mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00007313.json

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    "page_number": "134",
    "document_number": "467",
    "date": "11/15/21",
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  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 134 of 158 134 LBAAMAX5ps Rocchio - Cross 1 Q. Yes. \"The model should undergo rigorous testing to ensure the stages accurately represent the complex process of sexual grooming.\" Do you see that? 2 A. I do. 3 Q. \"Further, a standardized measure of grooming behaviors should be developed based on behaviors and stages delineated in the SGM,\" which is what they're talking about here. Right? 4 A. Yes. 5 Q. So as we stand here today, there has been no further rigorous testing of this model that you're aware of. Correct? 6 A. There is an enormous amount of testing and scientific study that led up to this particular model. I'm not aware -- I don't -- I can't speak as to whether or not they've done research subsequent to this, no. 7 Q. But even these authors say that this isn't good enough for evidence-based grooming testimony. Right? 8 A. That's not my reading of the paper, no. 9 Q. OK. And you don't -- have you ever asked these authors about their opinion? 10 A. No, I have not. 11 MR. PAGLIUCA: If we can turn to Exhibit 4, please. 12 Q. I'm not going to spend a lot of time on this. You've talked about it. This is the Bennett and O'Donohue opinions, or article, in which Bennett and O'Donohue say that there's a lack of consensus regarding what grooming is and talk about it 13 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007313",
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      "content": "1 Q. Yes. \"The model should undergo rigorous testing to ensure the stages accurately represent the complex process of sexual grooming.\" Do you see that? 2 A. I do. 3 Q. \"Further, a standardized measure of grooming behaviors should be developed based on behaviors and stages delineated in the SGM,\" which is what they're talking about here. Right? 4 A. Yes. 5 Q. So as we stand here today, there has been no further rigorous testing of this model that you're aware of. Correct? 6 A. There is an enormous amount of testing and scientific study that led up to this particular model. I'm not aware -- I don't -- I can't speak as to whether or not they've done research subsequent to this, no. 7 Q. But even these authors say that this isn't good enough for evidence-based grooming testimony. Right? 8 A. That's not my reading of the paper, no. 9 Q. OK. And you don't -- have you ever asked these authors about their opinion? 10 A. No, I have not. 11 MR. PAGLIUCA: If we can turn to Exhibit 4, please. 12 Q. I'm not going to spend a lot of time on this. You've talked about it. This is the Bennett and O'Donohue opinions, or article, in which Bennett and O'Donohue say that there's a lack of consensus regarding what grooming is and talk about it",
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  "entities": {
    "people": [
      "Rocchio",
      "Pagliuca",
      "Bennett",
      "O'Donohue"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "11/15/21"
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      "1:20-cr-00330-PAE",
      "Document 467",
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      "DOJ-OGR-00007313"
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