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Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 31 of 84 traumatic experiences” (second alteration in original)); Raniere, 2019 WL 2212639, at *3, *7 (admitting expert testimony that “disclosure by sexual assault victims often unfolds over time, and the process of disclosure is influenced by multiple and changing factors including, but not limited to, the specific characteristics of the experience, the victim’s psychological vulnerabilities, the victim’s relationship to her perpetrator and her pattern of recovery and coping”); United States v. Young, 623 F. App’x 863, 865-66 (9th Cir. 2015) (“[The expert] testified that . . . delayed disclosures, piecemeal disclosures and/or even recanted disclosures are coping mechanisms. ... [The expert]’s testimony was helpful and probative because [the defendant] had attacked the victims’ credibility based on their delayed and incomplete reports of abuse.” (citations and internal quotation marks omitted)); United States v. Betcher, 534 F.3d 820, 826 (8th Cir. 2008) (“In this case, Dr. Levitt’s testimony as to delayed disclosure helped the jury understand why the girls did not reveal they had been photographed until they were confronted with the images.”). The defendant suggests that Dr. Rocchio’s opinions on delayed disclosure are not helpful to the jury because they are too generic. As set forth here and more fully in Dr. Rocchio’s Jencks Act material, Dr. Rocchio has elaborated on her opinions about the relationship between child sexual abuse and traumatic memory.’ The defendant adds that, because Dr. Rocchio’s opinion is that delayed disclosure is consistent with sexual abuse but not a necessary consequence of sexual abuse, jurors have no means to determine whether a Minor Victim is lying or telling the truth. 7 The defendant also argues that Dr. Rocchio is not an expert in “the human brain or memory generally.” (Def. Mot. 3 at 17). The Government agrees. But Dr. Rocchio is an expert in trauma psychology, which includes related issues of memory. 30 DOJ-OGR-00005814