DOJ-OGR-00008003.pdf

Case 1:20-cr-00330-PAE Document 499-2 Filed 11/23/21 Page 135 of 159134 LBAAMAX5ps Rocchio - Cross 1 Q. Yes. "The model should undergo rigorous testing to ensure the stages accurately represent the complex process of sexual grooming." Do you see that? 2 A. I do. 3 Q. "Further, a standardized measure of grooming behaviors should be developed based on behaviors and stages delineated in the SGM," which is what they're talking about here. Right? 4 A. Yes. 5 Q. So as we stand here today, there has been no further rigorous testing of this model that you're aware of. Correct? 6 A. There is an enormous amount of testing and scientific study that led up to this particular model. I'm not aware -- I don't -- I can't speak as to whether or not they've done research subsequent to this, no. 7 Q. But even these authors say that this isn't good enough for evidence-based grooming testimony. Right? 8 A. That's not my reading of the paper, no. 9 Q. OK. And you don't -- have you ever asked these authors about their opinion? 10 A. No, I have not. 11 MR. PAGLIUCA: If we can turn to Exhibit 4, please. 12 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 13 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00008003