DOJ-OGR-00006728.pdf

--- Page 1 --- **Document Header** * Case Number: 1:20-cr-00330-PAE * Document Number: 452 * Filed Date: 11/12/21 * Page Number: 20 of 84 **Main Text** * (emphasis added): Dr. Rocchio's testimony will also include discussion of techniques used by perpetrators. * Dr. Rocchio's testimony regarding such techniques is supported by Dr. Rocchio's review of the relevant literature, see Exhibit A, and through her clinical work. By virtue of her experience treating victims, Dr. Rocchio is necessarily informed about perpetrators' actions. See Halamek, 5 F.4th at 1088 ("Extensive experience interviewing victims can qualify a person to testify about the relationships those victims tend to have with their abusers."). Dr. Rocchio will testify squarely within her expertise and experience. * b. Relevance and Rule 403 + Dr. Rocchio's opinions will assist the trier of fact in understanding the evidence at trial. + This case concerns an "unusual area of human interaction." See Feb. 25, 2020 Tr. at 39:8-9, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335. The Minor Victims in this case were trafficked over many years, and none were physically restrained. An average juror, with no experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not 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victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to 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Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not 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victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with 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continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not 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victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with sexual abuse victims, may not understand why the Minor Victims continued to experience with 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