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Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page5of84 ARGUMENT 1. The Court Should Admit the Testimony of Dr. Lisa Rocchio The Government intends to call Dr. Lisa Rocchio as an expert witness. Dr. Rocchio is the President-Elect of the Division of Trauma Psychology at the American Psychological Association. She is currently a clinical instructor at the Alpert Medical School of Brown University, and she has practiced psychology for approximately 25 years, specializing in treating patients with trauma, including sexual trauma in childhood and adolescence. Dr. Rocchio has treated hundreds of victims of trauma, including many victims of child sexual abuse, and she has written, presented, and taught about the assessment and treatment of trauma. She has also received continuing education on trauma and the treatment of trauma in a clinical setting. (See generally Curriculum Vitae, Def. Mot. 3 Ex. 2). On April 23, 2021, the Government timely notified the defendant of its intent to call Dr. Rocchio in its case-in-chief. As the notice explains, Dr. Rocchio is expected to testify, based on her relevant education, training, experience, and research, and offer the following opinions: Individuals with particular vulnerabilities are often targeted by perpetrators of sexual abuse. Sexual abuse of minors frequently occurs through the use of manipulation or coercion in the context of an established relationship that is developed over time, rather than through the use of forcible rape. Minor victims are often subject to a strategic pattern of behaviors, often called grooming, that can take a variety of forms and function to render the victims vulnerable to abuse, to obscure the nature of the abuse, and to build trust and attachment with their abuser. The relationship of trust and attachment can prevent victims from being aware that what they are experiencing is abuse and can prevent disclosure. Minor victims therefore may not identify themselves as victims of abuse while it is ongoing, and may not recognize the consequences of that abuse until adulthood. Repeated exploitation and abuse can increase the likelihood of victimization later in life and can result in long-term 4 DOJ-OGR-00006713