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Case 1:20-cr-00330-PAE Document 443 Filed 11/12/21 Page17 of 24 B. Opinion 2: The relationship of trust and attachment between an alleged perpetrator and alleged victim prevents victims from being aware that what they are experiencing is abuse and can prevent disclosure. Rocchio’s second opinion—that the relationship of trust and attachment between an alleged perpetrator and alleged victim prevents victims from being aware that what they are experiencing is abuse and can prevent disclosure—has several flaws that render it inadmissible. First, the opinion is unreliable, because it is, in reality, an opinion about grooming disguised as an opinion about delayed disclosure. In Rocchio’s view, alleged victims delay or fail to disclose alleged abuse because they were groomed. But because Rocchio’s proposed grooming testimony is unreliable, not helpful to the trier of fact, and unfairly prejudicial (for all the reasons given above, supra Part 1.a-1.c), so too is this opinion unreliable, not helpful to the trier of fact, and unfairly prejudicial. To reiterate, Rocchio’s opinions are based on her personal experience as a treatment provider. She assumes her clients are telling the truth, and her clients are a self-selected group of alleged victims. Rocchio cannot cite an error rate for her conclusions, nor can she say how representative her patients are of those who suffer sexual abuse. See E.E.O.C., 2010 WL 3466370, at *14 (exclusion of an expert is required where the expert makes “no effort to ensure that the materials he reviewed were representative”). Her conclusions cannot be tested or verified, and they are “virtually impregnable for purposes of cross-examination.” Gonyer, 2012 WL 3043020, at *2. Second, Rocchio apparently has no experience treating alleged perpetrators. So her view of the “relationship of trust and attachment between an alleged perpetrator and alleged victim” is entirely one-sided. See Schneider, 2010 WL 3734055, at *2-3. The second opinion Rocchio proposes to offer is outside her expertise. {2 DOJ-OGR-00006603