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Extraction Summary

6
People
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Organizations
1
Locations
1
Events
2
Relationships
3
Quotes

Document Information

Type: Legal document
File Size: 646 KB
Summary

This legal document is a motion filed on behalf of Ghislaine Maxwell on October 29, 2021, to exclude the expert testimony of Dr. Lisa M. Rocchio. The motion argues that Dr. Rocchio's opinions on "grooming" are subjective, not based on verifiable scientific methods, and therefore inadmissible under the Federal Rules of Evidence. The defense claims her testimony is an attempt by the government to use a "blind" expert to improperly vouch for the accusers' truthfulness.

People (6)

Name Role Context
Ghislaine Maxwell Defendant
The subject of the legal case, moving to exclude expert testimony.
Lisa M. Rocchio, Ph.D. Proposed expert witness
Her proposed testimony on "grooming" is being challenged in this motion.
Jeffrey Epstein
Mentioned as the beneficiary of Ms. Maxwell's alleged "grooming-by-proxy" of victims.
Natalie Bennett Author
Co-author of a cited article, 'The Construct of Grooming in Child Sexual Abuse'.
William O’Donohue Author
Co-author of a cited article, 'The Construct of Grooming in Child Sexual Abuse'.
Gonyer Defendant
Named in the cited case 'United States v. Gonyer'.

Organizations (1)

Name Type Context
Merrell Dow Pharmaceuticals, Inc. company
A party in the cited case 'Daubert v. Merrell Dow Pharmaceuticals, Inc.'.

Timeline (1 events)

2021-10-29
Ghislaine Maxwell's legal team filed a motion to exclude the proposed testimony of Lisa M. Rocchio.

Locations (1)

Location Context
Mentioned in the citation for 'United States v. Gonyer', referring to the District of Maine.

Relationships (2)

Ghislaine Maxwell co-conspirator (alleged) Jeffrey Epstein
The document alleges that Ms. Maxwell groomed victims 'not for her own benefit but for that of Jeffrey Epstein'.
Ghislaine Maxwell adversarial (legal) Lisa M. Rocchio
Maxwell is filing a motion to exclude Rocchio's testimony in her criminal case.

Key Quotes (3)

"there is no valid method to assess whether grooming has occurred or is occurring."
Source
— Natalie Bennett & William O’Donohue (Quoted from a journal article to argue that 'grooming' is not a verifiable phenomenon.)
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Quote #1
"grooming-by-proxy"
Source
— Lisa M. Rocchio (as described by the motion) (A term used to describe the allegation that Ms. Maxwell groomed victims for Jeffrey Epstein's benefit.)
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Quote #2
"virtually impregnable for purposes of cross-examination."
Source
— United States v. Gonyer case (Quoted from a previous case to describe expert conclusions that cannot be effectively challenged.)
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Quote #3

Full Extracted Text

Complete text extracted from the document (1,786 characters)

Case 1:20-cr-00330-PAE Document 386 Filed 10/29/21 Page 6 of 24
Ghislaine Maxwell moves to exclude the proposed testimony of Lisa M. Rocchio, Ph.D., under Federal Rules of Evidence 401, 402, 403, 404, 702, 704, and Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993).
INTRODUCTION AND SUMMARY OF THE ARGUMENT
The case against Ms. Maxwell is rife with problems. Recognizing them, the government retreats to a familiar tactic: The use of a “blind” expert to fill in the gaps, to explain away the inconsistencies, and to vouch of the truthfulness of the accusers.
The foundation of Lisa M. Rocchio’s proposed expert testimony is so-called “grooming” behavior. But grooming is not a widely recognized or highly predictable and verifiable phenomena. To the contrary, “there is no valid method to assess whether grooming has occurred or is occurring.”¹ What’s more, there is nothing—not a journal article, and not a study—to validate Rocchio’s opinions on “grooming-by-proxy”—i.e., that Ms. Maxwell groomed victims not for her own benefit but for that of Jeffrey Epstein.
Rocchio’s opinions about “grooming” are entirely subjective—they are based on her personal experience treating a self-selected group of people who claim to have been sexually abused and who Rocchio assumes are telling the truth. There are no studies or data to back up her conclusions; they have no associated error rate; they cannot be tested, verified, or reproduced; and they “virtually impregnable for purposes of cross-examination.”² Since “expert
¹ Natalie Bennett & William O’Donohue, The Construct of Grooming in Child Sexual Abuse, 23 J. Child Sexual Abuse 957, 974 (2014).
² United States v. Gonyer, No. 1:12-CR-00021-JAW, 2012 WL 3043020, at *2 (D. Me. July 24, 2012).
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