mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00006593.json

{
  "document_metadata": {
    "page_number": "7",
    "document_number": "443",
    "date": "11/12/21",
    "document_type": "court document",
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  "full_text": "Case 1:20-cr-00330-PAE Document 443 Filed 11/12/21 Page 7 of 24\nevidence can be both powerful and quite misleading because of the difficulty in evaluating it,\"3 and for all the other reasons given below, this Court should preclude Rocchio from testifying.\n\nFACTUAL BACKGROUND\n\nThe government has endorsed Rocchio as an expert witness. EXHIBIT 1. Although the government says that Rocchio is a \"clinical instructor of psychiatry and human behavior,\" the government's notice does not say in what specialty it proposes this Court endorse her. Id. at 1-3.\n\nInstead, the government broadly asserts that Rocchio has \"treated patients with trauma, including sexual trauma in childhood and adolescence,\" has \"received specialized training in traumatic stress, sexual abuse, and clinical and forensic psychology,\" and has \"written, presented, and taught about the assessment and treatment of trauma, among other topics.\" Id. at 1-2.\n\nAccording to the government, Rocchio intends to testify on the following topics:\n\nIndividuals with particular vulnerabilities are often targeted by perpetrators of sexual abuse. Sexual abuse of minors frequently occurs through the use of manipulation or coercion in the context of an established relationship that is developed over time, rather than through the use of forcible rape. Minor victims are often subject to a strategic pattern of behaviors, often called grooming, that can take a variety of forms and function to render the victims vulnerable to abuse, to obscure the nature of the abuse, and to build trust and attachment with their abuser. The relationship of trust and attachment can prevent victims from being aware that what they are experiencing is abuse and can prevent disclosure. Minor victims therefore may not identify themselves as victims of abuse while it is ongoing, and may not recognize the consequences of that abuse until adulthood. Repeated exploitation and abuse can increase the likelihood of victimization later in life and can result in long-term traumatic and psychological consequences, especially when it occurs in the context of complex trauma. The presence of other individuals can facilitate the sexual abuse of minors. Dr. Rocchio is also expected to testify 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. Dr. Rocchio has not evaluated any specific victim in this case, and the\n3 Daubert v. Merrell Dow Phar., Inc., 509 U.S. 579, 595 (1993).",
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      "content": "Case 1:20-cr-00330-PAE Document 443 Filed 11/12/21 Page 7 of 24",
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    {
      "type": "printed",
      "content": "evidence can be both powerful and quite misleading because of the difficulty in evaluating it,\"3 and for all the other reasons given below, this Court should preclude Rocchio from testifying.",
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    {
      "type": "printed",
      "content": "FACTUAL BACKGROUND",
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      "content": "The government has endorsed Rocchio as an expert witness. EXHIBIT 1. Although the government says that Rocchio is a \"clinical instructor of psychiatry and human behavior,\" the government's notice does not say in what specialty it proposes this Court endorse her. Id. at 1-3.",
      "position": "middle"
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    {
      "type": "printed",
      "content": "Instead, the government broadly asserts that Rocchio has \"treated patients with trauma, including sexual trauma in childhood and adolescence,\" has \"received specialized training in traumatic stress, sexual abuse, and clinical and forensic psychology,\" and has \"written, presented, and taught about the assessment and treatment of trauma, among other topics.\" Id. at 1-2.",
      "position": "middle"
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    {
      "type": "printed",
      "content": "According to the government, Rocchio intends to testify on the following topics:",
      "position": "middle"
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    {
      "type": "printed",
      "content": "Individuals with particular vulnerabilities are often targeted by perpetrators of sexual abuse. Sexual abuse of minors frequently occurs through the use of manipulation or coercion in the context of an established relationship that is developed over time, rather than through the use of forcible rape. Minor victims are often subject to a strategic pattern of behaviors, often called grooming, that can take a variety of forms and function to render the victims vulnerable to abuse, to obscure the nature of the abuse, and to build trust and attachment with their abuser. The relationship of trust and attachment can prevent victims from being aware that what they are experiencing is abuse and can prevent disclosure. Minor victims therefore may not identify themselves as victims of abuse while it is ongoing, and may not recognize the consequences of that abuse until adulthood. Repeated exploitation and abuse can increase the likelihood of victimization later in life and can result in long-term traumatic and psychological consequences, especially when it occurs in the context of complex trauma. The presence of other individuals can facilitate the sexual abuse of minors. Dr. Rocchio is also expected to testify 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. Dr. Rocchio has not evaluated any specific victim in this case, and the",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3 Daubert v. Merrell Dow Phar., Inc., 509 U.S. 579, 595 (1993).",
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  "entities": {
    "people": [
      "Rocchio"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "11/12/21",
      "1993"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 443"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and easy to read."
}