mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00006596.json

{
  "document_metadata": {
    "page_number": "10",
    "document_number": "443",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 443 Filed 11/12/21 Page 10 of 24\nelement of the crime charged or of a defense\" because those \"matters are for the trier of fact\nalone.\" Fed R. Evid. 704(b).\nRule 403 demands exclusion when the probative value of evidence is substantially\noutweighed by the danger of unfair prejudice or misleading the jury. Fed. R. Evid. 403.\nAnd Rule 404 prohibits any witness, witness or lay, from offering evidence \"of a person's\ncharacter or character trait . . . to prove that on a particular occasion the person acted in\naccordance with the character or trait.\" Fed. R. Evid. 404(a)(1).\nApplying these provisions, and as elaborated below, each of Rocchio's opinions is\ninadmissible.\n\nA. Opinion 1: Minor victims are often subject to a strategic pattern of\nbehaviors, often called grooming, that can take a variety of forms and\nfunction to render the victims vulnerable to abuse, to obscure the nature\nof the abuse, and to build trust and attachment with their abuser.\n\n1. Rocchio's grooming opinions are unreliable.\nRocchio's first and most prominent proposed area of testimony concerns \"grooming,\"\nwhich she characterizes as \"a strategic pattern of behavior[] . . . that can take a variety of forms\nand function to render the victims vulnerable to abuse, to obscure the nature of the abuse, and to\nbuild trust and attachment with their abuser.\" Ex. 1, p 2. Rocchio continues that \"[i]ndividuals\nwith particular vulnerabilities are often targeted [through grooming] by perpetrators of sexual\nabuse\" and that \"[s]exual abuse of minors frequently occurs through the use of manipulation or\ncoercion in the context of an established relationship that is developed over time, rather than\nthrough the use of forcible rape.\" Id.\nThese opinions on grooming are not based \"on scientific research or data.\" Gonyer, 2012\nWL 3043020, at *2 (granting defendant's motion to preclude evidence from the government's\n\"expert on sexual predator grooming techniques in its case-in-chief in a jury trial on charges of",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 443 Filed 11/12/21 Page 10 of 24",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "element of the crime charged or of a defense\" because those \"matters are for the trier of fact\nalone.\" Fed R. Evid. 704(b).\nRule 403 demands exclusion when the probative value of evidence is substantially\noutweighed by the danger of unfair prejudice or misleading the jury. Fed. R. Evid. 403.\nAnd Rule 404 prohibits any witness, witness or lay, from offering evidence \"of a person's\ncharacter or character trait . . . to prove that on a particular occasion the person acted in\naccordance with the character or trait.\" Fed. R. Evid. 404(a)(1).\nApplying these provisions, and as elaborated below, each of Rocchio's opinions is\ninadmissible.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "A. Opinion 1: Minor victims are often subject to a strategic pattern of\nbehaviors, often called grooming, that can take a variety of forms and\nfunction to render the victims vulnerable to abuse, to obscure the nature\nof the abuse, and to build trust and attachment with their abuser.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1. Rocchio's grooming opinions are unreliable.\nRocchio's first and most prominent proposed area of testimony concerns \"grooming,\"\nwhich she characterizes as \"a strategic pattern of behavior[] . . . that can take a variety of forms\nand function to render the victims vulnerable to abuse, to obscure the nature of the abuse, and to\nbuild trust and attachment with their abuser.\" Ex. 1, p 2. Rocchio continues that \"[i]ndividuals\nwith particular vulnerabilities are often targeted [through grooming] by perpetrators of sexual\nabuse\" and that \"[s]exual abuse of minors frequently occurs through the use of manipulation or\ncoercion in the context of an established relationship that is developed over time, rather than\nthrough the use of forcible rape.\" Id.\nThese opinions on grooming are not based \"on scientific research or data.\" Gonyer, 2012\nWL 3043020, at *2 (granting defendant's motion to preclude evidence from the government's\n\"expert on sexual predator grooming techniques in its case-in-chief in a jury trial on charges of",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "5",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006596",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Rocchio"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "11/12/21",
      "2012"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 443",
      "Ex. 1, p 2",
      "Gonyer, 2012 WL 3043020"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, discussing the admissibility of expert testimony regarding 'grooming' in the context of sexual abuse of minors. The text is printed and there are no visible stamps or handwritten notes."
}