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Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page17 of 84 patients are telling the truth.” (Def. Mot. 3 at 6). The defendant claims that this “fatally undermines the reliability of her opinion” because her conclusion has “no known or identified rate of error... nor is there a reliable method or a series of factors guiding Rocchio’s conclusion as to whether an individual victim is fabricating her abuse.” (/d. (alterations and quotation marks omitted)). Clinical psychologists are not so credulous. As part of Dr. Rocchio’s work as a practicing clinician, she examines consistencies and inconsistencies in the information provided by patients and assesses patient self-reporting in the context of literature and knowledge that she has developed in her years of practice. As the Government’s expert notice makes clear, Dr. Rocchio has treated hundreds and hundreds of patients in her decades of experience, and her opinions are based in part on the significant patterns she has observed among the patients she has treated. The Court should reject the defendant’s speculative claim that Dr. Rocchio has been misled by hundreds of patients who sought professional treatment for traumatic events that did not occur. In any event, the defendant’s argument about error rates misunderstands the nature of a Daubert inquiry. An error rate is but one of the Daubert factors that may or may not be applicable in every case. See Romano, 794 F.3d at 330. And in cases such as this, where a social science expert is testifying based on qualitative methodology, that factor is inapplicable. See Torres, 2021 WL 1947503, at *6n.8. As the Second Circuit has explained, “Peer review, publication, potential error rate, etc... . are not applicable to this kind of testimony, whose reliability depends heavily on the knowledge and experience of the expert, rather than the methodology or theory behind it. In such cases, the place to quibble with [an expert’s] academic training is on cross-examination . . . 16 DOJ-OGR-00006725