DOJ-OGR-00005811.pdf

--- Page 1 --- **Document Header** * **Case Number:** 1:20-cr-00330-PAE * **Document Number:** 397 * **Filed Date:** 10/29/21 * **Page Number:** 28 of 84 **Text Content** * **Paragraph 1:** + "pimp to arrange sex acts for third parties." + "See, e.g., Kidd, 385 F. Supp. 3d at 263; Oct. 17, 2019" + "Tr. at 27:1-12, United States v. Dupigny, No. 18 Cr. 528 (JMF) (S.D.N.Y.), Dkt. No. 198." + "Second, in any event, the Government did not provide expert notice on 'grooming by proxy.'" + "Dr. Rocchio will give an opinion on grooming, and she will discuss how '[t]he presence of other individuals can facilitate the sexual abuse of minors.'" + "(Expert Notice, Def. Mot. 3 Ex. 1 at 2)." + "The former is a reliable opinion, as explained above, and the defendant does not challenge the reliability of the latter opinion." + "(See Def. Mot. 3 at 14)." + "Third, trial testimony will show that the defendant (1) in fact participated in sexual abuse of minors, (2) facilitated that abuse through her presence, and (3) conspired with a predator who groomed and sexually abused minors." + "None of that involves 'grooming by proxy.'" * **Paragraph 2:** + "5. Dr. Rocchio's Opinion on Delayed Disclosure is Admissible" + "Finally, Dr. Rocchio will offer the opinion that 'nondisclosure, incremental disclosure, and secrecy are common among victims of sexual abuse for a variety of reasons, and that memory and disclosure of traumatic or abusive events is impacted by a number of factors, including the circumstances surrounding the trauma.'" + "(Def. Mot. 3 Ex. 1 at 2)." + "Much of the basis for this opinion is set forth in Dr. Rocchio's Jencks Act material." + "For instance, extensive psychological literature supports the idea that individuals who are harmed as children may come to disclose their experiences incrementally or not until much later, as they may only realize that their experiences were abusive later in life, among other reasons." + "Selected articles from that literature are attached as Exhibit B." + "See Alaggia et al., 'Facilitators and Barriers to Child Sexual Abuse (CSA) Disclosures: A Research Update (2000-2016),' 20 Trauma, Violence & Abuse 260, 276 (2016) ('Disclosure is now generally accepted as a complex and lifelong process,' 27" **Footer** * **Document ID:** DOJ-OGR-00005811