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Case 1:20-cr-00330-PAE Document 386-1 Filed 10/29/21 Page 3 of 4

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and forensic psychology. She has written, presented, and taught about the assessment and treatment of trauma, among other topics. Since 2014, Dr. Rocchio has been on the editorial review board of the APA journal Trauma Psychology: Theory, Research, Practice and Policy, and she is a member of the APA Ethics Committee. A copy of Dr. Rocchio’s curriculum vitae is being produced to you today bearing Bates number 3502-006.¹

Dr. Rocchio is expected to testify, based on her relevant education, training, experience, and research to the following: 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 traumatic and psychological consequences, especially when it occurs in the context of complex trauma. The presence of other individuals can facilitate the sexual abuse of minors. Dr. Rocchio is also expected to testify 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. Dr. Rocchio has not evaluated any specific victim in this case, and the Government does not presently intend to offer Dr. Rocchio’s testimony regarding any specific victim.

Dr. Rocchio’s expected testimony relies on her education and training on psychological trauma, traumatic stress, interpersonal violence, and sexual abuse. It also relies on Dr. Rocchio’s extensive clinical experience treating individuals who suffered sexual abuse and trauma in childhood and adolescence, as well as Dr. Rocchio’s experience conducting forensic psychological evaluations of people who have experienced sexual abuse and trauma. The Government is producing notes from the Government’s interviews with Dr. Rocchio today as well.

II. Request for Reciprocal Discovery and Expert Notice

In light of your request for the foregoing notice, the Government hereby requests reciprocal notice under Rule 16(b)(1)(C) of the Federal Rules of Criminal Procedure regarding any expert witness that the defendant intends to rely upon, including a written summary of any testimony that the defendant intends to use under Rules 702, 703, or 705 of the Federal Rules of Evidence, as well as the witness’s qualifications.

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¹ Dr. Rocchio has previously testified in state court and has been deposed in the course of federal and state litigation. As a courtesy, a list of that testimony is also being produced to you today bearing Bates number 3502-002.

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