mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00005810.json

{
  "document_metadata": {
    "page_number": "27",
    "document_number": "397",
    "date": "10/29/21",
    "document_type": "court document",
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  "full_text": "Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 27 of 84\n\n(citation and internal quotation marks omitted)). Dr. Rocchio, however, is not testifying about common experience or from common experience. Her testimony stems from her clinical experience, and it concerns the psychological experiences of victims when a third person is present during parts of their sexual abuse, as part of her broader opinion on attachment and coercion. The average juror will not have knowledge of or experience in the psychology of abuse victims, and Dr. Rocchio's testimony will aid their understanding.\n\nThe defendant relatedly seeks to preclude Dr. Rocchio from testifying about \"grooming-by-proxy,\" a term which appears nowhere in the Government's expert notice. (Def. Mot. 3 at 9). By that term, the defendant appears to argue that Dr. Rocchio will opine that an individual can groom a victim for abuse by another perpetrator, and that such an opinion is unreliable and \"prejudicial speculation.\" (Id.). This argument misses the mark in three respects. First, Dr. Rocchio's testimony primarily concerns the experience of victims, not perpetrators, as explained above. If the victim experienced attachment and grooming, it makes no analytical difference whether the perpetrator intends to engage in sexual contact with the victim or, instead, is preparing the victim for abuse by a third party. See Feb. 25, 2020 Tr. at 31:1-34:12, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335 (explaining that, where there is a \"reliable basis for . . . testi[mony] about trauma bonding and coercive control as phenomena that exist more broadly,\" the expert may testify, and defendants \"are at liberty to vigorously cross-examine [the expert] to attempt to cabin or limit trauma bonding and coercive control to populations predominately outside of the alleged victims in this case\"). Indeed, expert testimony is commonly offered in sex trafficking cases on the pimp-prostitute relationship, which is specifically designed to permit the\n\n26\n\nDOJ-OGR-00005810",
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      "content": "Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 27 of 84",
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      "type": "printed",
      "content": "(citation and internal quotation marks omitted)). Dr. Rocchio, however, is not testifying about common experience or from common experience. Her testimony stems from her clinical experience, and it concerns the psychological experiences of victims when a third person is present during parts of their sexual abuse, as part of her broader opinion on attachment and coercion. The average juror will not have knowledge of or experience in the psychology of abuse victims, and Dr. Rocchio's testimony will aid their understanding.",
      "position": "main body"
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    {
      "type": "printed",
      "content": "The defendant relatedly seeks to preclude Dr. Rocchio from testifying about \"grooming-by-proxy,\" a term which appears nowhere in the Government's expert notice. (Def. Mot. 3 at 9). By that term, the defendant appears to argue that Dr. Rocchio will opine that an individual can groom a victim for abuse by another perpetrator, and that such an opinion is unreliable and \"prejudicial speculation.\" (Id.). This argument misses the mark in three respects. First, Dr. Rocchio's testimony primarily concerns the experience of victims, not perpetrators, as explained above. If the victim experienced attachment and grooming, it makes no analytical difference whether the perpetrator intends to engage in sexual contact with the victim or, instead, is preparing the victim for abuse by a third party. See Feb. 25, 2020 Tr. at 31:1-34:12, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335 (explaining that, where there is a \"reliable basis for . . . testi[mony] about trauma bonding and coercive control as phenomena that exist more broadly,\" the expert may testify, and defendants \"are at liberty to vigorously cross-examine [the expert] to attempt to cabin or limit trauma bonding and coercive control to populations predominately outside of the alleged victims in this case\"). Indeed, expert testimony is commonly offered in sex trafficking cases on the pimp-prostitute relationship, which is specifically designed to permit the",
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      "content": "26",
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    {
      "type": "printed",
      "content": "DOJ-OGR-00005810",
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  "entities": {
    "people": [
      "Dr. Rocchio"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "10/29/21",
      "Feb. 25, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 397",
      "19 Cr. 131 (PAE)",
      "Dkt. No. 335",
      "DOJ-OGR-00005810"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, with a formal tone and legal language. There are no visible redactions or damage to the document."
}