mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00015010.json

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    "page_number": "134",
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    "date": "01/15/25",
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  "full_text": "Case 1:20-cr-00330-PAE Document 782 Filed 01/15/25 Page 134 of 158 134 LBAAMAX5ps Rocchio - Cross\n1 Q. Yes. \"The model should undergo rigorous testing to ensure the stages accurately represent the complex process of sexual grooming.\" Do you see that?\n2 A. I do.\n3 Q. \"Further, a standardized measure of grooming behaviors should be developed based on behaviors and stages delineated in the SGM,\" which is what they're talking about here. Right?\n4 A. Yes.\n5 Q. So as we stand here today, there has been no further rigorous testing of this model that you're aware of. Correct?\n6 A. There is an enormous amount of testing and scientific study that led up to this particular model. I'm not aware -- I don't -- I can't speak as to whether or not they've done research subsequent to this, no.\n7 Q. But even these authors say that this isn't good enough for evidence-based grooming testimony. Right?\n8 A. That's not my reading of the paper, no.\n9 Q. OK. And you don't -- have you ever asked these authors about their opinion?\n10 A. No, I have not.\n11 MR. PAGLIUCA: If we can turn to Exhibit 4, please.\n12 Q. I'm not going to spend a lot of time on this. You've talked about it. This is the Bennett and O'Donohue opinions, or article, in which Bennett and O'Donohue say that there's a lack of consensus regarding what grooming is and talk about it\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00015010",
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      "content": "1 Q. Yes. \"The model should undergo rigorous testing to ensure the stages accurately represent the complex process of sexual grooming.\" Do you see that?\n2 A. I do.\n3 Q. \"Further, a standardized measure of grooming behaviors should be developed based on behaviors and stages delineated in the SGM,\" which is what they're talking about here. Right?\n4 A. Yes.\n5 Q. So as we stand here today, there has been no further rigorous testing of this model that you're aware of. Correct?\n6 A. There is an enormous amount of testing and scientific study that led up to this particular model. I'm not aware -- I don't -- I can't speak as to whether or not they've done research subsequent to this, no.\n7 Q. But even these authors say that this isn't good enough for evidence-based grooming testimony. Right?\n8 A. That's not my reading of the paper, no.\n9 Q. OK. And you don't -- have you ever asked these authors about their opinion?\n10 A. No, I have not.\n11 MR. PAGLIUCA: If we can turn to Exhibit 4, please.\n12 Q. I'm not going to spend a lot of time on this. You've talked about it. This is the Bennett and O'Donohue opinions, or article, in which Bennett and O'Donohue say that there's a lack of consensus regarding what grooming is and talk about it",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00015010",
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  "entities": {
    "people": [
      "Rocchio",
      "PAGLIUCA",
      "Bennett",
      "O'Donohue"
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      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "01/15/25"
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      "1:20-cr-00330-PAE",
      "782",
      "DOJ-OGR-00015010"
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