DOJ-OGR-00015013.jpg

Case 1:20-cr-00330-PAE Document 782 Filed 01/15/25 Page 137 of 158 137 LBAAMAX5ps Rocchio - Cross 1 would be various stages in the pimp and prostitute literature 2 that are analogous to this. So, for example, how victims are 3 targeted and selected, how the relationship develops over time, 4 what sorts of behaviors are done to influence and coerce, and 5 then to develop that trauma bond and attachment, which may get 6 harder, for example, tactics that involve isolation and 7 increased dependency and things like that. 8 THE COURT: Do you have a sense, is the state of the 9 literature on that subject more settled or more advanced than 10 it is on the concept of grooming in child sexual abuse? 11 THE WITNESS: , 'm not sure that I can answer that. 12 [ think it's analogous literature. They're talking about the 13 same things, so I'm not -- I can't comment on that area of the 14 literature specifically. 15 THE COURT: Go ahead. 16 MR. PAGLIUCA: Thank you, your Honor. 17 Ms. Drescher, if you could pull up Exhibit 5 for me, 18 please. 19 Q. This is the article that you talked about by Dr. Dietz. 20 And, again, Dr. Dietz wrote this in 2017, published in 2018. 21 Is that right? 22 A. Yes. 23 QO. And Dr. Dietz warns, on page 31, that "there is 24 considerable risk of misleading the fact finder into believing 25 that these latter behaviors are well-established predictors of SOUTHERN D STR (212) CT REPORTERS, P.C. 805-0300 DOJ-OGR-00015013