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Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 20 of 84 (emphasis added)). Dr. Rocchio’s testimony will also include discussion of techniques used by perpetrators. Dr. Rocchio’s testimony regarding such techniques is supported by Dr. Rocchio’s review of the relevant literature, see Exhibit A, and through her clinical work. By virtue of her experience treating victims, Dr. Rocchio is necessarily informed about perpetrators’ actions. See Halamek, 5 F.4th at 1088 (“Extensive experience interviewing victims can qualify a person to testify about the relationships those victims tend to have with their abusers.”). Dr. Rocchio will 3 testify squarely within her expertise and experience. b. Relevance and Rule 403 Dr. Rocchio’s opinions will assist the trier of fact in understanding the evidence at trial. This case concerns an “unusual area of human interaction.” See Feb. 25, 2020 Tr. at 39:8-9, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335. The Minor Victims in this case were trafficked over many years, and none were physically restrained. An average juror, with no experience with sexual abuse victims, may not understand why the Minor Victims continued to 3 In United States v. Raniere, No. 18 Cr. 204 (NGG), 2019 WL 2212639 (E.D.N.Y. May 22, 2019), Judge Garaufis questioned whether an expert on grooming with experience focused on victims may have been able to testify reliably about how “perpetrators often use ‘grooming’ techniques on adult and child victims... .” Jd. at *7. Even then, he did not exclude the testimony—he simply ordered a Daubert hearing. Jd. at *8. The Government ultimately declined to proceed with that testimony rather than conduct a mid-trial Daubert hearing. Here, and as noted above, Dr. Rocchio’s proposed testimony concerns the experience of manipulated and coerced victims, rather than the intentions of perpetrators. 19 DOJ-OGR-00005803