DOJ-OGR-00006719.jpg

Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page11 of 84 United States v. Raniere, No. 18 Cr. 204 (NGG), 2019 WL 2212639, at *7 (E.D.N.Y. May 22, 2019). Instead, the defendant suggests that Dr. Rocchio’s opinions are unreliable, irrelevant, or prejudicial. To the contrary, and as explained in greater detail below, each of the Dr. Rocchio’s five challenged opinions is well supported and would aid the jury in understanding the evidence at trial. The Court should permit Dr. Rocchio to testify. 1. Dr. Rocchio’s Opinions on Coercion and Attachment are Admissible a. Reliability As described in the expert notice, Dr. Rocchio will testify about the role that trust and attachment play in relationships between a victim and an abuser: 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. (Expert Notice, Def. Mot. 3 Ex. 1 at 2). Dr. Rocchio will opine that victims are often abused in the context of a coercive and manipulative relationship which develops over time through the building of victims’ trust and attachment. One aspect of this relationship is “often called grooming.” (Def. Mot. 3 Ex. 1 at 2). However, the concepts of attachment and coercion go beyond grooming, and encompass both the trust-building aspect of the relationship and the ways in which 10 DOJ-OGR-00006719