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611 KB

Extraction Summary

6
People
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Organizations
2
Locations
5
Events
2
Relationships
4
Quotes

Document Information

Type: Legal filing (court document)
File Size: 611 KB
Summary

This legal filing (Document 397 in Case 1:20-cr-00330-PAE) argues for the admissibility of expert testimony regarding sex trafficking, coercive control, and the psychological relationship between pimps and victims. It cites several precedents (Kelly, Torres, Randall, Dupigny) where such testimony was permitted. Specifically, it defends the qualifications of Dr. Rocchio, a Brown University professor with 25 years of clinical experience, noting that the defendant does not contest her expertise.

People (6)

Name Role Context
Dr. Rocchio Expert Witness
Described as a leader in her field, professor at Brown University, with 25 years of clinical experience treating trau...
The Defendant Defendant
Implied to be Ghislaine Maxwell (Case 1:20-cr-00330). The text notes she does not contest Dr. Rocchio's qualifications.
Kelly Defendant in cited case
United States v. Kelly
Torres Defendant in cited case
United States v. Torres
Randall Defendant in cited case
United States v. Randall
Dupigny Defendant in cited case
United States v. Dupigny

Organizations (3)

Name Type Context
Brown University
Employer of expert witness Dr. Rocchio.
District Court
Referencing rulings in S.D.N.Y. and E.D.N.Y.
Department of Justice (DOJ)
Indicated by Bates stamp DOJ-OGR-00005793.

Timeline (5 events)

2019-10-17
Transcript in United States v. Dupigny
S.D.N.Y.
2020-02-25
Transcript in United States v. Randall
S.D.N.Y.
2021-05-13
Ruling in United States v. Torres
S.D.N.Y.
2021-07-23
Letter filed in United States v. Kelly
E.D.N.Y.
2021-10-29
Document Filed
Court

Locations (2)

Location Context
Southern District of New York (Court jurisdiction).
Eastern District of New York (Court jurisdiction).

Relationships (2)

Dr. Rocchio Employment Brown University
teaching others as a professor at Brown University
The Defendant Legal Opponent/Witness Dr. Rocchio
The defendant does not contest that Dr. Rocchio is a qualified expert.

Key Quotes (4)

"The defendant does not contest that Dr. Rocchio is a qualified expert."
Source
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Quote #1
"Dr. Rocchio is a leader in her field, teaching others as a professor at Brown University, and she has approximately twenty-five years of clinical experience."
Source
DOJ-OGR-00005793.jpg
Quote #2
"permitting expert testimony on “[t]rauma and coercive control in the context of sex trafficking, including the psychological relationship between pimps and the women prostituted by them”"
Source
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Quote #3
"case law quite commonly upholds this type of testimony against Daubert challenges"
Source
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Quote #4

Full Extracted Text

Complete text extracted from the document (1,733 characters)

Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 10 of 84
quotation marks omitted). The district court rejected that argument, explaining that “case law quite
commonly upholds this type of testimony against Daubert challenges,” and that the expert’s
experience writing about, treating, and speaking to prostitutes was sufficiently reliable. Id. at 263-
64; see also, e.g., Letter, United States v. Kelly, No. 19 Cr. 286 (AMD) (E.D.N.Y. July 23, 2021)
(Dkt. No. 134); United States v. Torres, No. 20 Cr. 608 (DLC), 2021 WL 1947503, at *6 (S.D.N.Y.
May 13, 2021) (permitting expert testimony on “domestic abuse and coercive control”); Feb. 25,
2020 Tr. at 24:1-40:15, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335
(permitting expert testimony on “[t]rauma and coercive control in the context of sex trafficking,
including the psychological relationship between pimps and the women prostituted by them”);
Notice and Oct. 17, 2019 Tr. at 27:1-12, United States v. Dupigny, No. 18 Cr. 528 (JMF)
(S.D.N.Y.), Dkt. Nos. 180-1, 198 (permitting expert testimony on “the psychological relationship
between a pimp and the woman prostituted by him” and “why prostituted women do not leave
their pimp”).
B. Discussion
The defendant does not contest that Dr. Rocchio is a qualified expert. Nor could she: Dr.
Rocchio is a leader in her field, teaching others as a professor at Brown University, and she has
approximately twenty-five years of clinical experience. She is testifying in general about core
concepts in her field, based on her “extensive study of the relevant data and literature and her
clinical experience treating hundreds of trauma and abuse patients over the past twenty years.”
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DOJ-OGR-00005793

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