mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00007481.json

{
  "document_metadata": {
    "page_number": "16",
    "document_number": "499",
    "date": "11/23/21",
    "document_type": "court document",
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    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 499 Filed 11/23/21 Page 16 of 28\n\npatients are telling the truth when they claim to have been abused. See Ex. 1, p 7 (\"Studies concerning the accurate reporting of alleged sexual assaults undermine the assertions made by Dr. Rocchio to the extent they are based on uncorroborated allegations and are also otherwise relevant here.\"). Because, in Dr. Dietz's opinion, Dr. Rocchio does not make sufficient allowance for the potential that her patients are not telling the truth, the jury is entitled to know how and why that analytical flaw undermines her opinions. As even the government concedes, Mot. at 9, \"the jury, and not the trial court, should decide among the conflicting views of different experts.\" In re Fosamax Prod. Liab. Litig., 645 F. Supp. 2d 164, 173 (S.D.N.Y. 2009) (quoting Kumho Tire Co. v. Carmichael, 526 U.S. 137, 153 (1999)).\n\nMoreover, Dr. Dietz's opinions are directly relevant to evaluate the nature and timing of the disclosures by the alleged victims in this case. As Dr. Rocchio admitted during her testimony at her Daubert hearing, there are numerous reasons why a report of sexual assault might not surface immediately, including the various pathways to a false allegation identified by Dr. Dietz. Ex. 2, p 153-54.\n\nNor are Dr. Dietz's opinions unreliable, as the government claims. Mot. at 20-21. First, Dr. Rocchio essentially admitted they were reliable during her testimony. Ex. 2, p 153-54.\n\nSecond, if Dr. Dietz's reliance on the Engle and O'Donohoe article weren't enough (which it is), Dr. Dietz will testify as well based on his extensive clinical experience. In his own practice, he has personally seen ten of the eleven pathways to false allegations identified by Engle & O'Donohue. Dr. Dietz thus could reliably offer these opinions even if the absence of the article. See Fed. R. Evid. 702, Advisory Committee Notes, 2000 Amendments. (\"Nothing in this [rule] is intended to suggest that experience alone--or experience in conjunction with other knowledge, skill, training or education--may not provide a sufficient foundation for expert\n\n12\n\nDOJ-OGR-00007481",
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      "content": "Case 1:20-cr-00330-PAE Document 499 Filed 11/23/21 Page 16 of 28",
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    {
      "type": "printed",
      "content": "patients are telling the truth when they claim to have been abused. See Ex. 1, p 7 (\"Studies concerning the accurate reporting of alleged sexual assaults undermine the assertions made by Dr. Rocchio to the extent they are based on uncorroborated allegations and are also otherwise relevant here.\"). Because, in Dr. Dietz's opinion, Dr. Rocchio does not make sufficient allowance for the potential that her patients are not telling the truth, the jury is entitled to know how and why that analytical flaw undermines her opinions. As even the government concedes, Mot. at 9, \"the jury, and not the trial court, should decide among the conflicting views of different experts.\" In re Fosamax Prod. Liab. Litig., 645 F. Supp. 2d 164, 173 (S.D.N.Y. 2009) (quoting Kumho Tire Co. v. Carmichael, 526 U.S. 137, 153 (1999)).\n\nMoreover, Dr. Dietz's opinions are directly relevant to evaluate the nature and timing of the disclosures by the alleged victims in this case. As Dr. Rocchio admitted during her testimony at her Daubert hearing, there are numerous reasons why a report of sexual assault might not surface immediately, including the various pathways to a false allegation identified by Dr. Dietz. Ex. 2, p 153-54.\n\nNor are Dr. Dietz's opinions unreliable, as the government claims. Mot. at 20-21. First, Dr. Rocchio essentially admitted they were reliable during her testimony. Ex. 2, p 153-54.\n\nSecond, if Dr. Dietz's reliance on the Engle and O'Donohoe article weren't enough (which it is), Dr. Dietz will testify as well based on his extensive clinical experience. In his own practice, he has personally seen ten of the eleven pathways to false allegations identified by Engle & O'Donohue. Dr. Dietz thus could reliably offer these opinions even if the absence of the article. See Fed. R. Evid. 702, Advisory Committee Notes, 2000 Amendments. (\"Nothing in this [rule] is intended to suggest that experience alone--or experience in conjunction with other knowledge, skill, training or education--may not provide a sufficient foundation for expert",
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      "content": "12",
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      "content": "DOJ-OGR-00007481",
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  "entities": {
    "people": [
      "Dr. Rocchio",
      "Dr. Dietz",
      "Engle",
      "O'Donohue",
      "Carmichael"
    ],
    "organizations": [],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "11/23/21",
      "1999",
      "2000",
      "2009"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 499",
      "Ex. 1",
      "Ex. 2",
      "Mot. at 9",
      "Mot. at 20-21",
      "645 F. Supp. 2d 164",
      "526 U.S. 137",
      "DOJ-OGR-00007481"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, discussing the testimony of expert witnesses Dr. Rocchio and Dr. Dietz. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}