mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00006597.json

{
  "document_metadata": {
    "page_number": "11",
    "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 11 of 24\n\nsexual exploitation of children and possession of child pornography\"). To be sure, the government's notice and Rocchio's CV do not point to a single study, report, or article (peer-reviewed or otherwise) establishing the reliability of her opinions on grooming. To the contrary, a review of grooming literature shows that grooming does not have a consistent definition and \"there is no valid method to assess whether grooming has occurred or is occurring.\" Natalie Bennett & William O'Donohue, The Construct of Grooming in Child Sexual Abuse, 23 J. Child Sexual Abuse 957, 974 (2014).\n\nRocchio's opinions appear to be based on her personal experience as a treatment provider of individuals who claim to have suffered trauma. But an expert basing her opinion solely on experience \"must do more than aver conclusorily that [her] experience led to [her] opinion,\" and she must do more than \"propound a particular interpretation of [a party's] conduct.\" Primavera Familienstifung v. Askin, 130 F. Supp. 2d 450, 530 (S.D.N.Y. 2001).4 An expert relies \"solely or primarily on experience, the witness must explain how that experience leads to the conclusion reached, why that experience is a sufficient basis for the opinion, and how that experience is reliably applied to the facts.\" Fed. R. Evid. 702, Advisory Committee's Note to the 2000 Amendments. Rocchio cannot provide that required explanation here.\n\nFirst, nothing beyond Rocchio's personal opinion corroborates the allegations by her patients. Rocchio simply assumes her patients are telling the truth when they claim they were abused. This assumption fatally undermines the reliability of her opinion because \"[t]here is also no known or identified rate of error to [Rocchio's] conclusion, nor is there a reliable method or a series of factors guiding [Rocchio's] conclusion as to whether an individual victim is fabricating [her] abuse.\" United States v. Schneider, No. CRIM.A. 10-29, 2010 WL 3734055, at *4 (E.D. Pa.\n\n4 Abrogated on other grounds by Casey v. Merck & Co., 653 F.3d 95, 100 (2d Cir. 2011).\n\n6\nDOJ-OGR-00006597",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 443 Filed 11/12/21 Page 11 of 24",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "sexual exploitation of children and possession of child pornography\"). To be sure, the government's notice and Rocchio's CV do not point to a single study, report, or article (peer-reviewed or otherwise) establishing the reliability of her opinions on grooming. To the contrary, a review of grooming literature shows that grooming does not have a consistent definition and \"there is no valid method to assess whether grooming has occurred or is occurring.\" Natalie Bennett & William O'Donohue, The Construct of Grooming in Child Sexual Abuse, 23 J. Child Sexual Abuse 957, 974 (2014).\n\nRocchio's opinions appear to be based on her personal experience as a treatment provider of individuals who claim to have suffered trauma. But an expert basing her opinion solely on experience \"must do more than aver conclusorily that [her] experience led to [her] opinion,\" and she must do more than \"propound a particular interpretation of [a party's] conduct.\" Primavera Familienstifung v. Askin, 130 F. Supp. 2d 450, 530 (S.D.N.Y. 2001).4 An expert relies \"solely or primarily on experience, the witness must explain how that experience leads to the conclusion reached, why that experience is a sufficient basis for the opinion, and how that experience is reliably applied to the facts.\" Fed. R. Evid. 702, Advisory Committee's Note to the 2000 Amendments. Rocchio cannot provide that required explanation here.\n\nFirst, nothing beyond Rocchio's personal opinion corroborates the allegations by her patients. Rocchio simply assumes her patients are telling the truth when they claim they were abused. This assumption fatally undermines the reliability of her opinion because \"[t]here is also no known or identified rate of error to [Rocchio's] conclusion, nor is there a reliable method or a series of factors guiding [Rocchio's] conclusion as to whether an individual victim is fabricating [her] abuse.\" United States v. Schneider, No. CRIM.A. 10-29, 2010 WL 3734055, at *4 (E.D. Pa.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "4 Abrogated on other grounds by Casey v. Merck & Co., 653 F.3d 95, 100 (2d Cir. 2011).",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "6",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006597",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Natalie Bennett",
      "William O'Donohue",
      "Rocchio",
      "Askin",
      "Schneider"
    ],
    "organizations": [
      "Merck & Co."
    ],
    "locations": [
      "S.D.N.Y.",
      "E.D. Pa.",
      "2d Cir."
    ],
    "dates": [
      "11/12/21",
      "2014",
      "2001",
      "2000",
      "2010",
      "2011"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 443",
      "23 J. Child Sexual Abuse 957",
      "130 F. Supp. 2d 450",
      "653 F.3d 95",
      "No. CRIM.A. 10-29",
      "2010 WL 3734055"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving sexual exploitation of children and possession of child pornography. The text discusses the reliability of an expert witness's opinions on grooming and the lack of corroborating evidence. The document includes citations to various court cases and legal references."
}