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Case 1:20-cr-00330-PAE Document670 Filed 06/22/22 Page9of55 This culture of silence provided space for the defendant and Epstein to operate a playbook through which they sexually abused young girls. At trial, Dr. Lisa Rocchio, an expert in psychology with a specialized expertise in traumatic stress and interpersonal violence, explained that children are most frequently sexually abused through grooming and coercion in the context of arelationship. (Tr. 713). Dr. Rocchio explained that abusers use a series of deceptive tactics to engage a child in sexual abuse. (Tr. 715-20). The defendant and Epstein used such tactics throughout the life of the conspiracy. In the early phase of the conspiracy, from at least approximately 1994 through approximately 2001, the defendant identified vulnerable girls, typically from single-mother households and difficult financial circumstances. (PSR § 26). The defendant and Epstein then isolated the girls, spending time with them away from their family and friends. (/d.). During that time, they groomed the girls through techniques such as giving them gifts, pretending to be friends, and building trust. (/d.). The defendant and Epstein then normalized sexual situations and sexual touching. (/d.). Finally, they transitioned to sexual abuse, often through the pretext of giving Epstein a massage. (/d.). This earlier phase required the defendant and Epstein to identify one girl at a time to target for grooming and abuse. In the later phase, from approximately 2001 until at least approximately 2004, the defendant and Epstein developed a scheme that created a constant stream of girls who recruited each other to visit Epstein at his Palm Beach residence. (PSR § 27). This new approach replaced some of the early grooming and trust-building steps with money provided to girls from struggling families. (/d.). Specifically, the defendant and Epstein paid young girls hundreds of dollars in cash in exchange for meeting Epstein to be sexually abused—again, often under the pretext of giving Epstein a massage. (/d.). Once a girl was introduced to these sexualized massages, she was offered more money if she brought other teenage girls to engage in sexualized massages with DOJ-OGR-00010544