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  "full_text": "Case 1:20-cr-00330-PAE Document 499-2 Filed 11/23/21 Page 156 of 159\nLBAAMAX5ps\nRocchio - Cross\n1 you.\n2 MR. PAGLIUCA: OK.\n3 THE COURT: Try that.\n4 MR. PAGLIUCA: All right.\n5 THE COURT: Thank you.\n6 Q. What is the study that you are relying on for your opinions about whether -- that has been tested here?\n7 A. There is no single study that I'm relying upon for my opinion.\n8 Q. OK. And what is the known potential rate of error for any of your opinions?\n9 A. It would depend on what you're -- how you're defining \"error.\" So, for example, in the study where they had a bunch of professionals identify, for example, the relevance of particular behaviors to grooming, in that particular study, they looked for, I think the standard in the field was a .78 statistical significance or measure of agreement. So different studies use different measures. There are other studies that looked at inter-rater reliability. In other words, if someone is coding the content of a qualitative interview that's been done, they'll look at the degree of agreement and of course potential disagreement, which would be error, in differences of opinion, and attempt to address and resolve those.\n10 But, as I had indicated earlier, in this field, a pure error rate, as in many areas of the social sciences, cannot be\n11 SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00008024",
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      "content": "LBAAMAX5ps\nRocchio - Cross",
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      "content": "1 you.\n2 MR. PAGLIUCA: OK.\n3 THE COURT: Try that.\n4 MR. PAGLIUCA: All right.\n5 THE COURT: Thank you.\n6 Q. What is the study that you are relying on for your opinions about whether -- that has been tested here?\n7 A. There is no single study that I'm relying upon for my opinion.\n8 Q. OK. And what is the known potential rate of error for any of your opinions?\n9 A. It would depend on what you're -- how you're defining \"error.\" So, for example, in the study where they had a bunch of professionals identify, for example, the relevance of particular behaviors to grooming, in that particular study, they looked for, I think the standard in the field was a .78 statistical significance or measure of agreement. So different studies use different measures. There are other studies that looked at inter-rater reliability. In other words, if someone is coding the content of a qualitative interview that's been done, they'll look at the degree of agreement and of course potential disagreement, which would be error, in differences of opinion, and attempt to address and resolve those.\n10 But, as I had indicated earlier, in this field, a pure error rate, as in many areas of the social sciences, cannot be",
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