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Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 5 of 84

ARGUMENT

I. The Court Should Admit the Testimony of Dr. Lisa Rocchio

The Government intends to call Dr. Lisa Rocchio as an expert witness. Dr. Rocchio is the
President-Elect of the Division of Trauma Psychology at the American Psychological Association.
She is currently a clinical instructor at the Alpert Medical School of Brown University, and she
has practiced psychology for approximately 25 years, specializing in treating patients with trauma,
including sexual trauma in childhood and adolescence. Dr. Rocchio has treated hundreds of
victims of trauma, including many victims of child sexual abuse, and she has written, presented,
and taught about the assessment and treatment of trauma. She has also received continuing
education on trauma and the treatment of trauma in a clinical setting. (See generally Curriculum
Vitae, Def. Mot. 3 Ex. 2).

On April 23, 2021, the Government timely notified the defendant of its intent to call Dr.
Rocchio in its case-in-chief. As the notice explains, Dr. Rocchio is expected to testify, based on
her relevant education, training, experience, and research, and offer the following opinions:

Individuals with particular vulnerabilities are often targeted by
perpetrators of sexual abuse. Sexual abuse of minors frequently
occurs through the use of manipulation or coercion in the context of
an established relationship that is developed over time, rather than
through the use of forcible rape. Minor victims are often subject to
a strategic pattern of behaviors, often called grooming, that can take
a variety of forms and function to render the victims vulnerable to
abuse, to obscure the nature of the abuse, and to build trust and
attachment with their abuser. The relationship of trust and
attachment can prevent victims from being aware that what they are
experiencing is abuse and can prevent disclosure. Minor victims
therefore may not identify themselves as victims of abuse while it is
ongoing, and may not recognize the consequences of that abuse until
adulthood. Repeated exploitation and abuse can increase the
likelihood of victimization later in life and can result in long-term
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