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Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 24 of 52 But that’s not what the government does. Instead, right after claiming that “[c]linical psychologists are not so credulous,” the government essentially says to Ms. Maxwell, “How dare you?” In the government’s words, “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.” Resp. at 16. In this way, and in one breath, the government attests that Rocchio is “not so credulous.” But in the next breath, the government asks this Court to assume that Rocchio “has [not] been misled by hundreds of patients who sought professional treatment for traumatic events that did not occur.” In other words, the government asks this Court to assume Rocchio’s patients are telling the truth, just as Rocchio does. Apparently Rocchio is “so credulous.” But there is no reason this Court should be. 39 66 The government next notes that the term “grooming-by-proxy” “appears nowhere in the Government’s expert notice.” Resp. at 26. That’s hardly surprising, though, because there is no reliable way to assess or analyze if one individual “grooming” a minor to facilitate abuse by someone else, even though that is exactly what the government says Ms. Maxwell did. As detailed today is Ms. Maxwell’s Rule 412 motion, the Indictment alleges “grooming” or “normalization” of sexual behavior by Ms. Maxwell over a dozen times. The government does not, however, contend that Ms. Maxwell “groomed” anyone for her own benefit; instead, the government contends that she “groomed” them for Epstein’s benefit. But as the government does not dispute, there is nothing—not a journal article, and not a study, nothing—to validate Rocchio’s opinions on grooming-by-proxy (even if she doesn’t use that phrase).° ° The articles and cases the government cites involve alleged grooming behavior by the preparator of the abuse, not alleged grooming behavior by a third party. 18 DOJ-OGR-00006904