mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00005644.json

{
  "document_metadata": {
    "page_number": "20 of 24",
    "document_number": "386",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 386 Filed 10/29/21 Page 20 of 24\n\nE. Opinion 5: Nondisclosure, incremental disclosure, and secrecy are common among victims of sexual abuse for a variety of reasons, and that memory and disclosure of traumatic or abusive events is impacted by a number of factors, including the circumstances surrounding the trauma\n\nThere are several problems with Rocchio's proposed testimony that \"nondisclosure, incremental disclosure, and secrecy are common among victims of sexual abuse for a variety of reasons, and that memory and disclosure of traumatic or abusive events is impacted by a number of factors, including the circumstances surrounding the trauma.\"\n\nThe first half of this opinion—regarding nondisclosure, incremental disclosure, or late disclosure—is unreliable because the alleged connection \"between child sexual abuse and a failure to report . . . is not a testable hypothesis.\" Schneider, 2010 WL 3734055, at *4. Rocchio offers no data or analyses to support her conclusion, Ex. 1, and she formed her subjective opinion based entirely on her treatment of a self-selected group of individuals she assumes are telling the truth, Schneider, 2010 WL 3734055, at *4 (\"Indeed, Edelman testifies that when her clinical patients tell her they have been subjected to sexual abuse, she unequivocally believes them.\"). \"There 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 or has simply delayed reporting such abuse.\" See id. And because Rocchio's experience is apparently \"limited to providing therapy for those child victims who have reported their abuse,\" Rocchio is in no position \"reliably opine as to the characteristics or psychology of victims who maintain their silence.\" See id. Rocchio's testimony, therefore, \"cannot be challenged or tested in any meaningful way.\" Id. Her opinions are unreliable and inadmissible.\n\nRocchio's testimony also \"will [not] help the trier of fact to understand the evidence or to determine a fact in issue.\" Fed. R. Evid. 702(a). Rocchio's opinions on disclosure are so generic",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 386 Filed 10/29/21 Page 20 of 24",
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    {
      "type": "printed",
      "content": "E. Opinion 5: Nondisclosure, incremental disclosure, and secrecy are common among victims of sexual abuse for a variety of reasons, and that memory and disclosure of traumatic or abusive events is impacted by a number of factors, including the circumstances surrounding the trauma",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "There are several problems with Rocchio's proposed testimony that \"nondisclosure, incremental disclosure, and secrecy are common among victims of sexual abuse for a variety of reasons, and that memory and disclosure of traumatic or abusive events is impacted by a number of factors, including the circumstances surrounding the trauma.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The first half of this opinion—regarding nondisclosure, incremental disclosure, or late disclosure—is unreliable because the alleged connection \"between child sexual abuse and a failure to report . . . is not a testable hypothesis.\" Schneider, 2010 WL 3734055, at *4. Rocchio offers no data or analyses to support her conclusion, Ex. 1, and she formed her subjective opinion based entirely on her treatment of a self-selected group of individuals she assumes are telling the truth, Schneider, 2010 WL 3734055, at *4 (\"Indeed, Edelman testifies that when her clinical patients tell her they have been subjected to sexual abuse, she unequivocally believes them.\"). \"There 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 or has simply delayed reporting such abuse.\" See id. And because Rocchio's experience is apparently \"limited to providing therapy for those child victims who have reported their abuse,\" Rocchio is in no position \"reliably opine as to the characteristics or psychology of victims who maintain their silence.\" See id. Rocchio's testimony, therefore, \"cannot be challenged or tested in any meaningful way.\" Id. Her opinions are unreliable and inadmissible.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Rocchio's testimony also \"will [not] help the trier of fact to understand the evidence or to determine a fact in issue.\" Fed. R. Evid. 702(a). Rocchio's opinions on disclosure are so generic",
      "position": "bottom"
    }
  ],
  "entities": {
    "people": [
      "Rocchio",
      "Edelman",
      "Schneider"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "10/29/21",
      "2010"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 386",
      "2010 WL 3734055"
    ]
  },
  "additional_notes": "The document appears to be a court filing discussing the admissibility of expert testimony in a sexual abuse case. The text is printed and there are no visible stamps or handwritten notes."
}