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be N Ww ws Oo OY ~] oO Ke) a fan) = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 1:20-cr-00330-PAE LBAAMAX5ps en Yes. the stages grooming." A. Ido. Os "Further, should be developed based on behaviors and st the SGM," which is what they're talking about A. Yes. Document 499-2 Filed 11/23/21 Rocchio - Cross Page 135 of 159134 "The model should undergo rigorous testing to ensure accurat Do you see that? a standardized measure of Q. So as we stand here today, rigorous t A. There is an enormous amount of that led u don't -- esting of p to this model can' this particular model. ly represent the complex process of sexual fF grooming behaviors in there has been no tages delineated here. that you're aware of. I'm not aware -- Right? further Correct? testing and scientific study t speak as to whether or not they've done research subsequent to this, no. Q. But even these authors say that this isn't good enough for vidence-based grooming testimony. Right? A. That's not my reading of the paper, no. Q. OK. And you don't —- have you ever asked these authors about their opinion? A. No, I have not. MR. PAGLIUCA: If we can turn to Exhibit 4, please. Q. I'm not going to spend a lot of time on this. You've talked about it. This is the Bennett and O'Donohue opinions, or article , in which Bennett and O'] Donohue say that there's a lack of consensus regarding what grooming is and talk about it SOUTH ERN D STR CT R (212) 805 EPORTERS, P.C. -—0300 DOJ-OGR-00008003