGR-00007249.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 70 of 158 70 LBAAMAX3ps Rocchio - Direct literature compare to your clinical practice and your forensic practice with respect to the question of individuals with particular vulnerabilities being at higher risk of childhood sexual abuse? A. It's highly consistent. Q. The defense has argued that a victim's prior sexual behavior is relevant to the concept of grooming. What's your reaction to that? A. In what way? I mean, I've talked about, certainly their experiences of victimization can make them more vulnerable, but I'm not sure what you mean. Q. Does whether a person, whether or not a person has had sexual experience, putting aside prior victimization, make them more or less vulnerable to being groomed? A. I'm not aware of any literature on that issue, nor do I even understand how that would theoretically make sense. To the extent that you're suggesting that somebody who has been sexually active in the past can or cannot be groomed, I'm not, even theoretically, I don't understand why that would be the case. But, no, certainly I don't believe that there is any literature that would support that statement. THE COURT: So to the extent you've seen in your practice and studies the impact of prior sexual conduct on the phenomenon of grooming, you understand it to potentially SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007249",
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+      "content": "literature compare to your clinical practice and your forensic practice with respect to the question of individuals with particular vulnerabilities being at higher risk of childhood sexual abuse? A. It's highly consistent. Q. The defense has argued that a victim's prior sexual behavior is relevant to the concept of grooming. What's your reaction to that? A. In what way? I mean, I've talked about, certainly their experiences of victimization can make them more vulnerable, but I'm not sure what you mean. Q. Does whether a person, whether or not a person has had sexual experience, putting aside prior victimization, make them more or less vulnerable to being groomed? A. I'm not aware of any literature on that issue, nor do I even understand how that would theoretically make sense. To the extent that you're suggesting that somebody who has been sexually active in the past can or cannot be groomed, I'm not, even theoretically, I don't understand why that would be the case. But, no, certainly I don't believe that there is any literature that would support that statement. THE COURT: So to the extent you've seen in your practice and studies the impact of prior sexual conduct on the phenomenon of grooming, you understand it to potentially",
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results/IMAGES003/DOJ-OGR-00007250.json

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+  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 71 of 158 71 LBAAMAX3ps Rocchio - Direct increase the likelihood of grooming or susceptibility to grooming? Do I have that right? THE WITNESS: No. I'm sorry. What increases susceptibility to grooming would be prior victimization. I believe I'm being asked here now about consensual sexual activity. And I'm not aware of any known or studied relationship between consensual sexual activity and grooming. THE COURT: Right. So to the extent prior sexual conduct of any kind that you're aware of impacts grooming, it's that prior victim -- prior victimization, prior subjecting to sexual abuse increases the likelihood of one being susceptible to grooming tactics. THE WITNESS: Can increase the likelihood of being sexually abused later, not necessarily susceptibility to grooming per se, but we know that it increases the likelihood of subsequent victimization. We also know that one of the effects of victimization in and of itself can be an increase in risky behavior. And for adolescents in particular that risky behavior can often take the form of risky sexual behavior. So I think that, to the extent that there might be a relationship between sexual abuse and grooming and sexual behavior, it's actually the inverse of what you've talked about, which is, you might see a lot of high-risk sexual behavior being engaged in, in someone who has been previously SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007250",
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+      "content": "increase the likelihood of grooming or susceptibility to grooming? Do I have that right? THE WITNESS: No. I'm sorry. What increases susceptibility to grooming would be prior victimization. I believe I'm being asked here now about consensual sexual activity. And I'm not aware of any known or studied relationship between consensual sexual activity and grooming. THE COURT: Right. So to the extent prior sexual conduct of any kind that you're aware of impacts grooming, it's that prior victim -- prior victimization, prior subjecting to sexual abuse increases the likelihood of one being susceptible to grooming tactics. THE WITNESS: Can increase the likelihood of being sexually abused later, not necessarily susceptibility to grooming per se, but we know that it increases the likelihood of subsequent victimization. We also know that one of the effects of victimization in and of itself can be an increase in risky behavior. And for adolescents in particular that risky behavior can often take the form of risky sexual behavior. So I think that, to the extent that there might be a relationship between sexual abuse and grooming and sexual behavior, it's actually the inverse of what you've talked about, which is, you might see a lot of high-risk sexual behavior being engaged in, in someone who has been previously",
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