DOJ-OGR-00006346.jpg
Extracted Text (OCR)
Case 1:20-cr-00330-PAE Document 435 Filed 11/11/21 Page5of11
Circuit in United States v. Johnson, 860 F.3d 1133, 1141 (8th Cir. 2017), and the District of
Massachusetts in Doe ex rel. Pike v. Pike, 405 F. Supp. 3d 243, 249 (D. Mass. 2019).
Here, Dr. Rocchio has extensive experience treating minors who have been sexually
abused, and those decades of relevant experience, combined with her formal training, are an
adequate basis for her to testify on methods that perpetrators of sexual abuse often use to build
trust with their victims, whether that be grooming or other forms of manipulation and coercion.
The Government has also provided several articles on the subject of grooming that convince the
Court that it is a well-accepted theory in Dr. Rocchio’s field. Though the Second Circuit has not
ruled on the admissibility of a grooming expert, it has previously recognized the academic
literature on grooming to facilitate sexual abuse of minors. See United States v. Brand, 467 F.3d
179, 203 (2d Cir. 2006). The Defense cites to several contrary articles that suggest experts
disagree on the kinds of behaviors that define grooming. But if experts disagree on the proper
interpretation of evidence, “it is not the Court’s role to resolve the dispute through exclusion of
one of the expert’s opinions.” Jn re Digital Music Antitrust Litig., 321 F.R.D. 64, 80 (S.D.N.Y.
2017).
Moreover, Dr. Rocchio addressed these contrary articles during the Daubert hearing,
identifying points of agreement and disagreement. Based on her testimony, the parties’
submission and accompanying exhibits, the Court concludes that the core concept of grooming is
well-accepted in the relevant literature, even if experts continue to debate the details.
The Defense’s primary argument is that Dr. Rocchio’s method is unreliable because it is
based on her personal experience with the clients she has treated, that Dr. Rocchio did not verify
whether those clients were truthful, and that Dr. Rocchio has not and cannot identify an error
rate. The Court finds that these objections are misplaced in the field of clinical psychology,
DOJ-OGR-00006346
Extracted Information
Dates
Document Details
| Filename | DOJ-OGR-00006346.jpg |
| File Size | 721.9 KB |
| OCR Confidence | 94.3% |
| Has Readable Text | Yes |
| Text Length | 2,137 characters |
| Indexed | 2026-02-03 17:10:08.686646 |