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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 23 of 29 Dietz Keywords grooming, seduction, child sexual abuse, acquaintance molestation, litigation Grooming and Seduction In the development of knowledge of child sexual abuse, few discoveries could outweigh the importance of recognizing that a large proportion of offenses are committed by acquaintances of the child using techniques other than force or threat of force. No individual has done more to share this insight with the international law enforcement community than Ken Lanning, whose writings and teachings have also reached mental health professionals, those who work in the criminal justice and social service systems, those who care for the nation's children, and countless concerned citizens and parents. The application of the terms \"seduction\" or \"grooming\" to these nonforceful, nonthreatening, and nonviolent techniques has been in the service of disseminating this important insight, which first burst into public consciousness as a real possibility in the mid-1980s as a result of partially untrue media reports about the McMartin School case and the case of Father Gilbert Gauthe, both of which stories first broke in 1984. Yet even today, far too many people, including many who should know better, have difficulty grasping the possibility of nonforceful, nonthreatening, and nonviolent acquaintance molestation, as their preconceptions of childhood innocence and predatory molesters are too strong to allow them to accept that children can be so readily manipulated into doing or allowing things that others find abhorrent. Grooming Lanning (2018) is precisely correct in dating to the 1980s the use of the term \"grooming\" to refer to techniques for gaining sexual access to children and in his observation that during the 1980s, this usage gradually increased. Using the search capabilities of Google Scholar, I found no use of the word \"grooming\" to mean such techniques in conjunction with the terms \"child sexual abuse,\" \"child molestation,\" or \"child molester\" in the professional literature from 1850 through 1983. The first publication identified by Google Scholar as using the term \"grooming\" in this way was an article by Conte (1984) citing Groth and Birnbaum (1979) for the proposition that \"[i]n most cases, except those involving abuse by a stranger, the perpetrator involves children in sexual abuse through a grooming process in which a combination of kindness, attention, material enticement, special privilege, and coercion are DOJ-OGR-00005890",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 25 of 31 Dietz not mention the misuse of the term in civil litigation. Where a victim is suing an employer or organization in connection with the sexual abuse of a minor by an employee or volunteer, it has become commonplace for the victim's advocate to argue that the failure to detect \"grooming\" was negligent on the part of the employer or organization. If their use of the term \"grooming\" always encompassed excessive focus on a particular child, time alone with the child, or inappropriate touching, this usage might not be problematic, but when \"grooming\" is applied to such common and desirable behaviors as being kind or attentive or helpful or caring, there is considerable risk of misleading the fact finder into believing that these latter behaviors are well-established predictors of child sexual abuse when there is no evidence whatsoever that they can help discriminate between good employees and volunteers, on the one hand, and risky employees and volunteers, on the other hand. In the litigation context, efforts to expand the concept of \"grooming\" to encompass desirable behaviors that are not associated with elevated risk is misleading, particularly when coupled with the presumption or suggestion that \"grooming\" always reflects an intent or plan to offend or, worse, that an offense can be proved by the fact that the accused engaged in \"grooming.\" Seducation Although I agree with Lanning (2018) that the term \"seduction\" is preferable to the term \"grooming,\" at least when there is an opportunity to explain how similar the seduction of a child is to the seduction of an age-appropriate partner, there is ample historical reason to be cautious about the use of the term \"seduction\" in this context without further explanation. This is because of two archaic usages of \"seduction\" in the older literature. Archaic Usage #1: Seduction as a Euphemism for the Offense One of the archaic usages of \"seduction,\" found often in the older scientific literature, is as a vague euphemism for any occurrence of child sexual abuse or an event that may have been sexually simulating to the child, as in these passages: \"[A] shock of some kind is held responsible for the neurosis—an attack by an animal, a threat of castration, a seduction, an actual viewing of parental coitus . . .\" (Isaacs, 1928, p. 193). \". . . I wondered whether the precocity of these fantasies and their frequency might not be due to actual seduction that the child had experienced . . .\" (Rank, 1942, p. 56). DOJ-OGR-00005892",
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"content": "Although I agree with Lanning (2018) that the term \"seduction\" is preferable to the term \"grooming,\" at least when there is an opportunity to explain how similar the seduction of a child is to the seduction of an age-appropriate partner, there is ample historical reason to be cautious about the use of the term \"seduction\" in this context without further explanation. This is because of two archaic usages of \"seduction\" in the older literature.",
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"content": "Archaic Usage #1: Seduction as a Euphemism for the Offense",
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"content": "One of the archaic usages of \"seduction,\" found often in the older scientific literature, is as a vague euphemism for any occurrence of child sexual abuse or an event that may have been sexually simulating to the child, as in these passages:",
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"content": "\"[A] shock of some kind is held responsible for the neurosis—an attack by an animal, a threat of castration, a seduction, an actual viewing of parental coitus . . .\" (Isaacs, 1928, p. 193). \". . . I wondered whether the precocity of these fantasies and their frequency might not be due to actual seduction that the child had experienced . . .\" (Rank, 1942, p. 56).",
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"additional_notes": "The document appears to be a court filing discussing the terms 'grooming' and 'seduction' in the context of child sexual abuse. The text is well-formatted and free of significant damage or redactions."
}

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"document_metadata": {
"page_number": "26",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 26 of 32 Journal of Interpersonal Violence 33(1) \n\n\". . . It was expected that a connection would be found between the child's symptom and the seduction, which was assumed to be the traumatic factor . . .\" (Bornstein, 1946, p. 230). \n\". . . [W]here father or mother, either consciously or unconsciously, elevate the child into a substitute sexual partner or commit real acts of seduction with him . . .\" (A. Freud, 1968, p. 45). \n\"If we assume that the term 'seduction' refers to any kind of sexual encounter, it can range from milder types, such as exposing oneself and enticing the child to follow suit, all the way to forcible rape\" (Finch, 1974, p. 34). \n\"She was then able to use the dolls to reveal the drama of her own seduction and the ensuing family chaos . . .\" (Mrazek, 1980, p. 279). \n\nHere \"seduction\" is not referring to the process by which a child is groomed or seduced but to the offensive event itself. Freud's seduction hypothesis \". . . generalized that the roots of all adult neuroses lay in childhood sexual contacts with adults\" (Gagnon, 1965, p. 177). The vagueness of this use of \"seduction\" makes it impossible to determine which child sexual abuse behaviors are and are not encompassed by the term and suggests that \"seduction\" may mean different specific things to different authors. \n\nAuthors sometimes imply that \"seduction\" does not include violence, as when they distinguish it from rape or other violent assaults, as in these examples: \n\n\"Klein has stated that an experience of seduction or rape by a grown-up person may have serious effects upon the child's psychic development . . .\" (Bender & Blau, 1937, p. 500). \n\"[T]he possible . . . event of seduction, incest, or rape . . .\" (Lewis & Sarrel, 1969, p. 606). \n\"Violence is rarely found to accompany the incestuous act, possibly because seduction, passive compliance, or sexual curiosity or exploration promote such relationships\" (Singer, 1979, p. 8). \n\"Children can be broken much more easily than adults, and the effect on them of torture, hatred, seduction, and rape—or even of indifference, of deprivation of love and care—is the devastating one of developmental arrest . . .\" (Shengold, 1979, p. 537). \n\nAlthough this usage comports with the modern idea of seduction or grooming insofar as it is to be distinguished from the use of force, threats, or violence, we would not today distinguish seduction from rape but rather would view seduction (or grooming) as a means of completing a rape or other sexual offense with minimal resistance or risk of disclosure. \n\nDOJ-OGR-00005893",
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"content": "\". . . It was expected that a connection would be found between the child's symptom and the seduction, which was assumed to be the traumatic factor . . .\" (Bornstein, 1946, p. 230). \n\". . . [W]here father or mother, either consciously or unconsciously, elevate the child into a substitute sexual partner or commit real acts of seduction with him . . .\" (A. Freud, 1968, p. 45). \n\"If we assume that the term 'seduction' refers to any kind of sexual encounter, it can range from milder types, such as exposing oneself and enticing the child to follow suit, all the way to forcible rape\" (Finch, 1974, p. 34). \n\"She was then able to use the dolls to reveal the drama of her own seduction and the ensuing family chaos . . .\" (Mrazek, 1980, p. 279).",
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"content": "Here \"seduction\" is not referring to the process by which a child is groomed or seduced but to the offensive event itself. Freud's seduction hypothesis \". . . generalized that the roots of all adult neuroses lay in childhood sexual contacts with adults\" (Gagnon, 1965, p. 177). The vagueness of this use of \"seduction\" makes it impossible to determine which child sexual abuse behaviors are and are not encompassed by the term and suggests that \"seduction\" may mean different specific things to different authors.",
"position": "middle"
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{
"type": "printed",
"content": "Authors sometimes imply that \"seduction\" does not include violence, as when they distinguish it from rape or other violent assaults, as in these examples: \n\n\"Klein has stated that an experience of seduction or rape by a grown-up person may have serious effects upon the child's psychic development . . .\" (Bender & Blau, 1937, p. 500). \n\"[T]he possible . . . event of seduction, incest, or rape . . .\" (Lewis & Sarrel, 1969, p. 606). \n\"Violence is rarely found to accompany the incestuous act, possibly because seduction, passive compliance, or sexual curiosity or exploration promote such relationships\" (Singer, 1979, p. 8). \n\"Children can be broken much more easily than adults, and the effect on them of torture, hatred, seduction, and rape—or even of indifference, of deprivation of love and care—is the devastating one of developmental arrest . . .\" (Shengold, 1979, p. 537).",
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"content": "Although this usage comports with the modern idea of seduction or grooming insofar as it is to be distinguished from the use of force, threats, or violence, we would not today distinguish seduction from rape but rather would view seduction (or grooming) as a means of completing a rape or other sexual offense with minimal resistance or risk of disclosure.",
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"additional_notes": "The document appears to be a page from a legal or academic text discussing the concept of 'seduction' in the context of child sexual abuse. The text includes citations to various authors and publications. The document is well-formatted and legible, with no visible redactions or damage."
}

96
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{
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"page_number": "27",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 27 of 33 Dietz Cioffi (1976) interpreted Freud as using the concept of seduction to refer only to nonviolent sexual assaults, writing \". . . he duly reported that he had discovered the specific cause of psychoneurotic disorder: A passive sexual experience before puberty. In other words, a seduction\" (p. 275). Cioffi's (1976) quotations of Freud in the same article support this interpretation: \"Freud later assigned to his patients in phrases like: 'hysterics trace back their symptoms to fictitious traumas'—or patients 'ascribe their symptoms to passive sexual experiences in early childhood'\" (p. 277). Even here, however, what constitutes a \"passive sexual experience\" is unclear, as it could mean the offender did not use violence, that the child did not resist, or that the child was not an active participant. Archaic Usage #2: The Child as Seducer A second archaic usage of \"seduction\" is to refer to the child's tempting of the offender. This is diametrically opposed to our current thinking about child sexual abuse in its suggestion that it is the child who is at fault, as in these examples: \"... [A] most striking feature was that these children were distinguished as unusually charming and attractive in their outward personalities. Thus, it is not remarkable that frequently we considered the possibility that the child might have been the actual seducer rather than the one innocently seduced\" (Bender & Blau, 1937, p. 514). \"The majority of pedophiles are harmless individuals and their victims are usually known to be aggressive and seductive children\" (Revitch & Weiss, 1962, p. 78). \"In many [cases] it was highly probable that the child had used his charm in the role of seducer rather than that he had been the innocent one who had been seduced . . .\" (Bender & Grunett, 1952, p. 826). \"Abraham (1907) and Bender and Blau (1937) have commented on how charming and seductive these children can be\" (Rosenfeld, Nadelson, Krieger, & Backman, 1977, p. 332). Three examples of authors attempting to remedy this archaic view are as follows: \"... Although there may be a different quality to a seduction than to an attack, it must be remembered that even a seductive child cannot have full adult comprehension of the act she is courting and cannot be viewed as responsible in this area\" (Lipton & Roth, 1969, p. 859). DOJ-OGR-00005894",
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{
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"content": "Cioffi (1976) interpreted Freud as using the concept of seduction to refer only to nonviolent sexual assaults, writing \". . . he duly reported that he had discovered the specific cause of psychoneurotic disorder: A passive sexual experience before puberty. In other words, a seduction\" (p. 275). Cioffi's (1976) quotations of Freud in the same article support this interpretation: \"Freud later assigned to his patients in phrases like: 'hysterics trace back their symptoms to fictitious traumas'—or patients 'ascribe their symptoms to passive sexual experiences in early childhood'\" (p. 277). Even here, however, what constitutes a \"passive sexual experience\" is unclear, as it could mean the offender did not use violence, that the child did not resist, or that the child was not an active participant.",
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"content": "Archaic Usage #2: The Child as Seducer",
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"content": "A second archaic usage of \"seduction\" is to refer to the child's tempting of the offender. This is diametrically opposed to our current thinking about child sexual abuse in its suggestion that it is the child who is at fault, as in these examples:",
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{
"type": "printed",
"content": "\"... [A] most striking feature was that these children were distinguished as unusually charming and attractive in their outward personalities. Thus, it is not remarkable that frequently we considered the possibility that the child might have been the actual seducer rather than the one innocently seduced\" (Bender & Blau, 1937, p. 514). \"The majority of pedophiles are harmless individuals and their victims are usually known to be aggressive and seductive children\" (Revitch & Weiss, 1962, p. 78). \"In many [cases] it was highly probable that the child had used his charm in the role of seducer rather than that he had been the innocent one who had been seduced . . .\" (Bender & Grunett, 1952, p. 826). \"Abraham (1907) and Bender and Blau (1937) have commented on how charming and seductive these children can be\" (Rosenfeld, Nadelson, Krieger, & Backman, 1977, p. 332).",
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"content": "Three examples of authors attempting to remedy this archaic view are as follows:",
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"content": "\"... Although there may be a different quality to a seduction than to an attack, it must be remembered that even a seductive child cannot have full adult comprehension of the act she is courting and cannot be viewed as responsible in this area\" (Lipton & Roth, 1969, p. 859).",
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"additional_notes": "The document appears to be a court filing discussing the concept of seduction in the context of child sexual abuse. The text includes citations to various academic sources and references to specific cases. The document is well-formatted and free of significant damage or redactions."
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85
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 28 of 34 Journal of Interpersonal Violence 33(1) \"Because the affectional needs of the child are not adequately met by the parents, the child may indiscriminately relate to adults in an affection-seeking manner in an effort to ensure her emotional survival. Numerous other investigators have characterized this behavior of the child as 'seductive'. However, our study indicates that this behavior is instead the child's often desperate attempt to meet her needs for care and attention . . . The child's behavior may often appear sexualized to an adult . . . As a result, it is more appropriate to describe this behavior as affection-seeking rather than seductive\" (Johnston, 1979, pp. 948-949). \"Everybody knows' that adults must protect themselves from groundless accusations of seductive or vindictive young people. . . . What everybody does not know, and would not want to know, is that the vast majority of investigated accusations prove valid and that most of the young people were less than eight years old at the time of initiation\" (Summit, 1983, p. 178). Conclusion Since its introduction to the peer-reviewed professional literature in 1984, the term \"grooming\" has become so widely adopted that it will remain in widespread use for decades to come. We can and should clarify the meaning of the term wherever possible to avoid misuse or misleading of our audiences. We could benefit from prospective studies of the frequency of grooming-like behaviors among adults in target-rich environments such as schools, youth sports, and youth groups, which could help distinguish behaviors portending risk from those that do not, though it would require a large sample and a long time to reveal at least some of the offenders in the sample. The two archaic uses of the term \"seduction\" in the context of child sexual abuse identified here are too recent and too widely known to justify completely abandoning the term \"grooming\" in favor of \"seduction,\" even if it were possible to do so. Perhaps the best strategy is that adopted by Lanning (2018) of explaining the parallel between the courtship and mating rituals that adults use with one another and the courtship and mating rituals that some use with children. Declaration of Conflicting Interests The author(s) declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article. DOJ-OGR-00005895",
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"content": "\"Because the affectional needs of the child are not adequately met by the parents, the child may indiscriminately relate to adults in an affection-seeking manner in an effort to ensure her emotional survival. Numerous other investigators have characterized this behavior of the child as 'seductive'. However, our study indicates that this behavior is instead the child's often desperate attempt to meet her needs for care and attention . . . The child's behavior may often appear sexualized to an adult . . . As a result, it is more appropriate to describe this behavior as affection-seeking rather than seductive\" (Johnston, 1979, pp. 948-949).",
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{
"type": "printed",
"content": "\"Everybody knows' that adults must protect themselves from groundless accusations of seductive or vindictive young people. . . . What everybody does not know, and would not want to know, is that the vast majority of investigated accusations prove valid and that most of the young people were less than eight years old at the time of initiation\" (Summit, 1983, p. 178).",
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{
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"content": "Conclusion",
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"content": "Since its introduction to the peer-reviewed professional literature in 1984, the term \"grooming\" has become so widely adopted that it will remain in widespread use for decades to come. We can and should clarify the meaning of the term wherever possible to avoid misuse or misleading of our audiences. We could benefit from prospective studies of the frequency of grooming-like behaviors among adults in target-rich environments such as schools, youth sports, and youth groups, which could help distinguish behaviors portending risk from those that do not, though it would require a large sample and a long time to reveal at least some of the offenders in the sample.",
"position": "main content"
},
{
"type": "printed",
"content": "The two archaic uses of the term \"seduction\" in the context of child sexual abuse identified here are too recent and too widely known to justify completely abandoning the term \"grooming\" in favor of \"seduction,\" even if it were possible to do so. Perhaps the best strategy is that adopted by Lanning (2018) of explaining the parallel between the courtship and mating rituals that adults use with one another and the courtship and mating rituals that some use with children.",
"position": "main content"
},
{
"type": "printed",
"content": "Declaration of Conflicting Interests",
"position": "main content"
},
{
"type": "printed",
"content": "The author(s) declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.",
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"additional_notes": "The document appears to be a court filing related to a case involving child sexual abuse. The text discusses the concept of 'grooming' and its implications. The document is well-formatted and free of significant damage or redactions."
}

112
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{
"document_metadata": {
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 29 of 35 Dietz Funding The author(s) received no financial support for the research, authorship, and/or publication of this article. Note 1. The data on which Figure 1 is based are derived from year-by-year searches of Google Scholar for the combination of the terms \"child sexual abuse\" and \"grooming,\" excluding citations and patents. One should not assume that the underlying database is complete or that all the publications included in the count use \"grooming\" in this way or represent peer-reviewed literature, as newsletters, government reports, books, and other documents also make their way into such searches. Nonetheless, the graph gives an adequate representation of the growing use of the term \"grooming\" for this purpose. References Abraham, K. (1907). The experiencing of sexual traumas as a form of sexual activity. In E. Jones (Ed.), Selected papers on psycho-analysis (pp. 47-63). London, England: Hogarth Press. Bender, L., & Blau, A. (1937). The reaction of children to sexual relations with adults. American Journal of Orthopsychiatry, 7, 500-518. Bender, L., & Grugett, Jr., A. E. (1952). A follow-up study of children who had atypical sexual experience. American Journal of Orthopsychiatry, 22, 825-837. Bornstein, B. (1946). Hysterical twilight states in an eight-year-old child. The Psychoanalytic Study of the Child, 2, 229-240. Cioffi, F. (1976). Was Freud a liar? Orthomolecular Psychiatry, 5, 275-280. Conte, J. R. (1984). The justice system and sexual abuse of children. Social Service Review, 58, 556-568. Finch, S. M. (1974). Effects of adult sexual seduction on children. Journal of Clinical Child Psychology, 3, 33-35. Freud, A. (1968). Indications and contraindications for child analysis. The Psychoanalytic Study of the Child, 23, 37-46. Gagnon, J. H. (1965). Female child victims of sex offenses. Social Problems, 13, 176-192. Groth, A. N., & Birnbaum, H. J. (1979). Men who rape: The psychology of the offender. New York, NY: Plenum Press. Isaacs, S. S. (1928). The mental hygiene of the pre-school child. British Journal of Medical Psychology, 8, 186-193. Johnston, M. S. K. (1979). The sexually mistreated child: Diagnostic evaluation. Child Abuse & Neglect, 3, 943-951. Kris, E. (1950). The significance of Freud's earliest discoveries. The International Journal of Psychoanalysis, 31, 108-116. Lanning, K. V. (2018). The evolution of grooming: Concept and term. Journal of Interpersonal Violence, 33, 5-16. DOJ-OGR-00005896",
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"content": "Funding The author(s) received no financial support for the research, authorship, and/or publication of this article.",
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"content": "Note 1. The data on which Figure 1 is based are derived from year-by-year searches of Google Scholar for the combination of the terms \"child sexual abuse\" and \"grooming,\" excluding citations and patents. One should not assume that the underlying database is complete or that all the publications included in the count use \"grooming\" in this way or represent peer-reviewed literature, as newsletters, government reports, books, and other documents also make their way into such searches. Nonetheless, the graph gives an adequate representation of the growing use of the term \"grooming\" for this purpose.",
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"content": "Abraham, K. (1907). The experiencing of sexual traumas as a form of sexual activity. In E. Jones (Ed.), Selected papers on psycho-analysis (pp. 47-63). London, England: Hogarth Press. Bender, L., & Blau, A. (1937). The reaction of children to sexual relations with adults. American Journal of Orthopsychiatry, 7, 500-518. Bender, L., & Grugett, Jr., A. E. (1952). A follow-up study of children who had atypical sexual experience. American Journal of Orthopsychiatry, 22, 825-837. Bornstein, B. (1946). Hysterical twilight states in an eight-year-old child. The Psychoanalytic Study of the Child, 2, 229-240. Cioffi, F. (1976). Was Freud a liar? Orthomolecular Psychiatry, 5, 275-280. Conte, J. R. (1984). The justice system and sexual abuse of children. Social Service Review, 58, 556-568. Finch, S. M. (1974). Effects of adult sexual seduction on children. Journal of Clinical Child Psychology, 3, 33-35. Freud, A. (1968). Indications and contraindications for child analysis. The Psychoanalytic Study of the Child, 23, 37-46. Gagnon, J. H. (1965). Female child victims of sex offenses. Social Problems, 13, 176-192. Groth, A. N., & Birnbaum, H. J. (1979). Men who rape: The psychology of the offender. New York, NY: Plenum Press. Isaacs, S. S. (1928). The mental hygiene of the pre-school child. British Journal of Medical Psychology, 8, 186-193. Johnston, M. S. K. (1979). The sexually mistreated child: Diagnostic evaluation. Child Abuse & Neglect, 3, 943-951. Kris, E. (1950). The significance of Freud's earliest discoveries. The International Journal of Psychoanalysis, 31, 108-116. Lanning, K. V. (2018). The evolution of grooming: Concept and term. Journal of Interpersonal Violence, 33, 5-16.",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 30 of 36 Journal of Interpersonal Violence 33(1) Lanning, K. V., & Dietz, P. (2014). Acquaintance molestation and youth-serving organizations. Journal of Interpersonal Violence, 29, 2815-2838. doi: 10.1177/0886260514532360 Lewis, M., & Sarrel, P. M. (1969). Some psychological aspects of seduction, incest, and rape in childhood. Journal of the American Academy of Child Psychiatry, 8, 606-619. Lipton, G. L., & Roth, E. I. (1969). Rape: A complex management problem in the pediatric emergency room. The Journal of Pediatrics, 75, 859-866. Mrazek, D. A. (1980). The child psychiatric examination of the sexually abused child. Child Abuse & Neglect, 4, 275-284. Rank, B. (1942). Where child-analysis stands today. American Imago; A Psychoanalytic Journal for the Arts and Sciences, 3(3), 41-60. Revitch, E., & Weiss, R. G. (1962). The pedophiliac offender. Diseases of the Nervous System, 23, 73-78. Rosenfeld, A. A., Nadelson, C. C., Krieger, M., & Backman, J. H. (1977). Incest and sexual abuse of children. Journal of the American Academy of Child Psychiatry, 16, 327-339. Shengold, L. L. (1979). Child abuse and deprivation: Soul murder. Journal of the American Psychoanalytic Association, 27, 533-559. Singer, M. (1979). Perspective on incest as child abuse. Australian & New Zealand Journal of Criminology, 12, 3-16. Summit, R. C. (1983). The child sexual abuse accommodation syndrome. Child Abuse & Neglect, 7, 177-193. Author Biography Park Dietz, MD, MPH, PhD, was educated at Cornell, Johns Hopkins, and the University of Pennsylvania, and taught for 10 years at Harvard Medical School and the University of Virginia School of Law and School of Medicine. He is now a clinical professor of psychiatry and biobehavioral sciences at University of California, Los Angeles (UCLA). As president of Park Dietz & Associates, Inc., he regularly oversees forensic evaluations of psychological damages and expert assessments of liability in child sexual abuse litigation, and as president of Threat Assessment Group, Inc., he regularly participates in the development and implementation of programs to prevent and respond to misconduct in organizations and institutions. DOJ-OGR-00005897",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 31 of 43 Journal of Sexual Aggression (November 2006), Vol. 12, No. 3, pp. 287–299 Sexual grooming of children: Review of literature and theoretical considerations Samantha Craven,1,* Sarah Brown1 & Elizabeth Gilchrist2 1Department of Psychology, Coventry University, Coventry, UK, and 2Department of Psychology, University of Kent, Canterbury, Kent, UK Abstract The current review aims to outline the existing understanding of sexual grooming. Issues of poor definition, the adoption of the term “grooming” and the prevalence of sexual grooming will be discussed. Consideration will be given to how prominent theories of child sexual abuse often neglect sexual grooming. This will be followed by a detailed account of the existing knowledge within the literature. Three types of sexual grooming were thus identified: self-grooming, grooming the environment and significant others and grooming the child. Based on these findings, a new definition of sexual grooming is suggested. Furthermore, the findings correspond well with current models of the sexual offence process. A more comprehensive understanding of sexual grooming is required to facilitate a preventative approach to child protection. Keywords Sexual grooming; theory of child sexual abuse Introduction The complex nature of the tactics used by child sex offenders in their efforts to sexually abuse children is increasingly evident in the accounts of the people affected by this predatory behaviour. Sexual grooming is a pertinent issue evident in society, but there is still little understanding about this phenomenon. This is reflected in problems relating to definition, which will be discussed in addition to the evolution of the term “grooming”. This review will consider whether present aetiological theories of child sexual abuse can account for “sexual grooming” behaviour, and further determines what knowledge has already been established about the phenomenon of sexual grooming. Based on these findings, a new definition is presented and consideration is given to how current knowledge of sexual grooming relate to models of the sexual offence process. Definition Professionals are yet to agree on a definition of sexual grooming of children (Gillespie, 2004). Previous literature has provided three specific definitions of grooming. The strengths and *Corresponding author: Samantha Craven, Department of Psychology, Coventry University, Priory Street, Coventry CV1 5FB, UK. Tel: 02476 887 048. Fax: 02476 888300. E-mail: s.craven@coventry.ac.uk ISSN 1355 2600 print/1742 6545 online © 2006 National Organisation for the Treatment of Abusers DOI: 10.1080/13552600601069414 DOJ-OGR-00005898",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 32 of 43\n288 S. Craven et al.\nweaknesses of these definitions are discussed in turn below. First, O'Connell defines sexual grooming as:\nA course of conduct enacted by a suspected paedophile, which would give a reasonable person cause for concern that any meeting with a child arising from the conduct would be for unlawful purposes. (O'Connell, 2003, p. 6)\nSecond, Howitt suggests that:\nGrooming... is the steps taken by paedophiles to \"entrap\" their victims and is in someways analogous to adult courtship. (Howitt, 1995, p. 176)\nThese two definitions are problematic, because they both refer to the term paedophile. Most sexual offenders who target child victims use sexual grooming, not just those classified as paedophiles. The term \"paedophile\" is a very specific clinical diagnosis, clearly not applicable to all offenders, and the association of grooming behaviour with paedophilia may prevent some offenders from acknowledging their own grooming behaviours. In addition, people known to the offender may not identify the grooming behaviour because they do not consider the individual to fit their image of a \"paedophile\". The public perception of a paedophile is littered with stereotypes that they are \"dirty old men\" or strangers; these perceptions may affect an individual's judgement of whether the behaviour they have observed is grooming. These misperceptions distract from the truth that most victims know their abuser. It is important that the wording of a definition does not thwart the identification of sexual grooming and the subsequent prevention or ending of abuse.\nFurthermore, the phrase \"a course of conduct\" requires subsequent definition. Additional problems include reference to \"a reasonable person\" and \"cause for concern\". Although legal precedent defines these phrases, they are ambiguous to the lay reader and hence they are open to misinterpretation and confusion. These definitions are confusing, at best, and at worst they reinforce the myth that strangers are the biggest risk to children. Consequently, this ambiguity may hinder the identification of the full range of sexual grooming behaviours.\nGillespie (2002) provides the third definition:\nThe process by which a child is befriended by a would-be abuser in an attempt to gain the child's confidence and trust, enabling them to get the child to acquiesce to abusive activity. It is frequently a pre-requisite for an abuser to gain access to a child. (Gillespie, 2002, p. 411; based on van Dam, 2001)\nThis definition avoids the use of the term paedophile. It also provides some clarity about the purpose of sexual grooming behaviour and identifies some of the stages that it involves. This appears to be the most appropriate published definition to date. Further evaluation of this definition will follow consideration of previous literature and current understanding about sexual grooming.\nPrevalence\nCanter, Hughes and Kirby (1998) provide evidence for the prevalence of the sexual grooming phenomenon. They used Small Space Analysis on a behaviour matrix of the interaction between 97 incarcerated child sex offenders and their victims. They identified three distinct behaviour repertoires of offender-victim interaction. The different types of offender-victim interaction acknowledged were aggressive, which was identifiable by the use of extreme\nDOJ-OGR-00005899",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 33 of 43\nSexual grooming of children 289\nviolence, threat and force; criminal-opportunist, which tended to be one-off offences on strangers; and intimate, which was categorized by the identified use of sexual grooming behaviours.\nForty-five per cent of Canter et al.'s (1998) sample were classified as being intimate offenders. Thus, 45% of the child sex offenders employed an intimate behaviour repertoire and sexual grooming behaviours. This figure is likely to be unrepresentative of the child offender population as a whole. Intimate offenders tend to cause less physical harm to their victims than the other categories of offenders and the very nature of the behaviour used to categorize the intimate offenders implies that they would be less likely to be reported, identified and convicted, because these grooming behaviours are used to avoid disclosure and conviction. Hence, it is likely that intimate offenders were under-represented in this prison sample.\nFigures show that eight of 10 sex abuse victims know their abuser (Stop it Now, 2003). In such cases, offenders have substantial interest in preventing disclosure, because in the event of disclosure the victim would be able to easily identify them as their abuser. This is supported by offenders' accounts about the strategies they employed to victimize the children they sexually abused; fear of disclosure affected how and when they victimized their victims (Conte, Wolf & Smith, 1989).\nAetiology of a motivation to abuse\nBefore an individual begins to groom a child, some level of motivation to abuse a child needs to be present. Furthermore, adequate theories of sexual offending should be able to account for the phenomenon of sexual grooming. Until recently there have been three dominant theories of child sexual abuse, namely Finkelhor's Pre-condition Model (1984); Marshall and Barbaree's Integrated Theory (1990); and Hall and Hirschman's Quadripartite Model (1992). In 2002, Ward and Siegert proposed a more comprehensive theory of child sexual abuse by \"knitting together\" the strengths of each of the above theories. They propose that there are five pathways to sexual offending against children; hence, the theory is called The Pathways Model. This review shall consider each of these only briefly, because Ward and colleagues have already provided in-depth reviews (see Ward, 2001, 2002; Ward & Hudson, 2001). Herein, more emphasis will be placed on how these theories relate to the phenomenon of sexual grooming.\nMarshall and Barbaree's Integrated Theory\nMarshall and Barbaree's (1990) Integrated Theory of the aetiology of sexual offending proposes that the presence of vulnerabilities, which develop as a result of adverse early developmental experiences, leave offenders unprepared to deal with the surge of hormones at puberty, and unable to understand the emotional world. As a resultant, offenders satisfy their emotional and sexual needs inappropriately in deviant ways. This theory suggests that sexual offending occurs as a consequence of an individual's sex and aggression drives becoming fused, as these functions share the same structure in the brain. Ward and Siegert (2002) state that this need not be the case, as there are many functions that are close in proximity but that do not affect each other. Furthermore, this theory suggests that sexual offending would be aggressive. Therefore, it would seem that it does not account for the phenomenon of sexual grooming, because the process of sexual grooming is generally not aggressive in nature.\nDOJ-OGR-00005900",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 34 of 43\n290 S. Craven et al.\nHowever, this criticism may be countered if a definition of aggression were to include indirect aggression, which sexual grooming could be considered to be.\n\nHall and Hirschman's Quadripartite Model\nHall and Hirschman's (1992) Quadripartite Model was first developed as a theory of rape, but it was applied subsequently to child sexual abuse. This model suggests that someone commits an act of child sexual abuse because of four vulnerability factors and the presence of opportunity. The vulnerability factors are physiological sexual arousal, distorted cognitions that act to justify sexual aggression, affective dyscontrol, and personality problems. It is suggested that offending will occur when the presence of these vulnerability factors exceed a threshold, this could include one or all of these vulnerabilities. There are several problems with this model; first, it does not explain why someone chooses to offend against a child rather than an adult. Second, sexual grooming is not an impulsive act and the threshold would need to be maintained over a long period of time in order to explain sexual grooming, because it can occur over weeks, months or even years. Hence, this theory can account for sexual grooming if it is accepted that, for example, sexual arousal persists over long periods of time, so once sexually aroused to children/child the offender would be continually aroused to them. A further problem with this theory relates to the presence of opportunity; offenders often create their own opportunities to offend.\n\nFinkelhor's Pre-condition Model\nFinkelhor's Pre-condition Model (1984) suggests that there are four pre-conditions to sexual offending. The first is the motivation to sexually abuse; it is suggested that this develops as a result of emotional congruence (a fit between the offender's emotional needs and the child's ability to meet them), deviant sexual arousal and blockage (the sexual needs of the offender not being met by appropriate adults). The second is to be able to overcome internal inhibitors; the third is to be able to overcome external inhibitors; and the fourth is to overcome the child's resistance. Before an incidence of abuse would take place, these pre-conditions need to be satisfied. Although Finkelhor does not use the term sexual grooming, others (e.g. Morrison, Erooga & Beckett, 1994; Sampson, 1994) have reviewed his work using this term. They referred to overcoming the child's resistance as grooming.\n\nWard and Siegert's Pathways Model\nWard and Siegert's (2002) model is based on the dysfunction of one or more psychological mechanisms—emotional regulation, intimacy deficits, cognitive distortions and sexual arousal (deviant sexual scripts). All the aforementioned psychological mechanisms are involved to some degree. There is evidence of these dysfunctional mechanisms being present typically in child molesters, although to different degrees and for different functions. The five possible pathways are specified by whichever dysfunctional psychological mechanism is the most dominant; in turn this will affect the others. In the case of the fifth pathway, all the psychological mechanisms would be similarly dysfunctional. A sexual offence occurs when the above is present in conjunction with sexual need. In addition, Ward and Siegert still emphasize the importance of there being an opportunity to offend; however, the nature of sexual grooming is to create an opportunity to offend. Successful theory would need to account for this.\n\nDOJ-OGR-00005901",
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"content": "Hall and Hirschman's Quadripartite Model\nHall and Hirschman's (1992) Quadripartite Model was first developed as a theory of rape, but it was applied subsequently to child sexual abuse. This model suggests that someone commits an act of child sexual abuse because of four vulnerability factors and the presence of opportunity. The vulnerability factors are physiological sexual arousal, distorted cognitions that act to justify sexual aggression, affective dyscontrol, and personality problems. It is suggested that offending will occur when the presence of these vulnerability factors exceed a threshold, this could include one or all of these vulnerabilities. There are several problems with this model; first, it does not explain why someone chooses to offend against a child rather than an adult. Second, sexual grooming is not an impulsive act and the threshold would need to be maintained over a long period of time in order to explain sexual grooming, because it can occur over weeks, months or even years. Hence, this theory can account for sexual grooming if it is accepted that, for example, sexual arousal persists over long periods of time, so once sexually aroused to children/child the offender would be continually aroused to them. A further problem with this theory relates to the presence of opportunity; offenders often create their own opportunities to offend.",
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"content": "Finkelhor's Pre-condition Model\nFinkelhor's Pre-condition Model (1984) suggests that there are four pre-conditions to sexual offending. The first is the motivation to sexually abuse; it is suggested that this develops as a result of emotional congruence (a fit between the offender's emotional needs and the child's ability to meet them), deviant sexual arousal and blockage (the sexual needs of the offender not being met by appropriate adults). The second is to be able to overcome internal inhibitors; the third is to be able to overcome external inhibitors; and the fourth is to overcome the child's resistance. Before an incidence of abuse would take place, these pre-conditions need to be satisfied. Although Finkelhor does not use the term sexual grooming, others (e.g. Morrison, Erooga & Beckett, 1994; Sampson, 1994) have reviewed his work using this term. They referred to overcoming the child's resistance as grooming.",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 35 of 43\n\nSexual grooming of children 291\n\nDespite Ward and Siegert presenting their Pathways Model as a comprehensive theory of sexual offending, it still only considers aetiology and no consideration is given to the offence process. In a comprehensive theory it is necessary to consider the whole journey from initial onset to the offence and beyond. In a similar way that the Transtheoretical Model (Prochaska & DiClemente, 1982) of change considers not only the action stage, where the overt behaviour is changed, but also the precontemplation, contemplation, preparation and maintenance stages, a theory of sexual offending against children needs to consider the whole journey. As demonstrated above, it is necessary that theories of aetiology are coherent with the phenomenon they are attempting to explain. While endeavouring to explain sexual offending it is important that sexual grooming is also factored into the equation, because it is part of the sexual offending phenomenon. Of the above theories, only Finkelhor's (1984) Pre-condition Model has taken this approach.\n\nOffence process\n\nIn addition to the Pre-condition Model (Finkelhor, 1984) there is one other model that considers the offence process of sexual offending. This is the Descriptive Model of the Offence Chain (Ward, Louden, Hudson & Marshall, 1995). Ward et al.'s model provides a much more detailed account of the offence process than the Pre-condition Model. While little evidence has been found to support Finkelhor's Pre-condition Model, Ward et al. used a grounded theory approach and developed their model directly from offenders' experiences. They identified nine stages of the offence chain. Stage one relates to the offender's background factors, including their perception of themselves and their life at the beginning of the offence chain and whether these factors caused positive or negative affect. Stage two describes distal planning of access to their victim; this could take the form of implicit, or explicit planning or chance. Contact with the victim takes place in stage three. Stage four involves cognitive restructuring, which will result in either positive or negative affect. Stage five entails proximal planning, which would either be self-focused, victim-focused or a mutual-focus. This leads to stage six and the sexual offence, which is followed by further cognitive restructuring at stage seven. This results in negative or positive evaluation and future resolutions regarding continued offending at stage eight. This resolution will be to either avoid future offending or to persist in an abusive pattern. Stage nine depicts the impact of these resolutions on the offender's life.\n\nIt is important to consider how sexual grooming fits into, and facilitates, the offence process, as this understanding is likely to aid the management of offenders and potential offenders by identifying the offence process prior to an sexual offence taking place. In addition, it is reasonable to suggest that motivation is not static but could be affected by later stages of the grooming and offence process, e.g. cognitive distortions developed later in the process could serve to reinforce prior motivation resulting in an entrenched deviant sexual interest. This may prove valuable to treatment programmes efforts of reducing motivation to offend.\n\nThe grooming process\n\nThe current review has identified three types of sexual grooming present in the literature—self-grooming, grooming the environment and significant others and grooming the child. Each of these will be discussed to explore current understanding of sexual grooming. Understanding of the grooming process and an ability to identify sexual grooming behaviour\n\nDOJ-OGR-00005902",
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"content": "Despite Ward and Siegert presenting their Pathways Model as a comprehensive theory of sexual offending, it still only considers aetiology and no consideration is given to the offence process. In a comprehensive theory it is necessary to consider the whole journey from initial onset to the offence and beyond. In a similar way that the Transtheoretical Model (Prochaska & DiClemente, 1982) of change considers not only the action stage, where the overt behaviour is changed, but also the precontemplation, contemplation, preparation and maintenance stages, a theory of sexual offending against children needs to consider the whole journey. As demonstrated above, it is necessary that theories of aetiology are coherent with the phenomenon they are attempting to explain. While endeavouring to explain sexual offending it is important that sexual grooming is also factored into the equation, because it is part of the sexual offending phenomenon. Of the above theories, only Finkelhor's (1984) Pre-condition Model has taken this approach.",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 36 of 43\n292 S. Craven et al.\nis crucial in order to prevent child sexual abuse. However, retrospective identification of sexual grooming, i.e. after a sexual offence has been committed, is much easier than prospective identification, i.e. before a sexual offence. Nevertheless, the latter is necessary in order to prevent the sexual abuse from taking place. The reason for this is because the behaviours used to groom a child for sexual abuse are not dissimilar to innocent behaviour intended to broaden a young person's experiences. The only difference may be the motivation underlying the behaviour.\n\nSelf-grooming\nvan Dam (2001) reports that during treatment, offenders' talk about \"grooming themselves\". They were referring to the justification or denial of their offending behaviour. It therefore seems important to consider this as part of the grooming process. However, it may be more agreeable to refer to this phenomenon by another name, avoiding the use of the term \"grooming\". Nevertheless, self-grooming is likely to play a part in the move from being motivated to sexually abuse a child to the subsequent targeting of a child, through the justification or denial of the steps child sexual offenders take towards abusing a child. Furthermore, self-grooming is likely to be affected by the response from the community and the child, and the success or failure of the efforts to victimize the child. \"Success\" is likely to result in further justification or denial of their actions and more entrenched sexual interest in children and motivation to offend. \"Failure\", on the other hand, is likely to result in the desistence of offending or the offender developing/enhancing his skills/strategies to ensure success.\nJustification and denial of offenders' behaviour manifests in cognitive distortions. Ward and Keenan (1999) propose that child sex offenders have cognitive distortions in the form of implicit theories, which relate to themselves, the victim and the world. Implicit theories help individuals to understand the world around them. Problems arise because offenders' implicit theories are maladaptive and supportive of sex with children. These implicit theories subsequently affect encoding and interpretation of future behaviours and events. Ward and Keenan have identified five implicit theories that account for most of the cognitive distortions held by child sex offenders: children as sexual objects; entitlement; dangerous world; uncontrollability; and nature of harm.\nOf course, it is not only offenders who have maladaptive implicit theories. For example, many people have an implicit theory that children are at most risk from strangers, which is not consistent with research findings. However, it is easier to believe that strangers sexually abuse children than accept that friends and family do; hence, this implicit theory helps to shelter people from the harsh nature of reality. Offenders' implicit theories work in a similar way, because it is easier for offenders to believe that the child seduced them than to accept that they sexually abused a child.\n\nGrooming the environment and significant others\nGrooming the child begins with identifying a vulnerable child (van Dam, 2001). Child sex offenders seem to have a special ability in recognizing vulnerable children (Conte et al., 1989). These vulnerabilities may be that the children have a poor relationship with their parents, do not have many friends (Berliner & Conte, 1990), or have already been victimized (Leberg, 1997). Alternatively, offenders may target women who were sexually abused as children, because the offender considers them easier to re-victimize.\nDOJ-OGR-00005903",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 37 of 43\nSexual grooming of children 293\n\nIn order to gain access to their victim(s), offenders groom the environment and their potential victim's significant others (e.g. parents, carers, teachers, etc). This may mean the offender integrating themselves into society and places where they are likely to meet children. This will often be a position of trust. Offenders then begin grooming the adults in this community, specifically those who are significant to their potential victim, with the aim of creating an opportunity to access and abuse a child or children. van Dam (2001) reports that offenders are frequently charming, very helpful, and have insider status. This is often an important factor in gaining access to potential victims). As offenders help out in the community, they are considering how their efforts will be rewarded later when they can then abuse the children in that community. Offenders are often able to \"read the community like a book\" in that they assess what they \"need\" and fulfil these needs accordingly (Hare & Hart, 1993). They can make themselves indispensable, too good to be true and will freely undertake jobs that others do not want to do (Leberg, 1997).\n\nA desire on the part of parents to avoid cognitive dissonance may assist offenders' grooming efforts. A parent may suffer cognitive dissonance as a result of concerns about the trustworthiness of the offender alongside their hospitality and acceptance of the offender. When thoughts do not match behaviour, cognitive dissonance manifests, and often thoughts are changed to be consistent with behaviour (van Dam, 2001). Thus, offenders gain insider status long before they start abusing a victim (van Dam, 2001). Grooming is therefore a well-organized long-term activity (Sanford, 1982). Offenders groom the community so well that if a victim discloses their abuse, the community may support the offender rather than the victim, because they deem the offender to be more believable than the child.\n\nIn the case of intrafamilial child sexual abuse, offenders are already in a position of trust and integrated in an environment where they can access potential victims. Some offenders groom the environment by targeting single-parent families to gain this status (Elliott, Browne & Kilcoyne, 1995). Offenders may do this because they believe that these children are more vulnerable and because they believe it will be easier to create opportunities to be alone with the child. Alternatively, offenders may target children or young people who have absent parents, and hence have less protection. In this incidence there is no need for the offender to groom the parents. They can become the child's friend and more easily arrange to have time alone with the child.\n\nIntrafamilial offenders often isolate the victim from their non-abusing parent, siblings and the outside world by developing an exclusive relationship with the child. For instance, they may encourage mothers to have more of a life outside the home, which then gives them increased opportunities to abuse their victims. Alternatively, they may isolate non-abusing parents from the outside world in order to prevent them from having people in whom to confide about any concerns (Leberg, 1997). Some offenders encourage mothers to develop an alcohol dependency, in part so that any future disclosures made lack credibility (Leberg, 1997). Other similar strategies employed to limit credibility include questioning the mother's parenting ability in front of friends and other family members. This may constitute part of their strategy for grooming the environment and significant others.\n\nGrooming the environment and significant others can occur as a result of implicit or explicit planning; alternatively, access to a child may occur by chance. Ward and Hudson (2000) have developed a conceptual model of how child sex offenders' implicit planning or seemingly unimportant decisions (SUDs) implicate their offending behaviour by leading them to high-risk situations, i.e. contact with children. This appears to be automatic, because although offenders are conscious of their specific behaviours, they are often unconscious of the effect of implicit goals on these behaviours.\n\nDOJ-OGR-00005904",
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"content": "In order to gain access to their victim(s), offenders groom the environment and their potential victim's significant others (e.g. parents, carers, teachers, etc). This may mean the offender integrating themselves into society and places where they are likely to meet children. This will often be a position of trust. Offenders then begin grooming the adults in this community, specifically those who are significant to their potential victim, with the aim of creating an opportunity to access and abuse a child or children. van Dam (2001) reports that offenders are frequently charming, very helpful, and have insider status. This is often an important factor in gaining access to potential victims). As offenders help out in the community, they are considering how their efforts will be rewarded later when they can then abuse the children in that community. Offenders are often able to \"read the community like a book\" in that they assess what they \"need\" and fulfil these needs accordingly (Hare & Hart, 1993). They can make themselves indispensable, too good to be true and will freely undertake jobs that others do not want to do (Leberg, 1997).",
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"content": "Intrafamilial offenders often isolate the victim from their non-abusing parent, siblings and the outside world by developing an exclusive relationship with the child. For instance, they may encourage mothers to have more of a life outside the home, which then gives them increased opportunities to abuse their victims. Alternatively, they may isolate non-abusing parents from the outside world in order to prevent them from having people in whom to confide about any concerns (Leberg, 1997). Some offenders encourage mothers to develop an alcohol dependency, in part so that any future disclosures made lack credibility (Leberg, 1997). Other similar strategies employed to limit credibility include questioning the mother's parenting ability in front of friends and other family members. This may constitute part of their strategy for grooming the environment and significant others.",
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"content": "Grooming the environment and significant others can occur as a result of implicit or explicit planning; alternatively, access to a child may occur by chance. Ward and Hudson (2000) have developed a conceptual model of how child sex offenders' implicit planning or seemingly unimportant decisions (SUDs) implicate their offending behaviour by leading them to high-risk situations, i.e. contact with children. This appears to be automatic, because although offenders are conscious of their specific behaviours, they are often unconscious of the effect of implicit goals on these behaviours.",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 38 of 43\n294 S. Craven et al.\nGollwitzer and Schaal (1998, cited in Ward & Hudson, 2000) suggest that it is through automatic goal-dependent action plans that these SUDs manifest. Ward and Hudson (2000) propose that there are two such action plans: offence scripts and mental simulations. Offence scripts manifest as a result of associations that have developed between situations and behaviours; subsequently, in the presence of certain cues, offence scripts may be activated without any conscious awareness. This is a possible explanation of continued offending and relapse following treatment.\nAutomatic goal-dependent action plans can be activated regardless of whether an individual has committed any previous sexual crimes. This alternative involves mental simulation. Mental simulation is where an individual plans out in detail how he would commit an offence. As with offence scripts, the presence of certain cues may activate this implicit planning, resulting in the enactment of the individual's fantasies. The notion of implicit planning may provide a possible explanation why the majority of victims know their abuser, because the cues that activate the implicit planning are more likely to be present within the family or in relation to children in the immediate locality (i.e. the places where an individual spends the majority of his time).\nIt is reasonable to suggest that the fundamental human need to belong may present one possibility to further understand offenders' ability to identify a victim and groom the environment and significant others. Research has shown that a need to belong can affect very basic cognitive functions, e.g. attention and encoding of social information (Pickett, Gardner & Knowles, 2004). Pickett et al. found a positive relationship between a need to belong and sensitivity to social cues. Sexual offenders often come from neglectful, violent and dysfunctional backgrounds (Craissati, McClurg & Browne, 2002). This environment is unlikely to provide an abundance of opportunities for emotional closeness and thus offenders are likely to have a need to belong. In addition, a need to belong is related to low self-esteem (Pickett et al., 2004) and research to date suggests that child sex offenders typically have low self-esteem (Marshall, Anderson & Champagne, 1997). This is supportive of the idea that a need to belong facilitates offenders' identification and access to a victim, because of the associated increased sensitivity to social cues. Children may be approached because the offender perceives them to be less threatening than peers. Alternatively, offenders may be able to identify vulnerabilities in other people because they themselves are vulnerable and thus recognize these signs in others. This explanation would relate to offenders that commit offences following implicit planning. Offenders using explicit planning may also have a need to belong and the associated increased sensitivity to social cues, as a result of a need to belong to the family of community in order to groom and subsequently abuse a child. It is therefore suggested that, in the presence of a motivation to sexually abuse a child, a need to belong often facilitates the identification of a victim and grooming of the environment and significant others.\nGrooming the child\nGrooming the child is the most commonly recognized form of sexual grooming. In addition to a desire for sexual gratification, there may or may not be a relational aspect to the grooming process, depending on the offender's motivation to abuse. Sexual grooming has been considered by some to be analogous to adult courtship (e.g. Howitt, 1995). In addition, Herman (1981) and Christiansen and Blake (1990) talk about sexually abusive fathers adopting the role of suitor towards their daughter. In the case of intrafamilial abuse, the offender promotes the child in place of the mother (Leberg, 1997). Alternatively, the offender may interact with the child on the child's wavelength (van Dam, 2001). Wilson (1999) found\nDOJ-OGR-00005905",
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"content": "Gollwitzer and Schaal (1998, cited in Ward & Hudson, 2000) suggest that it is through automatic goal-dependent action plans that these SUDs manifest. Ward and Hudson (2000) propose that there are two such action plans: offence scripts and mental simulations. Offence scripts manifest as a result of associations that have developed between situations and behaviours; subsequently, in the presence of certain cues, offence scripts may be activated without any conscious awareness. This is a possible explanation of continued offending and relapse following treatment.",
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"content": "Automatic goal-dependent action plans can be activated regardless of whether an individual has committed any previous sexual crimes. This alternative involves mental simulation. Mental simulation is where an individual plans out in detail how he would commit an offence. As with offence scripts, the presence of certain cues may activate this implicit planning, resulting in the enactment of the individual's fantasies. The notion of implicit planning may provide a possible explanation why the majority of victims know their abuser, because the cues that activate the implicit planning are more likely to be present within the family or in relation to children in the immediate locality (i.e. the places where an individual spends the majority of his time).",
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"content": "It is reasonable to suggest that the fundamental human need to belong may present one possibility to further understand offenders' ability to identify a victim and groom the environment and significant others. Research has shown that a need to belong can affect very basic cognitive functions, e.g. attention and encoding of social information (Pickett, Gardner & Knowles, 2004). Pickett et al. found a positive relationship between a need to belong and sensitivity to social cues. Sexual offenders often come from neglectful, violent and dysfunctional backgrounds (Craissati, McClurg & Browne, 2002). This environment is unlikely to provide an abundance of opportunities for emotional closeness and thus offenders are likely to have a need to belong. In addition, a need to belong is related to low self-esteem (Pickett et al., 2004) and research to date suggests that child sex offenders typically have low self-esteem (Marshall, Anderson & Champagne, 1997). This is supportive of the idea that a need to belong facilitates offenders' identification and access to a victim, because of the associated increased sensitivity to social cues. Children may be approached because the offender perceives them to be less threatening than peers. Alternatively, offenders may be able to identify vulnerabilities in other people because they themselves are vulnerable and thus recognize these signs in others. This explanation would relate to offenders that commit offences following implicit planning. Offenders using explicit planning may also have a need to belong and the associated increased sensitivity to social cues, as a result of a need to belong to the family of community in order to groom and subsequently abuse a child. It is therefore suggested that, in the presence of a motivation to sexually abuse a child, a need to belong often facilitates the identification of a victim and grooming of the environment and significant others.",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 39 of 43\n\nSexual grooming of children 295\n\nthat offenders who abused boys showed a preference for interacting at the child's level, and incest offenders tended to raise the victim's status to that of an adult, while offenders who abused girls were more concerned with sexual gratification. The types of behaviour that constitute grooming the child take two different forms—physical and psychological.\n\nPhysical grooming involves the gradual sexualization of the relationship between the offender and the victim (Berliner & Conte, 1990). Psychological grooming is used to achieve this increased sexualization. At first, the offender may justify the sexual behaviour through providing the child with his or her version of sex education, which states that sex between children and adults is acceptable and that the offender has a responsibility to train the child for later life (Berliner & Conte, 1990; Leberg, 1997). The abuser builds the child's trust (Christiansen & Blake, 1990; Leberg, 1997; Wyre, 1987, cited in Howitt, 1995; van Dam, 2001), makes him or her feel good (Warner, 2000) and then starts to violate boundaries (Christiansen & Blake, 1990; van Dam, 2001). This may involve intentionally entering the bedroom while the child or young person is undressed, or getting dressed together and exposing himself to the child.\n\nOffenders often desensitize a child to touch by beginning with non-sexual touching such as tickling or stroking the child's head. Conversation may also become more sexual. Alternatively, offenders may confuse victims by continuing to talk to the child about a positive unrelated issue while they begin touching the child sexually (Leberg, 1997). The child may have no idea that something inappropriate is happening. The aim is to progress to sexual touching, first on top of clothes and later under or without clothes (Berliner & Conte, 1990; Christiansen & Blake, 1990; Leberg, 1997; van Dam, 2001). Thus, the intention is to make the child compliant with the offender's sexual demands and overcome the child's resistance (Finkelhor, 1984; Leberg, 1997; Warner, 2000).\n\nIn addition to using psychological grooming to increase compliance, it is also used to avoid disclosure. Children are groomed to want to be around the adult who is grooming them (Wolf, 1985). Offenders need to maintain the child's cooperation and secrecy to achieve this. One way that the offender does this is by isolating the child and alienating them from others (Warner, 2000). Leberg (1997) refers to this factor as something separate from grooming, others (e.g. van Dam, 2001) consider it to be part of the grooming process. Isolating the child creates a barrier which prevents the child from having a confidant in whom to disclose (Warner, 2000). In addition, the keeping of secrets acts as a source of further isolation (Lerner, 1993, cited in van Dam, 2001). Children are very good at keeping secrets when asked to. Peters (1991, cited in Ceci & Bruck, 1993) found that 82% of children in his study delayed or did not report an event that they had witnessed, because the thief in the scenario asked them not to tell anyone. The thief in this scenario was a stranger, to whom the children had no loyalty, and so it is likely that children would be even more likely to protect a known and loved adult.\n\nFurther strategies used by offenders to maintain the child's compliance include issuing threats and bribes (Berliner & Conte, 1990; Christiansen & Blake, 1990). Bribes may take the form of material gifts or extra privileges (Christiansen & Blake, 1990). In addition, offenders are skilled at using children's natural vulnerabilities against them. For instance, children very often have a strong desire to protect their parents. When the offender informs them that their parents would be very hurt if they found out what they had been doing, children may remain silent (Berliner & Conte, 1990). Offenders may also demonstrate their potential for violence through violence towards others, e.g. other family members. Thereby offenders reinforce the message that they will enact their threats about hurting the child and/or the child's family.\n\nDOJ-OGR-00005906",
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"content": "Physical grooming involves the gradual sexualization of the relationship between the offender and the victim (Berliner & Conte, 1990). Psychological grooming is used to achieve this increased sexualization. At first, the offender may justify the sexual behaviour through providing the child with his or her version of sex education, which states that sex between children and adults is acceptable and that the offender has a responsibility to train the child for later life (Berliner & Conte, 1990; Leberg, 1997). The abuser builds the child's trust (Christiansen & Blake, 1990; Leberg, 1997; Wyre, 1987, cited in Howitt, 1995; van Dam, 2001), makes him or her feel good (Warner, 2000) and then starts to violate boundaries (Christiansen & Blake, 1990; van Dam, 2001). This may involve intentionally entering the bedroom while the child or young person is undressed, or getting dressed together and exposing himself to the child.",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 40 of 43\n296 S. Craven et al.\n\nOffenders frequently make the child feel responsible for the abuse (Leberg, 1997; van Dam, 2001; Warner, 2000). They convince the child that they are to blame for letting the abuse happen and that they should have stopped it (Leberg, 1997). This is reinforced by stereotypes in society, which emphasize that men cannot control their sex drive (Warner, 2000). Additional guilt may be felt if the child has been made to perform sexual acts on the abuser or another child (Warner, 2000). However, this feeling of responsibility and guilt is overshadowed by the self-betrayal the child feels as their body reacts to sexual stimulation against their will (Warner, 2000) which children may interpret as evidence that they are enjoying themselves. This is internalized and resultantly may have an impact on the child's developing identity. Disclosure is avoided because the child feels that it is “all their fault”, that he/she is bad and that no one will believe them (Warner, 2000).\n\nEach victim's experience of grooming is different, because offenders adapt their strategies dependent on the child, whose response during the grooming process is important. It seems reasonable to suggest that offenders require some level of “empathy” during the grooming process to recognize reactions in the child, so that they can adapt their strategy accordingly. For example, during the desensitization process an offender would need to recognize the limits of the victim and to strategically increase those limits. It is proposed that empathy involves four components: (1) emotion recognition; (2) perspective-taking; (3) emotion replication; and (4) response decision (Marshall, Hudson, Jones & Fernandez, 1995). Continuing with the previous example, offenders recognize the distress in their victim and make a decision based on this, because they choose to stop temporally as a strategic part of the desensitization process. Thus, offenders appear to have ability in components (1) and (4), which are the cognitive components, but not in the affective components (2) and (3). While early research on empathy in sex offenders concluded that they have empathy deficits, more recent research has found that this empathy deficit to be victim-specific (Fernandez, Marshall, Lightbody & O'Sullivan, 1999; Marshall, Hamilton & Fernandez, 2001; Marshall et al., 1995). This is inconsistent with the suggestion that the grooming process requires some level of empathy. However, Fernandez et al. (1999; Marshall et al., 2001) provide a possible explanation for this. They suggest that victim-specific empathy deficits manifest as cognitive distortions, which protect the offenders from negatively evaluating themselves, thus allowing them to continue abusing a child. Based on this suggestion, victim-specific empathy deficits arise as a consequence rather than a cause of the abuse. These cognitive distortions therefore facilitate self-grooming.\n\nThe manifestation of a cognitive distortion relating to a victim-specific empathy deficit may be facilitated by cognitive deconstruction. Cognitive deconstruction (see Ward, Hudson & Marshall, 1995) is a state entered into to escape negative experiences and negative self-evaluation. Cognitive deconstruction involves processing at a lower, more concrete, level, i.e. muscular movements, and rewards of behaviour, rather than social action. Resultantly, the individual has much more focus on feelings of pleasure and less awareness of the consequences of his behaviour. This concrete-level focus may reinforce cognitive distortions such as victims enjoyed the abuse because they became physically aroused, which justifies the offender's lack of empathy toward their victim.\n\nSelf-grooming, grooming the environment and significant others, and grooming the child are relevant to situational and preferential offenders, extra-familial and intrafamilial offences. It is important that the different types of sexual grooming apply to these different typologies and classifications of offenders because sexual grooming is not used solely by one group of offenders and, furthermore, these categories are not mutually exclusive (Itzin, 2001).\n\nDOJ-OGR-00005907",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 41 of 43\nSexual grooming of children 297\n\nTowards a new definition of sexual grooming of children\n\nThe definitions of sexual grooming presented at the start of this review do not reflect the complexity of the sexual grooming of children, which is demonstrated in the previous discussion of the different types of sexual grooming. Based on the above findings it seems necessary to provide a new definition that attempts to encapsulate the complexity of sexual grooming, while still being easy to understand. We propose the following:\n\nA process by which a person prepares a child, significant adults and the environment for the abuse of this child. Specific goals include gaining access to the child, gaining the child's compliance and maintaining the child's secrecy to avoid disclosure. This process serves to strengthen the offender's abusive pattern, as it may be used as a means of justifying or denying their actions.\n\nConclusion\n\nDespite the wide acceptance of the term, sexual grooming of children is not understood clearly, particularly in the public domain. Testimonies from both victims and perpetrators highlight the pertinence of the problem. Furthermore, the government in England and Wales has introduced legislation in the Sexual Offences Act 2003 regarding \"meeting a child following sexual grooming\" (see Part 1: section 152003). A greater understanding of the meaning, elements and process of sexual grooming is required to effectively utilize this legislation (for review see Craven, Brown & Gilchrist, in press).\n\nRegardless of the prevalence and pertinence of sexual grooming, most aetiological theories of child sexual abuse neglect the phenomenon. The main reason for this is likely to be because prominent theories of child sexual abuse were devised more than 10 years ago, at a time when sexual grooming was not recognized as it is today. Therefore, it is necessary that theories be reconsidered based on this recent awareness. Ward (2001, 2002; Ward & Hudson, 2001; Ward & Siegert, 2002) has begun the process of theory knitting and development. While Ward and Siegert's Pathways Model is able to account for sexual grooming, it still focuses on the presence of opportunity rather than explicitly recognizing that offenders often create their own opportunities to offend.\n\nThe current review has identified three types of sexual grooming discussed in the literature: self-grooming, grooming the environment and significant others and grooming the child. Based on these findings an alternative definition has been suggested, which includes details about offenders' objectives, e.g. gaining access to a child, gaining the child's compliance, maintaining secrecy and avoiding disclosure.\n\nA fuller understanding of sexual grooming is required. Consideration needs to be given to offender–victim interaction (before, during and after the offence), micro behaviours that may indicate to significant adults that a child is being sexually groomed, or indeed that they themselves are being groomed by an offender, and the seemingly impossible task of proving beyond reasonable doubt that the ambiguous behaviour of sexual grooming is sexually motivated. This would provide many benefits to child protection and the policing and treatment of child sex offenders with a specific focus on prevention of child sexual abuse rather than reactive responses to it. To optimize the impact of acquired knowledge and understanding, it is necessary to consider how these findings are disseminated to the relevant groups involved with children, e.g. parents, police, and social workers.\n\nDOJ-OGR-00005908",
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"content": "Conclusion\n\nDespite the wide acceptance of the term, sexual grooming of children is not understood clearly, particularly in the public domain. Testimonies from both victims and perpetrators highlight the pertinence of the problem. Furthermore, the government in England and Wales has introduced legislation in the Sexual Offences Act 2003 regarding \"meeting a child following sexual grooming\" (see Part 1: section 152003). A greater understanding of the meaning, elements and process of sexual grooming is required to effectively utilize this legislation (for review see Craven, Brown & Gilchrist, in press).\n\nRegardless of the prevalence and pertinence of sexual grooming, most aetiological theories of child sexual abuse neglect the phenomenon. The main reason for this is likely to be because prominent theories of child sexual abuse were devised more than 10 years ago, at a time when sexual grooming was not recognized as it is today. Therefore, it is necessary that theories be reconsidered based on this recent awareness. Ward (2001, 2002; Ward & Hudson, 2001; Ward & Siegert, 2002) has begun the process of theory knitting and development. While Ward and Siegert's Pathways Model is able to account for sexual grooming, it still focuses on the presence of opportunity rather than explicitly recognizing that offenders often create their own opportunities to offend.",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-1 Filed 10/29/21 Page 43 of 43\nSexual grooming of children 299\nStop it Now (2003). What we all need to know to protect our children. Available at: http://www.stopitnow.org.uk/ Stop%2002.pdf (accessed December 2003).\nvan Dam, C. (2001). Identifying Child Molesters: Preventing Child Sexual Abuse by Recognizing the Patterns of the Offenders. Binghamton, NY: Haworth Maltreatment and Trauma Press/The Haworth Press, Inc.\nWard, T. (2001). A critique of Hall and Hirschman's quadripartite model of child sexual abuse. Psychology, Public Policy, and Law, 7, 333 350.\nWard, T. (2002). Marshall and Barbaree's integrated theory of child sexual abuse: A critique. Psychology, Crime and Law, 8, 209 228.\nWard, T. & Hudson, S. M. (2000). Sexual offenders' implicit planning: A conceptual model. Sexual Abuse: Journal of Research and Treatment, 12, 189 202.\nWard, T. & Hudson, S. M. (2001). Finkelhor's precondition model of child sexual abuse: A critique. Psychology, Crime and Law, 7, 291 307.\nWard, T., Hudson, S. M. & Marshall, W. L. (1995). Cognitive distortions and affective deficits in sex offenders: A cognitive deconstructionist interpretation. Sexual Abuse: Journal of Research and Treatment, 7, 67 83.\nWard, T. & Keenan, T. (1999). Child molesters' implicit theories. Journal of Interpersonal Violence, 14, 821 838.\nWard, T., Louden, K., Hudson, S. M. & Marshall, W. L. (1995). A descriptive model of the offense chain for child molesters. Journal of Interpersonal Violence, 10, 452 472.\nWard, T. & Siegert, R. (2002). Toward a comprehensive theory of child sexual abuse: A theory knitting perspective. Psychology, Crime and Law, 8, 319 351.\nWarner, S. (2000). Understanding Child Sexual Abuse: Making the Tactics Possible. Gloucester: Handsell.\nWilson, R. J. (1999). Emotional congruence in sexual offenders against children. Sexual Abuse: Journal of Research and Treatment, 11, 33 48.\nWolf, S. (1985). A multi-factor model of deviant sexuality. Victimology: An International Journal, 10, 359 374.\nDOJ-OGR-00005910",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 2 of 45 Review Manuscript TRAUMA, VIOLENCE, & ABUSE 2019, Vol. 20(2) 260–283 © The Author(s) 2017 Article reuse guidelines: sagepub.com/journals-permissions DOI: 10.1177/1524838017697312 journals.sagepub.com/home/tva SAGE Facilitators and Barriers to Child Sexual Abuse (CSA) Disclosures: A Research Update (2000–2016) Ramona Alaggia1, Delphine Collin-Vézina2, and Rusan Lateef1 Abstract Identifying and understanding factors that promote or inhibit child sexual abuse (CSA) disclosures has the potential to facilitate earlier disclosures, assist survivors to receive services without delay, and prevent further sexual victimization. Timely access to therapeutic services can mitigate risk to the mental health of survivors of all ages. This review of the research focuses on CSA disclosures with children, youth, and adults across the life course. Using Kiteley and Stogdon's literature review framework, 33 studies since 2000 were identified and analyzed to extrapolate the most convincing findings to be considered for practice and future research. The centering question asked: What is the state of CSA disclosure research and what can be learned to apply to practice and future research? Using Braun and Clarke's guidelines for thematic analysis, five themes emerged: (1) Disclosure is an iterative, interactive process rather than a discrete event best done within a relational context; (2) contemporary disclosure models reflect a social-ecological, person-in-environment orientation for understanding the complex interplay of individual, familial, contextual, and cultural factors involved in CSA disclosure; (3) age and gender significantly influence disclosure; (4) there is a lack of a life-course perspective; and (5) barriers to disclosure continue to outweigh facilitators. Although solid strides have been made in understanding CSA disclosures, the current state of knowledge does not fully capture a cohesive picture of disclosure processes and pathways over the life course. More research is needed on environmental, contextual, and cultural factors. Barriers continue to be identified more frequently than facilitators, although dialogical forums are emerging as important facilitators of CSA disclosure. Implications for practice in facilitating CSA disclosures are discussed with recommendations for future research. Keywords sexual abuse, child abuse, cultural contexts Introduction Timely access to supportive and therapeutic resources for child sexual abuse (CSA) survivors can mitigate risk to the health and mental health well-being of children, youth, and adults. Identifying and understanding factors that promote or inhibit CSA disclosures have the potential to facilitate earlier disclosures, assist survivors to receive services without delay, and potentially prevent further sexual victimization. Increased knowledge on both the factors and the processes involved in CSA disclosures is timely when research continues to show high rates of delayed disclosures (Collin-Vézina, Sablonniere, Palmer, & Milne, 2015; Crisma, Bascelli, Paci, & Romito, 2004; Easton, 2013; Goodman-Brown, Edelstein, Goodman, Jones, & Gordon, 2003; Hershkowitz, Lanes, & Lamb, 2007; Jonzon & Lindblad, 2004; McElvaney, 2015; Smith et al., 2000). Incidence studies in the United States and Canada report decreasing CSA rates (Fallon et al., 2015; Finkelhor, Shattuck, Turner, & Hamby, 2014; Trocmé et al., 2005, 2008), while at the same time global trends from systematic reviews and meta-analyses have found concerning rates of CSA, with averages of 18–20% for females and of 8–10% for males (Pereda, Guilera, Forns, & Gómez-Benito, 2009). The highest rates found for girls is in Australia (21.5%) and for boys in Africa (19.3%), with the lowest rates for both girls (11.3%) and boys (4.1%) reported in Asia (Stoltenborgh, van IJzendoorn, Euser, & Bakermans-Kranenburg, 2011). These findings point to the incongruence between the low number of official reports of 1Factor-Inwentash Faculty of Social Work, University of Toronto, Toronto, Ontario, Canada 2Centre for Research on Children and Families, School of Social Work, McGill University, Montreal, Quebec, Canada Corresponding Author: Ramona Alaggia, Factor-Inwentash Chair in Children's Mental Health, Factor-Inwentash Faculty of Social Work, University of Toronto, 246 Bloor St. West, Toronto, Ontario, Canada M4KIW1. Email: ramona.alaggia@utoronto.ca DOI-OGR-00005912",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 5 of 45 (continued) Table I. (continued) Study Purpose Design Sample Findings Summary McEvaney and Cu hane (2015) To investigate the feasibility of using child abuse assessment tools based on CSA disclosure. Victim disclosure interviews based on the QID. Female reports of children seen for assessment and CSA abuse unit in the hospital were reviewed. Sample and 17 years old. Majority were female, educated, and employed. White. Content analysis was conducted on 39 female and 7 male cases based on a coded framework. Parents were asked to have the child reveal for the study, were assessed. Majority of children (43%) were dent fed (1) lack of opportu nity to (2) opportu ty to self dent fed (3) Add ona themes of the b ing fed for cons dent fed shame/embarassment and peer influence were also dent fed. Perspectives of offenders on victim disclosure by victims rested during the offense. Majority of children and peers key to disclosure process. The sample size was small but with characteristics important to the study. Serves as an important exploratory process bringing forward potential themes for consideration. Disclosure processes sexua abuse perpetrator: with ntrarf perpetrator commit ted abuse and most (78.6%) of the victims did outs de the fam y take place more spontaneously and quickly; contrary, extrafam d sclosures done at school (80%) most often to the fam y member or a few other peers (94.6%) were abused by another adult. At time of the study, this was the largest qua tave data set to have been analyzed with an exp ct focus on adult male survivors' perceptions of barriers to CSA disclosure. Because the sample was med n terms of racial or ethnic differences (7.3%) disclosure differences based on race or ethnicity were not discerned. The majority of abuse reported was by c regy wh ch might present a un que set of barr ers to d sclosure. 220 of age (most age range 12-18 years) 78.2% were female victims, and 41.8% were male. In 14 cases, the perpetrator was a family member and in four cases, the perpetrator was a family member or acquaintance. Using qualitative content analysis, researchers conducted a secondary analysis on one study focus was on barriers to CSA disclosure with male survivors. Recruitment organization based survey. We Being organized from survey data, the 2010 CSA history survey, that used CSA history open-ended term on disclosure barriers. 460 men with CSA history completed an anonymous, Internet-based survey. Survey respondents were categorized into three domains of sociocultural: (1) interpersonal mistrust of others; (2) fear of not being believed; and (3) personal internal responses; past responses; and sexual abuse. Two thirds of respondents were of ages 18–84 years. Wh th respondents were Dumont, Messerschm tt: V a, Bohu, and Rey-Sal mon (2014) This study examined how the relationship between the perpetrator and victim, especially the victim at a or within the family, impact CSA disclosure. Female reports of children seen for assessment and CSA abuse unit in the hospital were reviewed. Easton, Salzman, and W s (2014)",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 7 of 45 (continued) Table 1. (continued) Study Hunter (2011) Schaeffer, Leventhal, and Asnes (2011) Summary Findings Design Purpose A majority of the 22 part c pants d d not make a d sclosure unt l and a er they ngs support agg s (2004) mode c disclosure but suff ent samp e sze s for very ng behav or nd rect attempts to category. cs d sclosure shou d be a comp ex process. An innovat ve study to try to assess can fac tate d sclosures of CSA. Data were based on a large number of nterv ews. Data ed anays s produced deta ed findings supporting other ngs on d sclosure. The barr ers to ch d sclosure dent f ed were: (1) ch d s w tnessed (e.g., the perpetrator abuse was a request ev dence of abuse) (e.g., the ch d was tntesed); (2) fears get n trouble she he to d); (3) ack of understand ng ty (e.g., the ch d fa ed to recogn zeabus ve behavior as unaccepta e); and (5) the perpetrator was a fr end not to burden them. Ear er d sclosures are reated to extra fam occurrence of v ct m abuse together, and parents who were vewed as conf dan ts samp e sze. More y out of 22 part c pants d d report h gher eve s of shame and se f-b ame about the r y sexua exper ences. Fear, shame and se f-b ame were further det ected n the man n tors d sclosure. The ngs are further det a ed and through subthemes. The ngs support agg s (2004) mode c disclosure but suff ent samp e sze s for very ng behav or nd rect attempts to category. cs d sclosure shou d be a comp ex process. Study sought to f nd out f 191 nterv ews of CSA v ct ms aged 3-18 over a 1-yr per od were add dress nqry ry about the process of a ch d s d sclosure; (2) determ ne f ch d s d sclosure fac l tated f orens c nterv ews Forens c nterv ewers were asked to incorporate quest ons about \"rea sons for d sclosure\" and to test f they \"ran\" or \"fy\" ed them to de ay d sclosure. Interview protoco related to the ex sting forens c nterv ew content. Interview protoco related to the ex sting forens c nterv ew content. ch d ren's reasons for d sclosure were extracted, transcribed and analyzed us ng grounded theory method of anays s. Sample community and couns ng serv ces v ct ms genera y, v ct m heath, and mental heath. Sexua Assault Module of the Juven le V ct m zat on used Narrat ve nqry ry methodo gy. Face-to-face nterv ews were conducted w th 713 women part c pants. Data were ana yzed us ng Rosentha s (2004) F-scher- Rosentha s (2004) method. Purpose of th s study was to deve op a fu er understand ng of CSA d sclosures. Th s study med to: (1) add dress nqry ry about the process of a ch d s d sclosure; (2) determ ne f ch d s d sclosure fac l tated f orens c nterv ews; (3) descr be factors that ed them to test f they \"ran\" or \"fy\" ed them to de ay d sclosure. 74% of ch dren were female and 51% were Caucas an 265 DOJ-OGR-00005917",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 8 of 45 (continued) Table I. (continued) Study Alaggia (2010) Fontes and Pummer (2010) Ungar, Barter, McConnech, Tutty, and Fathom. (2009a) Summary Findings Themes Sample Design Purpose The study presents a comprehensive socio-ecological analysis of CSA disclosure. Of note, 42% had disclosed the abuse during childhood; 26% had not disclosed because they had repressed the memory of the abuse; and the remainder had attempted some form of disclosure, but it was not successful. A retrospective approach that could be affected by recall issues. One of the few works that adds knowledge to cultural contextual factors affecting CSA disclosure. Uniquely combines findings with an in-depth study of CSA disclosure. Recommendations made to (1) disclose CSA details; (2) question cultural competency; and (3) culture stands as an important factor in disclosure, not so much in CSA cases which are not so different. Youths' experiences of CSA disclosure were examined in a national sample of 1621 youths. Evaluation forms were completed by youth owing to participation in abuse prevention programs.",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 9 of 45 (continued) Table 1. (continued) Study Design Purpose/findings Sample Summary Ungar, Tutty, McComne , Barter, and Fa rhom (2009b) This study explored abuse disclosure strategies with a nonrepresentative sample of 1,099 Canadian youth who completed own victimization forms Red Cross RespectED programming between 2000 and 2003 was the focus of the study. One of the goals of the study was to document not only youth's experiences of abuse but also their attitudes towards abuse prevention programs: (1) What forms of abuse disclosure barriers do youth face? (2) What's their abuse disclosure patterns? (3) What are youth's experiences with abuse disclosure? (4) What are youth's interactions with peers, educators, and caregivers? About three-quarters of youth disclosed; significantly more youth disclosed to peers than to adults. About half disclosed to CSA survivors. Findings suggest disclosure is a process, with expectations shaped by young people's previous experiences of abuse. Patterns of incremental disclosure were reported. Innovative designs of this study provide insights into young people's perceptions of good disclosure experiences. High trustworthiness of the data was ensured through use of youth focus groups, interviews, and observation data. The study results are somewhat limited because most of the descriptions of abuse can offer because of the clinical nature of the data. Regional survey-based differences may not have been picked up. Scope and approach were broad and creative. 1,099 youth evaluated forms of abuse disclosure. Out of 1,099 participants, 225 males and 779 females indicated that they had been abused. Of those, 43 males and 180 females disclosed the abuse. Of those who disclosed, a portion of males and females reported that they had disclosed to \"When I was abused\" or \"When I was younger\". 5% were directed towards professionals and others, with fewer choosing parents/family, and others. Twenty-seven interviewers and focus groups were so done to understand contextual issues and engage youth program facilitators in the interpretation of findings. A coding structure was developed for analyses to synthesize themes across data sources.",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 10 of 45 Table 1. (continued) Study Purpose Design Sample Findings Summary Priebe and Svedin (2008) This study aimed to investigate disclosure patterns and examine predictors of disclosure and nondisclosure. Participants completed 65-item questionnaires that included questions about background, consensual sex, sexual abuse experiences, noncontact abuse (e.g., exhibitionism), and female- and male-perpetrated CSA and whether they disclosed CSA or not. The sample consisted of 4,339 high school students in Sweden (2,324 boys). The mean age of the participants was 18.15 years. This study used a subsample of 1,962 participants who reported CSA and answered disclosure questions. Fewer had reported the abuse to a professional (contact abuse) with more severe CSA, but over 69% of boys (23%) and girls (6%) reported disclosure to someone. More of the sexual abuse boys experienced was key to disclosure; father or other male relative, rather than a female abuser. A qualitative component of the study provided a broader understanding of disclosure processes. Study focused on male survivors of CSA disclosure challenges for male survivors of CSA: (1) To understand three issues: (1) To understand",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 12 of 45\n\nTable I. (continued)\n\nStudy\n\nA gg a and K rts henbaum (2005)\n\nA gg a (2005)\n\nCo gngs Gr f f ths and Kuma o (2005)\n\n270\n\nPurpose ves of the current study were to\n\nf y a broad range\nof factors, nclud ng\nfam dynam cs that\ncontribute to or\n\nPurpose samp ng of men and women a ong\n\nh ndrose CSA\nwas\nto quetate y exp ore\nor promote d scosure\nby exa n ng a range\nof factors nclud ng\ngender c dynam c-\n\nThe study's purpose was\nto quetate y exp ore\n\nSummary\n\nOver ha f the part c pants had not\nd closed the abuse dur ng ch hood. Of the nond sclosers,\npart c pants x d scose\nbecause they had repressed or\nforgotten the memory. A most\none th rd of the d scosure\n\nThree themes emerged for men that\nnh b ted or prec p tated d scosure: (1) reasons re ated to gender\n\nContent ana ys s dent f ed two broad\nd mens ons of d scosure: (1) agency:\nch-d nated d scosure versus\n\nThese resu ts ft nto A gg a's (2004)\nd scosure framework. Through\ndata ana ys s, two raters coded\n\nF nd ngs\n\nFour major themes emerged suggest ng\nthat CSA d scosure can be seen as a\ncond t ng when certa n fam-\n\nneeded on γ. More data are\ngarner more nformat on on\nd sc osure.\n\nprec bant for d sc osure, and (3) fea that\nprec bant for nond sc osure. Two\npredom nant themes w th ffect\n\nauthor's d scosure es us a\ndef ned four d screte categor es ons\nwh ch proved to be both\nexhaustive and mutua y excusive\n\n(continued)\n\n1,737 cases of CSA\nDurban area of KwZulu-Nata, South\nAfr ca v ct ms\n\nTwo study\nobject ves to: (1)\nexam ne how and\n\nDes gn\n\nA qua tat ve og ca\ndes gn—LIM—was\nused to e ct\n\nd scosure\n\nSurv vors of CSA were\nnterv ewed about\nther d scosure\n\nNarrat ve nterv ews were\nconducted to capture fam y eve\nfactors. Axa and\n\nL ne-by- ne open\ncod ng was conducted\nto capture fam y eve\nfactors and\n\nStudy exam ned patterns\nof d scosure n a arge\nrepresentat ve samp e\nof South Afr can CSA\nv ct ms\n\n1,614 g rls and\n2001 to December\n2003 g ts and\n\n1,737 cases of CSA reported to the North Durban\n\nobject ves to: (1)\nexam ne how and\n\nDOJ-OGR-00005922",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 13 of 45 (continued) Table 1. (continued) Study | Purpose | Design | Sample | Findings | Summary Hershkovitz and Lamb (2005) | To identify characteristics of suspected child abuse victims that are associated with disclosure during interviews | Large database of suspected cases of child abuse between 1998 and 2002 was analyzed. Interviews using standardized NICHD Protocol were conducted. Interview data were analyzed. | The sample comprised 26,446 children aged 3- to 14-years-old. 65% of the 26,446 children reported sexual abuse and physical abuse was reported in 6% of cases. Analyses only involved cases that had come to the attention of the agency making the referral. Disclosure rates increased 1- to 5-year-olds: 50% to 67%; 6- to 10-year-olds: 67% to 74%; and 11- to 14-year-olds: 74% disclosed abuse when questioned. None of the children were asked about physical abuse. Evidence for delayed disclosure was found. The results indicate that disclosure is a fundamental process that becomes more difficult the longer it is delayed. Children first told a family member. Shorter delay was more likely when the perpetrator was a family member. Over 90% of the 26,446 children made key findings of disclosure. Rates of disclosure varied systematically depending on the nature of the alleged offenses and the relationship between the victim and the suspected perpetrator. Children aged 3- to 6-years-old were less likely to disclose abuse during a forensic interview. Disclosure rates grew with age. | Generalizability of this study is limited by the fact that the sample was comprised of children who were referred for assessment referred through a police report. Overall findings indicate that rates of disclosure vary systematically depending on the nature of the alleged offenses and the relationship between the victim and the suspected perpetrator. Analyses only involved cases that had come to the attention of the agency making the referral. Disclosure rates increased 1- to 5-year-olds: 50% to 67%; 6- to 10-year-olds: 67% to 74%; and 11- to 14-year-olds: 74% disclosed abuse when questioned. None of the children were asked about physical abuse. Evidence for delayed disclosure was found. The results indicate that disclosure is a fundamental process that becomes more difficult the longer it is delayed. Children first told a family member. Shorter delay was more likely when the perpetrator was a family member. Strengthening parent-child relationships is an important practice when the child's experiences are taken into account. Jensen, Jørundsen, Mossige, and Tjersland (2005) | To study how children and parents were able to report their experiences in the context of an interview which dated back to what made them talk about sexual abuse experiences; the reactions of the parents; and what the parents and children perceived as helpful in the disclosure process. | Qualitative approach to data collection was used. Therapeutic conversations were analyzed through a tentative approach. | 20 families were interviewed 22 times in total. 3-4 participants in each family were interviewed. Children and parents were interviewed separately. Follow-up interviews were held 1 year after the initial interviews. | The study involved 20 families with a total of 22 children. Children aged 3-15 years (average age 7.5 years) and 16 adults participated. Sexually abused children felt it was difficult to share their experiences with someone in the family or close relative. When the child's experiences were taken into account, a purpose to talk, a connection on what they are talking about, and strengthening parent-child relationships is an important practice when the child's experiences are taken into account. | DOJ-OGR-00005923 271",
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"content": "Hershkovitz and Lamb (2005) | To identify characteristics of suspected child abuse victims that are associated with disclosure during interviews | Large database of suspected cases of child abuse between 1998 and 2002 was analyzed. Interviews using standardized NICHD Protocol were conducted. Interview data were analyzed. | The sample comprised 26,446 children aged 3- to 14-years-old. 65% of the 26,446 children reported sexual abuse and physical abuse was reported in 6% of cases. Analyses only involved cases that had come to the attention of the agency making the referral. Disclosure rates increased 1- to 5-year-olds: 50% to 67%; 6- to 10-year-olds: 67% to 74%; and 11- to 14-year-olds: 74% disclosed abuse when questioned. None of the children were asked about physical abuse. Evidence for delayed disclosure was found. The results indicate that disclosure is a fundamental process that becomes more difficult the longer it is delayed. Children first told a family member. Shorter delay was more likely when the perpetrator was a family member. | Generalizability of this study is limited by the fact that the sample was comprised of children who were referred for assessment referred through a police report. Overall findings indicate that rates of disclosure vary systematically depending on the nature of the alleged offenses and the relationship between the victim and the suspected perpetrator. Analyses only involved cases that had come to the attention of the agency making the referral. Disclosure rates increased 1- to 5-year-olds: 50% to 67%; 6- to 10-year-olds: 67% to 74%; and 11- to 14-year-olds: 74% disclosed abuse when questioned. None of the children were asked about physical abuse. Evidence for delayed disclosure was found. The results indicate that disclosure is a fundamental process that becomes more difficult the longer it is delayed. Children first told a family member. Shorter delay was more likely when the perpetrator was a family member. Strengthening parent-child relationships is an important practice when the child's experiences are taken into account.",
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"content": "Jensen, Jørundsen, Mossige, and Tjersland (2005) | To study how children and parents were able to report their experiences in the context of an interview which dated back to what made them talk about sexual abuse experiences; the reactions of the parents; and what the parents and children perceived as helpful in the disclosure process. | Qualitative approach to data collection was used. Therapeutic conversations were analyzed through a tentative approach. | 20 families were interviewed 22 times in total. 3-4 participants in each family were interviewed. Children and parents were interviewed separately. Follow-up interviews were held 1 year after the initial interviews. | The study involved 20 families with a total of 22 children. Children aged 3-15 years (average age 7.5 years) and 16 adults participated. Sexually abused children felt it was difficult to share their experiences with someone in the family or close relative. When the child's experiences were taken into account, a purpose to talk, a connection on what they are talking about, and strengthening parent-child relationships is an important practice when the child's experiences are taken into account.",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 17 of 45 Table 1. (continued) Study Purpose Design Sample questionnaire for childhood abuse characteristics and the disclosure. Child disclosure, perception of response and fear of negative consequences probed. Correlate analyses were conducted with path analyses to test the hypothesized causal relations among variables. The study focus was to gather data from a large sample of women about the length of time to disclosure. Structured telephone interviews were conducted with approximately 2,009 women who reported being sexually assaulted before age 18 and who were randomly selected from a sample of 2,009 respondents. A computer-assisted telephone interviewing (CATI) system was used to conduct the interviews. Random digit dialing (RDD) was used to select the sample. The survey consisted of several measures designed to assess the disclosure of child sexual abuse and its consequences. The present study reports on data from the demographic and disclosure variables. Two probability samples, Wave 1 and Wave 2, were selected from the 1989 and 1995 National Crime Victimization Surveys (NCVS). The average age at the time of the first rape was 10.9 years. Of the 288 women who reported being sexually assaulted, 28% stated that they had told no one about the assault at the time it occurred. The time frame of this survey may have had contextual influences on the major types of events reported in the sample. The average number of sexual assaults (including CSA) reported was 2.09. Anyone queried by the interviewer was considered to be a disclosure. Approximately 47% of women between 18 and 34 years old reported being sexually assaulted. Fewer than 10% of victims reported making a report to law enforcement personnel. On average, 12% of child rape victims stated that they had reported the assault to someone. The time frame of this survey may have influenced the major types of events reported in the sample. The average number of sexual assaults (including CSA) reported was 2.09. Anyone queried by the interviewer was considered to be a disclosure. Summary negative consequences to disclosure took longer to disclose. We designed a study with a high level of rigor. Produced a valuable mode of disclosure for further investigation. Researchers were not able to interview children. However, perceptions were not able to be determined. Findings negative consequences to disclosure took longer to disclose. Children who brought harm to others took longer to disclose. Fear of negative consequences to disclosure took longer to disclose. Approximately 47% of women between 18 and 34 years old reported being sexually assaulted. Smith, LeTourneau, Saunders, K. Patrick, Resnick and Best (2000) Note. SCL-90 = Symptom Check-List-90; SES = socioeconomic status; LIM = long interview method; CSA = child sexual abuse; NCHD = National Institute of Child Health and Human Development; QIS = Questionnaire Informatique sur les Aggressions Sexuelles; NWS = National Women's Study; DSA = Disclosure of Sexual Abuse; NSA = National Survey of Adolescents.",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 26 of 45\nChild Abuse Review Vol. 24: 159–169 (2015)\nPublished online 9 May 2015 in Wiley Online Library\n(wileyonlinelibrary.com) DOI: 10.1002/car.2280\nDisclosure of Child Sexual Abuse: Delays, Non-disclosure and Partial Disclosure. What the research Tells Us and Implications for Practice\nRosaleen McElvaney\nSchool of Nursing and Human Sciences, Dublin City University, Dublin, Ireland\nThis paper reviews the research on disclosure of child sexual abuse with specific reference to delays in disclosing, non-disclosure and partial disclosure of experiences of child sexual abuse. Findings from large-scale national probability studies highlight the prevalence of both non-disclosure and delays in disclosure, while findings from small-scale qualitative studies portray the complexity, diversity and individuality of experiences. The possible explanations regarding why children are reluctant to disclose such experiences have significant implications for addressing the issue of child sexual abuse from the perspectives of child protection, legal and therapeutic professionals. The importance of understanding the dynamics of disclosure, in particular the needs of young people to maintain control over the disclosure process, the important role that peers play in this process, the responses of adults in both informal and formal networks, and the opportunities to tell, is key to helping young people speak more promptly about their experiences of sexual abuse.\nCopyright © 2013 John Wiley & Sons, Ltd.\nKey Practitioner Messages:\n- Children typically delay disclosing experiences of abuse.\n- Asking children questions about their wellbeing gives them the opportunity to tell when they are ready.\n- The challenge is to find the right questions at the right time.\n- Peers can be the right people to ask these questions.\n- Adolescents need to know about how to ask and what to do if someone tells.\nKey Words: child sex abuse; disclosure; research to practice\nAn issue of increasing concern in recent years is the phenomenon of delayed disclosure of childhood sexual abuse and the need to understand the process of how children and adults disclose their experiences of child sexual abuse, given the implications for child protection, social justice and\n*Correspondence to: Rosaleen McElvaney, School of Nursing and Human Sciences, Dublin City University, Glasnevin, Dublin 9, Ireland. E-mail: rosaleen.mcelvaney@dcu.ie\nCopyright © 2013 John Wiley & Sons, Ltd.\nAccepted: 17 February 2013\nDOI-OGR-00005936",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 27 of 45\n160\nMcElvaney\n\n'This paper reviews the research on disclosure patterns of childhood sexual abuse'\n\nmental health outcomes. This paper reviews the research on disclosure patterns of childhood sexual abuse, specifically delays in disclosure, non-disclosure (as evident through adult retrospective studies) and partial disclosures, and discusses implications for practice. Literature searches of the online databases PSYCINFO and Social Sciences Citation Index, in addition to manual searches of texts published since 2000, were conducted using the search terms 'child sexual abuse', 'sex abuse' and 'disclosure'.\n\nThe research to date on disclosure patterns is based on two sampling methodologies - studies of adults reporting retrospective experiences and studies of children. The former group of studies has the benefit of drawing on large-scale national probability samples which can be considered to be representative of the general population. The latter group with some small exceptions (predominantly adolescent studies) uses samples of young people who have disclosed sexual abuse but would not be considered as representative of all children who have been abused:\n\n'children who decide to tell someone about being sexually abused and whose cases therefore come to court are not representative of sexually abused children in general' (Olafson and Lederman, 2006, p. 29).\n\nPatterns of Disclosure: Delays and Non-disclosure\n\n'Most people who experience sexual abuse in childhood do not disclose this abuse until adulthood'\n\nThere is consensus in the research literature that most people who experience sexual abuse in childhood do not disclose this abuse until adulthood, and when disclosure does occur in childhood, significant delays are common. Table 1 summarises two large-scale studies to highlight the extent of delays in disclosure and the percentage of those who did not disclose to anyone prior to the study.\n\nKogan (2004) examined the timing of disclosure of unwanted sexual experiences in childhood or adolescence in a sub-sample (n = 263 adolescent women, aged 12 to 17) of the National Survey of Adolescents (Kilpatrick and Saunders, 1995) in the USA - a nationally representative study. Kogan's results can be summarised as follows: immediate disclosure (within 1 month) 43 per cent, delayed disclosure (less than 1 year) 31 per cent and non-disclosure (disclosed only during the survey) 26 per cent. Smith and colleagues (2000) examined a sub-sample (n = 288) of the National Women's Study in the USA (Resnick et al., 1993, cited in Smith et al., 2000) who had reported a childhood rape prior to the age of 18. Smith et al.'s findings can be summarised as follows: immediate disclosure (within 1 month) 27 per cent, delayed disclosure (more than a year) 58 per cent and non-disclosure (survey only) 28 per cent. Those who had never disclosed prior to the survey constitute comparable proportions in these two studies while the rates for immediate disclosure and delayed disclosure vary.\n\nTable 1. Patterns of disclosure - delay and non-disclosure\n\n| | Kogan (2004) (n = 263 adolescents) | Smith et al. (2000) (n = 288 adults) |\n|----------------|--------------------------------|--------------------------------------|\n| Told within 24 hours | 24% | 18% |\n| Told within 1 month | 19% | 9% |\n| Told within 1 year | 12% | 11% |\n| Delayed telling more than 1 year | 19% | 47% |\n| Never told before survey | 26% | 28% |\n\nCopyright © 2013 John Wiley & Sons, Ltd. Child Abuse Rev. Vol. 24: 159–169 (2015)\nDOI: 10.1002/car\nDOJ-OGR-00005937",
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"content": "There is consensus in the research literature that most people who experience sexual abuse in childhood do not disclose this abuse until adulthood, and when disclosure does occur in childhood, significant delays are common. Table 1 summarises two large-scale studies to highlight the extent of delays in disclosure and the percentage of those who did not disclose to anyone prior to the study.Kogan (2004) examined the timing of disclosure of unwanted sexual experiences in childhood or adolescence in a sub-sample (n = 263 adolescent women, aged 12 to 17) of the National Survey of Adolescents (Kilpatrick and Saunders, 1995) in the USA - a nationally representative study. Kogan's results can be summarised as follows: immediate disclosure (within 1 month) 43 per cent, delayed disclosure (less than 1 year) 31 per cent and non-disclosure (disclosed only during the survey) 26 per cent. Smith and colleagues (2000) examined a sub-sample (n = 288) of the National Women's Study in the USA (Resnick et al., 1993, cited in Smith et al., 2000) who had reported a childhood rape prior to the age of 18. Smith et al.'s findings can be summarised as follows: immediate disclosure (within 1 month) 27 per cent, delayed disclosure (more than a year) 58 per cent and non-disclosure (survey only) 28 per cent. Those who had never disclosed prior to the survey constitute comparable proportions in these two studies while the rates for immediate disclosure and delayed disclosure vary.",
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"content": "| | Kogan (2004) (n = 263 adolescents) | Smith et al. (2000) (n = 288 adults) |\n|----------------|--------------------------------|--------------------------------------|\n| Told within 24 hours | 24% | 18% |\n| Told within 1 month | 19% | 9% |\n| Told within 1 year | 12% | 11% |\n| Delayed telling more than 1 year | 19% | 47% |\n| Never told before survey | 26% | 28% |",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 28 of 45 Disclosure Patterns in Child Sexual Abuse 161 disclosure are higher in the adolescent study than in the adult study, a reassuring finding given the increased awareness of sexual abuse in society during the past 20 years. Goodman-Brown and colleagues (2003) examined USA district attorney files of 218 children. Their categories were slightly different from the previous two studies but in summary, immediate disclosers (within 1 month) constituted 64 per cent of the sample while 29 per cent disclosed within six months. This study is unusual insofar as the sample studied had reported their experience of abuse to the authorities and a prosecution was in progress. Goodman-Brown et al. also pointed out that families who participated in this study were more likely to represent those children who experienced abuse by someone outside the family. Research has found that delays in disclosure are longer for those abused within the family (Sjoberg and Lindblad, 2002; Goodman-Brown et al., 2003; Kogan, 2004; Hershkowitz et al., 2005). Therefore, children who disclose more promptly may be overrepresented in legal samples. In Sweden, Priebe and Svedin (2008) conducted a national survey of 4339 adolescents, of whom 1962 reported some form of sexual abuse (65% of girls and 23% of boys). Details of the time lapse in disclosing were not available from this study. However, of those who had disclosed and answered the questions on disclosure (n = 1493), 59.5 per cent had told no-one of their experiences prior to the survey. Of those who did disclose, 80.5 per cent mentioned a 'friend of my own age' as the only person who they had told. In this study, 6.8 per cent had reported their experiences to the social authorities or police. A further Swedish study of 122 women who had experienced childhood sexual abuse (Jonson and Lindblad, 2004) found that 32 per cent disclosed during childhood (before the age of 18) while the majority told in adulthood (68%). The delay was up to 49 years, with an average of 21 years (SD = 12.9). Of those who told in childhood, 59 per cent told only one person. In Ireland, the SAVI study (n = 3118, McGee et al., 2002) found that 47 per cent of those respondents who had experienced some form of sexual assault prior to age 17 had told no-one of this experience until the survey. McElvaney (2002) investigated delay in a legal sample of ten adults who had made formal complaints of childhood sexual abuse in Ireland and found delays ranging from 20 years to 50 years. Studies of children in the context of forensic/investigative interviews where children are interviewed by professionals due to concerns that the child has been sexually abused also point to high non-disclosure rates, particularly striking in cases where there is corroborative evidence that abuse has occurred - medical evidence (Lyon, 2007), or confessions from the abuser or videotaped evidence/witness reports (Sjoberg and Lindblad, 2002). Lyon (2007) reported his findings from a review of studies published between 1965 and 1993 of children diagnosed with gonorrhoea where the average disclosure rate among 579 children was 43 per cent (n = 250). In a study where the evidence for the abuse was available on videotape, children have denied abuse when interviewed by the police (Sjoberg and Lindblad, 2002). In summary, significant numbers of children do not disclose experiences of sexual abuse until adulthood and adult survey results suggest that significant 'The rates for immediate disclosure are lower in the adolescent study than in the adult study' 'Children who disclose more promptly may be overrepresented in legal samples' 'Delays ranging from 20 years to 50 years' Copyright © 2013 John Wiley & Sons, Ltd. Child Abuse Rev. Vol. 24: 159 169 (2015) DOI: 10.1002/car DOJ-OGR-00005938",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 29 of 45\n162 McElvaney\n\n'High numbers of respondents disclosing to researchers for the first time'\nproportions of adults have never disclosed such abuse, as evidenced by the high numbers of respondents disclosing to researchers for the first time.\n\nPatterns of Disclosure - Partial Disclosure\nInformation on how children disclose over time can be obtained from studies of children who participated in forensic/investigative interviews where children are interviewed by professionals due to concerns that the child has been sexually abused. The issue of partial disclosures was highlighted by earlier studies such as those by DeVoe and Faller (1999) of five- to ten-year olds (i.e. making detailed informal disclosures that were not replicated in formal interviews) and Elliott and Briere (1994) of children aged eight to 15 years (i.e. disclosing only partial information until confronted with external evidence that led to more complete disclosures).\nMore recently, investigators have examined the role of the interviewer and questioning styles in the forensic interview and how this impacts on children's disclosures and the level of detail provided in interview. Hershkowitz et al. (2006) compared tapes of interviews with children who disclosed sexual abuse and those who did not (but about whom there was 'substantial' reason to believe that they had been abused). They found that interviewers behaved differently with the two groups, using different types of prompts with children who presented as somewhat uncooperative, offered fewer details and gave more uninformative responses at the beginning of the interview. It would appear that interviewers responded to less communicative children by increasing the proportion of closed questions which in turn led to children being less forthcoming. Lamb et al. (2002) have found that the use of a protocol that emphasises the use of prompts that elicit free narrative (e.g. 'tell me about that') as compared with closed questions (those requiring a yes/no response) has resulted in more detail and more accuracy in children's accounts.\n\n'They found that interviewers behaved differently with the two groups'\n\nAlthough few studies exist that examine the phenomenon of disclosure in informal settings (when disclosure is made to a friend or family member), some qualitative studies have described this process. McElvaney (2008) quoted one teenage girl who described hinting to her mother prior to disclosing the experience: 'I didn't tell her what happened but I was saying things that made her think it made her think that it happened but I didn't tell her' (p. 127). A parent described how her teenage son told her over a period of days, keeping the most difficult parts of the story until last:\n\n'He came out with like it came out over two or three days so you know...he'd say well I've something else to tell you... the bad stuff last... what hurt him most and what he's saying what hurt him most' (p. 92)\n\nAnd finally, one young person described how she told her social worker:\n\n'I couldn't tell her most things but I just gave things to her to read... I told her at first I told her bits of it and em then just the others. I finished writing and then I gave them to her... later I told her that it was the father as well.' (p. 93)\n\nThis young person had been abused by both a father and son in a family with whom she was staying.\n\nChild Abuse Rev. Vol. 24: 159 169 (2015)\nDOI: 10.1002/car\n\nCopyright 2013 John Wiley & Sons, Ltd.\nDOJ-OGR-00005939",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 30 of 45 Disclosure Patterns in Child Sexual Abuse 163 In reviewing the literature on this subject, London and colleagues (2005) noted, 'when children do disclose, it often takes them a long time to do so' (p. 204). Reasons for Patterns of Delay, Partial Disclosure and Non-disclosure There are many influences on disclosure that have been identified in the research literature to help explain why it is that children delay disclosure, are reluctant to disclose, provide details of their experiences over time or do not disclose at all. Age has been identified as a significant predictor of disclosure in that younger children are less likely to disclose than older children. Children who are abused by a family member are less likely to disclose and more likely to delay disclosure than those abused by someone outside the family (Smith et al., 2000; Goodman-Brown et al., 2003; Kogan, 2004). Children who do disclose during forensic interviews compared to children who do not disclose in such contexts (yet concerns remain that they have been abused) are more likely to have parents (particularly mothers) who are more supportive (Lawson and Chaffin, 1992). In Priebe and Svedin's (2008) study of young people, parental bonding (positive relationship with parent who was not overprotective) was identified as the most significant predictor of disclosure for both boys and girls. However, close relationships can also act as an inhibitor to disclosure. McElvaney (2008) found that many young people in her study were reluctant to disclose due to concerns of upsetting their parents while others were concerned about the consequences of others of their disclosure. One 13-year-old girl described her concern that if she told, her uncle would go to jail and her small cousins would be left without a father: 'I didn't want them to grow up with no Dad and just looking at ... their other little friends having their Dad holding their hand I felt like I was taking their Dad away from them' (p. 130) Gender has been found to influence disclosure in that boys appear to be more reluctant to disclose than girls (Goodman-Brown et al., 2003; Hershkowitz et al., 2005; Ungar et al., 2009a). Mental health difficulties on the part of the child have also been found to be relevant, particularly when children experience dissociative symptoms or other post-traumatic stress symptomatology (Priebe and Svedin, 2008). Some studies have found that the severity of abuse (e.g. penetrative abuse) predicts earlier disclosure while other studies have found no relationship between different types of abuse and disclosure timing. Similarly, the relationship between the duration of abuse - one-off incidents of abuse compared with abuse that takes place over a significant period of time - and timely disclosure has been investigated with mixed findings. Fear of the consequences of disclosure has been identified as a predictor of delayed disclosure and this in turn is associated with the age of the child (Goodman-Brown et al., 2003). Older children are more cognitively competent in terms of being able to reflect on and anticipate possible reactions to their disclosure. This can act then as an inhibitor to disclosure, although as noted above, most studies have found that older children are more likely to disclose than younger children. Fears of not being believed have been described by young people as inhibiting their disclosure and these fears are often \"When children do disclose, it often takes them a long time to do so\" 'Younger children are less likely to disclose than older children' 'Many young people in her study were reluctant to disclose due to concerns of upsetting their parents' 'Fear of the consequences of disclosure has been identified as a predictor of delayed disclosure' Copyright © 2013 John Wiley & Sons, Ltd. Child Abuse Rev. Vol. 24: 159 169 (2015) DOI: 10.1002/car DOJ-OGR-00005940",
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"content": "Gender has been found to influence disclosure in that boys appear to be more reluctant to disclose than girls (Goodman-Brown et al., 2003; Hershkowitz et al., 2005; Ungar et al., 2009a). Mental health difficulties on the part of the child have also been found to be relevant, particularly when children experience dissociative symptoms or other post-traumatic stress symptomatology (Priebe and Svedin, 2008). Some studies have found that the severity of abuse (e.g. penetrative abuse) predicts earlier disclosure while other studies have found no relationship between different types of abuse and disclosure timing. Similarly, the relationship between the duration of abuse - one-off incidents of abuse compared with abuse that takes place over a significant period of time - and timely disclosure has been investigated with mixed findings. Fear of the consequences of disclosure has been identified as a predictor of delayed disclosure and this in turn is associated with the age of the child (Goodman-Brown et al., 2003). Older children are more cognitively competent in terms of being able to reflect on and anticipate possible reactions to their disclosure. This can act then as an inhibitor to disclosure, although as noted above, most studies have found that older children are more likely to disclose than younger children. Fears of not being believed have been described by young people as inhibiting their disclosure and these fears are often",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 31 of 45\n\n164 McElvaney\n\njustified. Hershkowitz et al. (2007) interviewed children about their initial disclosures prior to formal interview and 50 per cent of the sample (n = 30) reported feeling afraid or ashamed of their parents' reaction. The authors reported that parents did show a tendency to blame their children and react angrily to the disclosure.\n\nRecent research has highlighted the need for children to be asked direct questions to facilitate their disclosure. Of those children who did disclose, significant proportions disclosed following prompts rather than it being initiated by the child (Kogan, 2004). Qualitative studies drawing on interviews with children that focus on the disclosure process are important in investigating the precise circumstances that led to disclosures for children. McElvaney (2008) found that parents' questioning of children was prompted by their concern about the young person's emotional distress. On occasion, young people were communicating that something was not right in their world but were not able to articulate this verbally. Signs of psychological distress were, however, evident and questions targeted at the reasons for this distress were identified by McElvaney as a factor that helped young people to tell. Thus, many children may not have told about their experiences of abuse because they were not asked. McGee et al. (2002) followed up a sample of their respondents who had disclosed childhood abuse for the first time in their survey. When asked why they had not disclosed prior to the survey, many respondents noted that it was because they had not been asked. Increasingly, research studies are finding that significant proportions of disclosure have been prompted by questions by caregivers, friends or others in the child's educational and social milieu that in themselves provide an opportunity for the young person to tell (Jensen et al., 2005; Hershkowitz et al., 2007; McElvaney et al., 2012).\n\n'Investigating the precise circumstances that led to disclosures for children'\n\n'Significant proportions of disclosure have been prompted by questions by caregivers, friends or others'\n\nFinally, some children need time to tell. Mudaly and Goddard (2006) quote a 13-year-old girl: 'she (mother) helped by not making me, not rushing me to get it out, which, um, I think it's a really stupid idea to make kids get it out A.S.A.P.' (p. 91).\n\nImplications for Practice\n\nThe consensus in the research literature at the present time is that disclosure is multi-determined, influenced by a complex range of factors that may influence each child in a different way. Large-scale national probability studies confirm that non-disclosure and delays in disclosure are significant problems facing society and in particular for those professionals tasked with safeguarding the wellbeing of children. Children's fears and anxieties in relation to telling need to be understood and contained by those in their environment so that early disclosure can be encouraged and facilitated.\n\n'The implications of these findings can be considered in interrelated contexts'\n\nThe implications of these findings can be considered in interrelated contexts: the legal context where action can only be taken if the child is able to give a clear, credible account of his/her experiences; child protection and therapeutic contexts where a comprehensive account is required to enable child protection professionals to intervene and where the psychological sequelae can be addressed to minimise the long-term impact of the experiences; and family and community contexts where early disclosure needs to be encouraged, and\n\nCopyright © 2013 John Wiley & Sons, Ltd. Child Abuse Rev. Vol. 24: 159–169 (2015) DOI: 10.1002/car DOJ-OGR-00005941",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 32 of 45 Disclosure Patterns in Child Sexual Abuse 165 other family issues addressed in the aftermath of disclosure and where peers play an important role. Studies have confirmed the importance of professionals asking children and young people in a sensitive, open manner about possible experiences of abuse using non-leading questioning styles to minimise inaccurate accounts or contaminate children's narratives. It is clearly important for professionals to remain open to the possibility of abuse and further disclosure. It is equally important for professionals to be able to avoid persisting with questioning those children who are 'reluctant disclosers'. Similarly, professionals engaged with children in therapeutic work need to be open to the possibility of both initial and further disclosures. Contradiction in witness statements is a well-known feature of false statements and giving additional detail to original formal statements can be interpreted within child protection, therapeutic and legal contexts as a contradiction of an earlier account. Listening to children's accounts of their experiences of disclosure helps us understand why it is that disclosure can be delayed and that when they do feel ready to tell this is not an 'all or nothing' decision. As one young person in Staller and Nelson-Gardell's (2005) study noted, 'it's never finished, never' p. 1426. This understanding in turn helps us identify those circumstances and reactions that may encourage the child to disclose. The importance of asking children questions, thus giving them an opportunity to tell, has been identified. While parents, teachers and those in daily contact with children are often reluctant to question children, it is clear that many children do not disclose unless given this opportunity. Education and increased awareness are needed on how to question children in an appropriate manner. McElvaney (2008) noted that questions did not need to be about sexual abuse per se, but rather questions prompted by the young person's psychological distress, asking after the young people's wellbeing. This questioning in effect acted as an external pressure for the young person to tell his/her secret (McElvaney et al., 2012). In Ungar et al.'s (2009a) study of Canadian youth, they found that young people used a range of disclosure strategies ranging from less direct strategies (such as risk-taking behaviours, not talking about the abuse) to direct strategies (such as seeking support from peers, turning to non-professional adult supports, disclosing to formal service providers), representing a process that relied heavily on others to 'build the bridges between the youth and formal care providers' (p. 352). The tendency to delay disclosing and the partial nature of many disclosures are not conducive to successful legal investigations and prosecutions. In addition, the knowledge base that exists within the legal sphere is limited if only a percentage of the children who experience sexual abuse engage with this system. The disproportionately high 'immediate disclosure' rate found in Goodman-Brown et al.'s (2003) legal sample compared to Kogan's (2004) community sample raises the question of the representation of delayed disclosers in the legal system. Are children who delay in disclosing less likely to engage with the legal system? Are delays in disclosing contributing to decisions not to prosecute child sexual abuse crimes? In Ireland, the 1990s saw a significant increase in the numbers of complainants coming before the courts reporting experiences of childhood sexual abuse. Many of these cases were referred to the higher courts for judicial review proceedings to establish whether the cases could proceed without prejudicing the accused given the Copyright © 2013 John Wiley & Sons, Ltd. 'Contradiction in witness statements is a well-known feature of false statements' 'Education and increased awareness are needed on how to question children in an appropriate manner' 'Are children who delay in disclosing less likely to engage with the legal system?' Child Abuse Rev. Vol. 24: 159 169 (2015) DOI: 10.1002/car DOJ-OGR-00005942",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 34 of 45\nDisclosure Patterns in Child Sexual Abuse 167\npressure for young people by providing opportunities to tell may be needed to help young people tell more promptly. However, the lack of control that young people experience following disclosure remains an issue (Ungar et al., 2009b; Quayle et al., 2012). This highlights the need for dissemination of information directly to young people about the legal process, the possible consequences of disclosure, as well as ongoing developments in legal proceedings when young people and their families interface with the legal system.\nThe more recent focus on investigating those strategies that children use in making disclosures rather than solely on identifying barriers to disclosure is perhaps more helpful in informing awareness-raising campaigns and professional interventions. The author is involved in a large-scale review of children's files in an assessment service to ascertain those factors that helped children tell about their experiences of sexual abuse. A pilot study has suggested that this is an appropriate methodology for gathering data on children's experiences of informal disclosure, acknowledging the limitations of such an approach. Ungar et al. (2009a) describe the optimal conditions for disclosure as follows: being directly asked about experiences of abuse; having access to someone who will listen, believe and respond appropriately; having knowledge and language about what constitutes abuse and how to access help; having a sense of control over the process of disclosure both in terms of their anonymity (not being identified until they are ready for this) and confidentiality (the right to control who knows); and effective responses by adults both in informal and formal contexts.\nUngar et al. (2009b) support recent developments in prevention programmes that target supportive formal and informal caregivers in being better able to detect the possibility of abuse and support disclosures rather than focusing on empowering children themselves in making disclosures. Their findings in relation to the importance of bridge building for young people to access formal supports are supported by Jensen et al.'s (2005) emphasis on the dialogical nature of disclosure, and the important role that trusted adults and peers play in the disclosure process through noticing signs of psychological distress and asking young people about their psychological wellbeing (Collings et al., 2005; Jensen et al., 2005; McElvaney et al., 2012). More emphasis is therefore needed on providing opportunities for children and young people to disclose. The challenge for professionals and those who care for children is how to do this in a way that protects children and promotes their wellbeing.\nReferences\nCollings SJ, Griffiths S, Kumalo M. 2005. Patterns of disclosure in child sexual abuse. South African Journal of Psychology 35(2): 270 285.\nDeVoe ER, Faller KC. 1999.The characteristics of disclosure among children who may have been sexually abused. Child Maltreatment 4: 217 227.\nElliott DM, Briere J. 1994. Forensic sexual abuse evaluations of older children: Disclosures and symptomatology. Behavioral Sciences & the Law 12: 261 277.\nGoodman Brown TB, Edelstein RS, Goodman GS, Jones DPH, Gordon DS. 2003. Why children tell: A model of children's disclosure of sexual abuse. Child Abuse & Neglect 27: 525 540.\nHershkowitz I, Horowitz D, Lamb ME. 2005. Trends in children's disclosure of abuse in Israel: A national study. Child Abuse & Neglect 29(11): 1203 1214.\nHershkowitz I, Orbach Y, Lamb ME, Sternberg KJ, Horowitz D. 2006. Dynamics of forensic interviews with suspected abuse victims who do not disclose. Child Abuse & Neglect 30: 753 769.\n'More recent focus on investigating those strategies that children use in making disclosures'\n'Having a sense of control over the process of disclosure both in terms of their anonymity and confidentiality'\nCopyright 2013 John Wiley & Sons, Ltd.\nChild Abuse Rev. Vol. 24: 159 169 (2015)\nDOI: 10.1002/car\nDOJ-OGR-00005944",
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"full_text": "Case 1:20-cr-00330-PAE Document 397-2 Filed 10/29/21 Page 42 of 45\nIva A. E. Bicanic et al.\nTable 3. Demographic and (post-)rape characteristics by disclosure time (early vs. delayed disclosers) and odds ratios for delayed disclosure\n\nDemographic and (post-)rape characteristics\tEarly disclosure (N = 185)\tDelayed disclosure (i.e., > 1-week post-rape), N = 131\t\t\t\nN\t%\tN\t%\tOR\t95% CI\nAge category (years)\t\t\t\t\t\t\n18 25\t55\t17.4\t22\t7.0\t\t\n12 17\t130\t41.1\t109\t34.5\t2.10\t1.20 3.65*\nDutch origin\t\t\t\t\t\t\nNo\t27\t8.5\t22\t7.0\t\t\nYes\t158\t50.0\t109\t34.5\t0.85\t0.46 1.56\nLiving with parent(s)\t\t\t\t\t\t\nNo\t29\t9.2\t16\t5.1\t\t\nYes\t155\t49.2\t115\t36.5\t1.35\t0.70 2.59\nComplete family structure\t\t\t\t\t\t\nNo\t58\t18.4\t42\t13.3\t\t\nYes\t127\t40.3\t88\t27.9\t0.96\t0.59 1.55\nCurrent sexual relationship\t\t\t\t\t\t\nNo\t127\t41.8\t97\t31.9\t\t\nYes\t53\t17.4\t27\t8.9\t0.67\t0.39 1.14\nPrior negative sexual experience(s)\t\t\t\t\t\t\nNo\t152\t49.4\t110\t35.7\t\t\nYes\t32\t10.4\t14\t4.5\t0.61\t0.31 1.19\nKnown assailant\t\t\t\t\t\t\nNo\t56\t17.7\t36\t11.4\t\t\nYes\t129\t40.8\t95\t30.1\t1.15\t0.70 1.88\nClose to assailant\t\t\t\t\t\t\nNo\t150\t47.6\t84\t26.7\t\t\nYes\t35\t11.1\t46\t14.6\t2.35\t1.40 3.93*\nGroup rape\t\t\t\t\t\t\nNo\t160\t50.8\t116\t36.8\t\t\nYes\t24\t7.6\t15\t4.8\t0.86\t0.43 1.71\nAge of assailant (years)\t\t\t\t\t\t\n12 17\t63\t20.6\t54\t17.6\t\t\n> 18\t117\t38.2\t72\t23.5\t0.72\t0.45 1.14\nUse of penetration\t\t\t\t\t\t\nNo\t46\t14.7\t19\t6.1\t\t\nYes\t136\t43.5\t112\t35.8\t1.99\t1.10 3.60*\nUse of threats\t\t\t\t\t\t\nNo\t90\t31.6\t48\t16.8\t\t\nYes\t76\t26.7\t71\t24.9\t1.75\t1.09 2.82*\nUse of physical violence\t\t\t\t\t\t\nNo\t130\t42.6\t82\t26.9\t\t\nYes\t51\t16.7\t42\t13.8\t1.31\t0.80 2.14\nVictim's alcohol use\t\t\t\t\t\t\nNo\t72\t33.5\t69\t32.1\t\t\nYes\t61\t28.4\t13\t6.0\t0.22\t0.11 0.44*\n*p < 0.05.\nSeven participants were dropped from analyses due to missing disclosure time data.\nmember, or mentor. This finding is consistent with previous studies showing that the closer the relationship between the victim and assailant, the less likely the young woman was to report this victimization to anyone (Koss, 1988; Rickert et al., 2005; Wolitzky-Taylor et al., 2011). The dynamics of intrafamilial abuse is often proposed as\n6\n(page number not for citation purpose)\nCitation: European Journal of Psychotraumatology 2015, 6: 25883 http://dx.doi.org/10.3402/ejpt.v6.25883\nDOJ-OGR-00005952",
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"content": "Demographic and (post-)rape characteristics\tEarly disclosure (N = 185)\tDelayed disclosure (i.e., > 1-week post-rape), N = 131\t\t\t\nN\t%\tN\t%\tOR\t95% CI\nAge category (years)\t\t\t\t\t\t\n18 25\t55\t17.4\t22\t7.0\t\t\n12 17\t130\t41.1\t109\t34.5\t2.10\t1.20 3.65*\nDutch origin\t\t\t\t\t\t\nNo\t27\t8.5\t22\t7.0\t\t\nYes\t158\t50.0\t109\t34.5\t0.85\t0.46 1.56\nLiving with parent(s)\t\t\t\t\t\t\nNo\t29\t9.2\t16\t5.1\t\t\nYes\t155\t49.2\t115\t36.5\t1.35\t0.70 2.59\nComplete family structure\t\t\t\t\t\t\nNo\t58\t18.4\t42\t13.3\t\t\nYes\t127\t40.3\t88\t27.9\t0.96\t0.59 1.55\nCurrent sexual relationship\t\t\t\t\t\t\nNo\t127\t41.8\t97\t31.9\t\t\nYes\t53\t17.4\t27\t8.9\t0.67\t0.39 1.14\nPrior negative sexual experience(s)\t\t\t\t\t\t\nNo\t152\t49.4\t110\t35.7\t\t\nYes\t32\t10.4\t14\t4.5\t0.61\t0.31 1.19\nKnown assailant\t\t\t\t\t\t\nNo\t56\t17.7\t36\t11.4\t\t\nYes\t129\t40.8\t95\t30.1\t1.15\t0.70 1.88\nClose to assailant\t\t\t\t\t\t\nNo\t150\t47.6\t84\t26.7\t\t\nYes\t35\t11.1\t46\t14.6\t2.35\t1.40 3.93*\nGroup rape\t\t\t\t\t\t\nNo\t160\t50.8\t116\t36.8\t\t\nYes\t24\t7.6\t15\t4.8\t0.86\t0.43 1.71\nAge of assailant (years)\t\t\t\t\t\t\n12 17\t63\t20.6\t54\t17.6\t\t\n> 18\t117\t38.2\t72\t23.5\t0.72\t0.45 1.14\nUse of penetration\t\t\t\t\t\t\nNo\t46\t14.7\t19\t6.1\t\t\nYes\t136\t43.5\t112\t35.8\t1.99\t1.10 3.60*\nUse of threats\t\t\t\t\t\t\nNo\t90\t31.6\t48\t16.8\t\t\nYes\t76\t26.7\t71\t24.9\t1.75\t1.09 2.82*\nUse of physical violence\t\t\t\t\t\t\nNo\t130\t42.6\t82\t26.9\t\t\nYes\t51\t16.7\t42\t13.8\t1.31\t0.80 2.14\nVictim's alcohol use\t\t\t\t\t\t\nNo\t72\t33.5\t69\t32.1\t\t\nYes\t61\t28.4\t13\t6.0\t0.22\t0.11 0.44*\n*p < 0.05.",
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 1 of 52\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\nUNITED STATES OF AMERICA,\n\nv.\n\nGHISLAINE MAXWELL,\n\nDefendant.\n\nS2 20 Cr. 330 (AJN)\n\nGHISLAINE MAXWELL'S REPLY IN SUPPORT OF\nHER MOTIONS IN LIMINE\n\nJeffrey S. Pagliuca\nLaura A. Menninger\nHADDON, MORGAN & FOREMAN P.C.\n150 East 10th Avenue\nDenver, CO 80203\nPhone: 303-831-7364\n\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue\nNew York, NY 10022\nPhone: 212-957-7600\n\nBobbi C. Sternheim\nLaw Offices of Bobbi C. Sternheim\n225 Broadway, Suite 715\nNew York, NY 10007\nPhone: 212-243-1100\n\nAttorneys for Ghislaine Maxwell\n\nDOJ-OGR-00005956",
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 2 of 52\n\nTABLE OF CONTENTS\n\nI. THIS COURT SHOULD PRECLUDE INTRODUCTION OF ALLEGED CO-CONSPIRATOR STATEMENTS AS A SANCTION FOR GOVERNMENT'S FAILURE TO COMPLY WITH THIS COURT'S SEPTEMBER 3, 2021 ORDER 1\nA. The Court's Order was Neither Ambiguous Nor Misread by the Defense....................... 1\nB. The Court Has the Authority to Require Disclosure ....................................... 2\nC. There Should Be a Sanction ................................................................ 4\nD. There are Substantial Issues with the Government's Anticipated Position .................... 5\nII. GOVERNMENT CONCEDEDLY FAILED TO GIVE NOTICE OF THE BASIS OR REASONING TO ADMIT ANY 404(B) EVIDENCE 6\nA. The Emails Bear No Relationship to the Charged Conspiracy, Reflect Pure Propensity Evidence, and Otherwise are Unduly Prejudicial to Uninvolved Third-Party Adults. 7\nB. ....................................................................................................... 11\n1. ....................................................................................................... 12\n2. The government has apparently abandoned efforts to introduce her testimony as Rule 404(b) evidence. ............................................................................... 13\n3. ....................................................................................................... constitutes an impermissible constructive amendment and variance to the Indictment. .................... 13\nC. Ms. Maxwell reiterates her request to defer briefing and ruling on the admissibility ....................................................................................................... for two weeks. .................... 15\nIII. THIS COURT SHOULD EXCLUDE LISA ROCCHIO'S TESTIMONY UNDER FEDERAL RULE OF EVIDENCE 702 AND DAUBERT V. MERRELL DOW PHARMACEUTICALS, INC., 509 U.S. 579 (1993) AND GRANT A DAUBERT HEARING 15\nA. This Court should reject the government's arguments to the extent that they are based on newly disclosed material, which this Court ordered the government to produce six months ago. ....................................................................................................... 15\nB. Rocchio's proposed testimony is inadmissible......................................... 17\nC. At a minimum, this Court should hold a Daubert hearing. ........................... 23\nIV. THE COURT SHOULD EXCLUDE EVIDENCE RELATED ....................................................................................................... 24\nV. THE GOVERNMENT CONCEDES THAT IT WILL NOT OFFER EVIDENCE OF MS. MAXWELL'S ALLEGED \"FLIGHT\" 32\ni\nDOJ-OGR-00005957",
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155
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61
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81
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 7 of 52\n\nGhislaine Maxwell hereby submits her Reply In Support of Her Motions in Limine.\n\nI. THIS COURT SHOULD PRECLUDE INTRODUCTION OF ALLEGED CO-CONSPIRATOR STATEMENTS AS A SANCTION FOR GOVERNMENT'S FAILURE TO COMPLY WITH THIS COURT'S SEPTEMBER 3, 2021 ORDER\n\nThe government offers several excuses for its failure to comply with this Court's September 3, 2021 Order. These excuses are insufficient and should be rejected.\n\nA. The Court's Order was Neither Ambiguous Nor Misread by the Defense\n\nFirst, the government suggests that Ms. Maxwell has misread the Order. We disagree. The Court unambiguously rejected the government's position and ruled that the government's expressed concern about disclosure \"does not outweigh the risk of surprise to the Defendant in this case or the need for the parties to litigate co-conspirator issues in advance of trial to ensure the absence of delay.\" Dkt. 335 at 3. To both \"avoid the risk of surprise\" and \"litigate co-conspirator issues in advance of trial to ensure the absence of delay,\" the Court identified two things that were necessary from the government: First, no later than October 11, 2021, the government was required to \"disclose to the defense the identities of any unnamed co-conspirators who allegedly participated in the conspiracies charged in the S2 indictment to whom the government will refer at trial.\" Id. Second, the Court, unambiguously and emphatically, directed: \"The Government is FURTHER ORDERED to disclose all co-conspirator hearsay statements it intends to offer at trial no later than October 11, as consistent with this Court's scheduling order. Dkt. No. 297 at 1.\" (emphasis in original.)\n\nThe Court used the word \"disclose\" both as to the identity of the co-conspirators \"to whom the government will refer at trial\" and \"all co-conspirator hearsay statements it intends to offer at trial....\" The government, in an attempt to blunt the Order, decided to interpret the same word, \"disclose\" in materially distinct fashions. As to the identity of the co-conspirators, the government disclosed (i.e., identified) three names. When it was parsing the second part of\n\n1\n\nDOJ-OGR-00005962",
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"content": "First, the government suggests that Ms. Maxwell has misread the Order. We disagree. The Court unambiguously rejected the government's position and ruled that the government's expressed concern about disclosure \"does not outweigh the risk of surprise to the Defendant in this case or the need for the parties to litigate co-conspirator issues in advance of trial to ensure the absence of delay.\" Dkt. 335 at 3. To both \"avoid the risk of surprise\" and \"litigate co-conspirator issues in advance of trial to ensure the absence of delay,\" the Court identified two things that were necessary from the government: First, no later than October 11, 2021, the government was required to \"disclose to the defense the identities of any unnamed co-conspirators who allegedly participated in the conspiracies charged in the S2 indictment to whom the government will refer at trial.\" Id. Second, the Court, unambiguously and emphatically, directed: \"The Government is FURTHER ORDERED to disclose all co-conspirator hearsay statements it intends to offer at trial no later than October 11, as consistent with this Court's scheduling order. Dkt. No. 297 at 1.\" (emphasis in original.)",
"position": "middle"
},
{
"type": "printed",
"content": "The Court used the word \"disclose\" both as to the identity of the co-conspirators \"to whom the government will refer at trial\" and \"all co-conspirator hearsay statements it intends to offer at trial....\" The government, in an attempt to blunt the Order, decided to interpret the same word, \"disclose\" in materially distinct fashions. As to the identity of the co-conspirators, the government disclosed (i.e., identified) three names. When it was parsing the second part of",
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"type": "printed",
"content": "1",
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{
"type": "printed",
"content": "DOJ-OGR-00005962",
"position": "footer"
}
],
"entities": {
"people": [
"Ghislaine Maxwell",
"Ms. Maxwell"
],
"organizations": [
"Government"
],
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"dates": [
"September 3, 2021",
"October 11, 2021",
"10/29/21"
],
"reference_numbers": [
"1:20-cr-00330-PAE",
"Document 398",
"Dkt. 335",
"Dkt. No. 297",
"DOJ-OGR-00005962"
]
},
"additional_notes": "The document appears to be a court filing related to the case of Ghislaine Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 7 of 52."
}

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{
"document_metadata": {
"page_number": "8",
"document_number": "398",
"date": "10/29/21",
"document_type": "court document",
"has_handwriting": false,
"has_stamps": false
},
"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 8 of 52\n\nthe Order, however, the government defined the word \"disclose\" differently. Disclose, as to the actual statements, according to the government, means \"produced\" at some time in the past or to be produced in the future, perhaps as an oral statement during trial.\n\nOf course, the Court will tell the parties whether it meant two completely different things when it used the same word, as argued by the government, or whether it intended for the government to disclose the statements it intends to offer as co-conspirator statements. To avoid delay over this issue during trial, Ms. Maxwell suggests that she cannot litigate this issue in advance of trial without knowing what statements are being offered under Federal Rule of Evidence 801(d)(2)(e).\n\nWhat is clear from the government's response is not that it misunderstood the Order, but rather, it continues to disagree with the Order.\n\nB. The Court Has the Authority to Require Disclosure\n\nSecond, doubling down on its disagreement with the Court, the government claims \"it is aware of no such case\" in which a court ordered the identification of anticipated co-conspirator statements prior to trial. While the government may not be \"aware\" of such cases, they certainly, and abundantly, exist.\n\nIn United States v. Bocio, 103 F. Supp. 2d 531, 534 (N.D.N.Y. 2000), the court ordered pretrial disclosure of statements of co-conspirators (Government \"must disclose to the defendant and make available for inspection, copying, or photographing: any relevant written or recorded statements ..., or copies thereof, within the possession, custody, or control of the government.\").\n\nIn United States v. Jacobs, 650 F. Supp. 2d 160, 171 (D. Conn. 2009), the court ordered co-conspirator statements be produced in advance of trial (\"In the case of a co-conspirator who the government plans to call as a witness at trial, that time is now, and the government is directed to produce any relevant statement to defense counsel forthwith.\")\n\n2\n\nDOJ-OGR-00005963",
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{
"type": "printed",
"content": "the Order, however, the government defined the word \"disclose\" differently. Disclose, as to the actual statements, according to the government, means \"produced\" at some time in the past or to be produced in the future, perhaps as an oral statement during trial.",
"position": "top"
},
{
"type": "printed",
"content": "Of course, the Court will tell the parties whether it meant two completely different things when it used the same word, as argued by the government, or whether it intended for the government to disclose the statements it intends to offer as co-conspirator statements. To avoid delay over this issue during trial, Ms. Maxwell suggests that she cannot litigate this issue in advance of trial without knowing what statements are being offered under Federal Rule of Evidence 801(d)(2)(e).",
"position": "middle"
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{
"type": "printed",
"content": "What is clear from the government's response is not that it misunderstood the Order, but rather, it continues to disagree with the Order.",
"position": "middle"
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{
"type": "printed",
"content": "B. The Court Has the Authority to Require Disclosure",
"position": "middle"
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{
"type": "printed",
"content": "Second, doubling down on its disagreement with the Court, the government claims \"it is aware of no such case\" in which a court ordered the identification of anticipated co-conspirator statements prior to trial. While the government may not be \"aware\" of such cases, they certainly, and abundantly, exist.",
"position": "middle"
},
{
"type": "printed",
"content": "In United States v. Bocio, 103 F. Supp. 2d 531, 534 (N.D.N.Y. 2000), the court ordered pretrial disclosure of statements of co-conspirators (Government \"must disclose to the defendant and make available for inspection, copying, or photographing: any relevant written or recorded statements ..., or copies thereof, within the possession, custody, or control of the government.\").",
"position": "middle"
},
{
"type": "printed",
"content": "In United States v. Jacobs, 650 F. Supp. 2d 160, 171 (D. Conn. 2009), the court ordered co-conspirator statements be produced in advance of trial (\"In the case of a co-conspirator who the government plans to call as a witness at trial, that time is now, and the government is directed to produce any relevant statement to defense counsel forthwith.\")",
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"additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 8 of a 52-page document."
}

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{
"document_metadata": {
"page_number": "9",
"document_number": "398",
"date": "10/29/21",
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 9 of 52\n\nIn United States v. Velez, No. 3:10CR147 JBA, 2010 WL 4929266, at *7 (D. Conn. Nov. 30, 2010), the defendant moved for disclosure of any co-conspirator statements in advance of trial. In response, the government agreed to disclose \"well in advance of trial, exactly which of the intercepted telephone calls will be offered as full exhibits at trial and transcripts of those calls will be provided in advance of trial.\" Based on that representation the court denied the motion to produce as moot, \"without prejudice to renew if the Government fails to comply with its ongoing disclosure obligations.\" Id.\n\nIn United States v. Smalls, No. CR 06-2403 RB, 2008 WL 11361098, at *8-9 (D.N.M. Jan. 24, 2008), the court's order was very detailed:\n\nThe United States is hereby instructed to:\n\nfile a supplemental brief identifying the summary witness; specifically identifying each and every coconspirator statement it intends to offer at trial as evidence against Defendants pursuant to Fed. R. Evid. 801(d)(2)(E); and stating how each proffered statement satisfies the requirements of Rule 801(d)(2)(E). Specifically, with respect to each alleged coconspirator statement, the United States must indicate: a) the identity of the coconspirator who made the alleged statement; b) the identity of the person or persons to whom the coconspirator statement was made; c) the identity of the witness who will testify at trial about the coconspirator statement; d) the content of the coconspirator statement; e) when the statement was made; f) how the statement is in the course of the alleged conspiracy; and g) how the statement is in furtherance of the alleged conspiracy. Additionally, the United States must identify the independent evidence it intends to offer in support of admission of the alleged coconspirator statements.\n\nSee also United States v. Brewington, No. 15-CR-00073-PAB, 2018 WL 1411274, at *3 (D. Colo. Mar. 21, 2018) (court required the government to identify and produce all its purported 801(d)(2)(e) statements, in the hundreds; held an evidentiary pre-trial hearing about the admissibility of those statements; and made detailed, statement by statement rulings about admissibility, excluding some and conditionally admitting others); United States v. Bozeman, No. 3:11-CR-129, 2012 WL 1071207, at *14 (E.D. Tenn. Mar. 29, 2012), aff'd, No. 3:11-CR-\n\n3\n\nDOJ-OGR-00005964",
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"content": "In United States v. Velez, No. 3:10CR147 JBA, 2010 WL 4929266, at *7 (D. Conn. Nov. 30, 2010), the defendant moved for disclosure of any co-conspirator statements in advance of trial. In response, the government agreed to disclose \"well in advance of trial, exactly which of the intercepted telephone calls will be offered as full exhibits at trial and transcripts of those calls will be provided in advance of trial.\" Based on that representation the court denied the motion to produce as moot, \"without prejudice to renew if the Government fails to comply with its ongoing disclosure obligations.\" Id.",
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"content": "In United States v. Smalls, No. CR 06-2403 RB, 2008 WL 11361098, at *8-9 (D.N.M. Jan. 24, 2008), the court's order was very detailed:",
"position": "main body"
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{
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"content": "The United States is hereby instructed to:\n\nfile a supplemental brief identifying the summary witness; specifically identifying each and every coconspirator statement it intends to offer at trial as evidence against Defendants pursuant to Fed. R. Evid. 801(d)(2)(E); and stating how each proffered statement satisfies the requirements of Rule 801(d)(2)(E). Specifically, with respect to each alleged coconspirator statement, the United States must indicate: a) the identity of the coconspirator who made the alleged statement; b) the identity of the person or persons to whom the coconspirator statement was made; c) the identity of the witness who will testify at trial about the coconspirator statement; d) the content of the coconspirator statement; e) when the statement was made; f) how the statement is in the course of the alleged conspiracy; and g) how the statement is in furtherance of the alleged conspiracy. Additionally, the United States must identify the independent evidence it intends to offer in support of admission of the alleged coconspirator statements.",
"position": "main body"
},
{
"type": "printed",
"content": "See also United States v. Brewington, No. 15-CR-00073-PAB, 2018 WL 1411274, at *3 (D. Colo. Mar. 21, 2018) (court required the government to identify and produce all its purported 801(d)(2)(e) statements, in the hundreds; held an evidentiary pre-trial hearing about the admissibility of those statements; and made detailed, statement by statement rulings about admissibility, excluding some and conditionally admitting others); United States v. Bozeman, No. 3:11-CR-129, 2012 WL 1071207, at *14 (E.D. Tenn. Mar. 29, 2012), aff'd, No. 3:11-CR-",
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"additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}

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{
"document_metadata": {
"page_number": "10",
"document_number": "398",
"date": "10/29/21",
"document_type": "court document",
"has_handwriting": false,
"has_stamps": false
},
"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 10 of 52\n\n129-1, 2012 WL 1565099 (E.D. Tenn. May 1, 2012) (government must disclose any statements of co-conspirators that it intends to use at trial three weeks prior to the trial).\n\nThere is ample legal authority for the Court to enter the Order to avoid delays and arguments during trial about what statements are or are not within the 10-year conspiracy alleged here and to prevent surprise and prejudice to the Defendant.\n\nC. There Should Be a Sanction\n\nHedging its bets, the government acknowledges that it \"may have misread the court's order\" but offers no solution other than the defense is \"free to litigate the admissibility of any such statement during trial.\" This was the government's losing argument before the Order.\n\nDistrict courts have broad discretion to sanction a party who violates discovery orders. United States v. Golyansky, 291 F.3d 1245, 1249 (10th Cir. 2002). In considering a particular remedy for a violation, the factors considered are \"the reasons why disclosure was not made, the extent of the prejudice, if any, to the opposing party, the feasibility of rectifying that prejudice by a continuance, and any other relevant circumstances.\" United States v. Lee, 834 F.3d 145, 159 (2d Cir. 2016) (quoting United States v. Pineros, 532 F.2d 868, 871 (2d Cir. 1976)). The appropriate remedy is exclusion. Ms. Maxwell has been in jail for approximately 18 months. She is trying not to request a continuance of the trial and her lawyers are making every effort to review massive amounts of discovery, interview potential witness, prepare for trial, and juggle a myriad of other responsibilities. The government offers no legitimate excuse for non-compliance. It clearly knows what statements it will try to introduce, it just does not want to tell anyone to avoid challenges to the statements. This is willful, not negligent or inadvertent conduct which should not be sanctioned by the Court.\n\n4\n\nDOJ-OGR-00005965",
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"content": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 10 of 52",
"position": "header"
},
{
"type": "printed",
"content": "129-1, 2012 WL 1565099 (E.D. Tenn. May 1, 2012) (government must disclose any statements of co-conspirators that it intends to use at trial three weeks prior to the trial).\n\nThere is ample legal authority for the Court to enter the Order to avoid delays and arguments during trial about what statements are or are not within the 10-year conspiracy alleged here and to prevent surprise and prejudice to the Defendant.",
"position": "top"
},
{
"type": "printed",
"content": "C. There Should Be a Sanction",
"position": "middle"
},
{
"type": "printed",
"content": "Hedging its bets, the government acknowledges that it \"may have misread the court's order\" but offers no solution other than the defense is \"free to litigate the admissibility of any such statement during trial.\" This was the government's losing argument before the Order.\n\nDistrict courts have broad discretion to sanction a party who violates discovery orders. United States v. Golyansky, 291 F.3d 1245, 1249 (10th Cir. 2002). In considering a particular remedy for a violation, the factors considered are \"the reasons why disclosure was not made, the extent of the prejudice, if any, to the opposing party, the feasibility of rectifying that prejudice by a continuance, and any other relevant circumstances.\" United States v. Lee, 834 F.3d 145, 159 (2d Cir. 2016) (quoting United States v. Pineros, 532 F.2d 868, 871 (2d Cir. 1976)). The appropriate remedy is exclusion. Ms. Maxwell has been in jail for approximately 18 months. She is trying not to request a continuance of the trial and her lawyers are making every effort to review massive amounts of discovery, interview potential witness, prepare for trial, and juggle a myriad of other responsibilities. The government offers no legitimate excuse for non-compliance. It clearly knows what statements it will try to introduce, it just does not want to tell anyone to avoid challenges to the statements. This is willful, not negligent or inadvertent conduct which should not be sanctioned by the Court.",
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},
"additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 10 of 52."
}

64
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{
"document_metadata": {
"page_number": "11",
"document_number": "398",
"date": "10/29/21",
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 11 of 52\n\nD. There are Substantial Issues with the Government's Anticipated Position\n\nFor a statement to fall within the definition of Fed. R. Evid. 801(d)(2)(E), \"a court must find (1) that there was a conspiracy, (2) that its members included the declarant and the party against whom the statement is offered, and (3) that the statement was made both (a) during the course of and (b) in furtherance of the conspiracy.\" United States v. Tracy, 12 F.3d 1186, 1196 (2d Cir. 1993). A cursory review of the discovery produced related to one purported co-conspirator demonstrates the folly of proceeding as the government persists.\n\n[REDACTED TEXT BLOCK]\n\nThe government failed to follow the Court's Order and fails to explain why it did not disclose the statements as ordered. Accordingly, the Court should prohibit introduction of any alleged co-conspirator statements at trial.\n\n5\n\nDOJ-OGR-00005966",
"text_blocks": [
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"content": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 11 of 52",
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{
"type": "printed",
"content": "D. There are Substantial Issues with the Government's Anticipated Position",
"position": "header"
},
{
"type": "printed",
"content": "For a statement to fall within the definition of Fed. R. Evid. 801(d)(2)(E), \"a court must find (1) that there was a conspiracy, (2) that its members included the declarant and the party against whom the statement is offered, and (3) that the statement was made both (a) during the course of and (b) in furtherance of the conspiracy.\" United States v. Tracy, 12 F.3d 1186, 1196 (2d Cir. 1993). A cursory review of the discovery produced related to one purported co-conspirator demonstrates the folly of proceeding as the government persists.",
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"content": "The government failed to follow the Court's Order and fails to explain why it did not disclose the statements as ordered. Accordingly, the Court should prohibit introduction of any alleged co-conspirator statements at trial.",
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"additional_notes": "The document contains a redacted text block. The document appears to be a court filing related to a criminal case."
}

66
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{
"document_metadata": {
"page_number": "12 of 52",
"document_number": "398",
"date": "10/29/21",
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 12 of 52\n\nII. GOVERNMENT CONCEDEDLY FAILED TO GIVE NOTICE OF THE BASIS OR REASONING TO ADMIT ANY 404(B) EVIDENCE\n\nThe government concedes that (i) it was aware of the December 2020 Amendments to Rule 404(b) (Resp. at 34), (ii) those Amendments required it to give notice of the \"permitted purpose for which the prosecutor intends to offer the [404(b)] evidence and the reasoning that supports the purpose\" (id.) (\"Notice\"), and (iii) the October 11th \"Maxwell Rule 404 Letter\" (\"Letter\") did not identify the \"permitted purpose\" under Rule 404(b) for which the government seeks (alternative) admission of the two categories of evidence, nor the \"reasoning that supports that evidence.\"1 The government wholly fails to explain why it could not comply with these \"relatively modest\" new Notice requirements on the timeline ordered by this Court. Nowhere in response does the government seek leave for an extension to provide the appropriate Notice out of time nor justify its \"good cause\" for failure to timely comply with both the Court's Order and the Rule. Instead, they assert that \"any alleged gap in the Government's notice is remediated by this brief.\" Resp. at 39-40. To quote the government's response to Ms. Maxwell's motion in limine, \"to the extent the [government] takes issue with the rule\" requiring specific pre-trial Notice under Rule 404(b), \"that complaint is properly directed to the drafters of the Federal Rules of Evidence.\" Resp. at 61 n.15.\n\nHaving failed to comply with the Notice requirements of the Rule by the (extended) Court ordered deadline of October 11, the government belatedly argues that the tendered evidence is either direct evidence or admissible under Rule 404(b). They are wrong on both fronts.\n\n1 Under the misleading and disingenuous sub-heading (2) (\"The Government has Met and Exceeded its Notice Obligations\"), the government points only to its (i) October 11 disclosure of certain of the evidence (which gives neither a a proper \"purpose\" or \"reasoning\"), and (ii) its Response (the required \"notice is remediated by this brief\").\n\n6\n\nDOJ-OGR-00005967",
"text_blocks": [
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"content": "II. GOVERNMENT CONCEDEDLY FAILED TO GIVE NOTICE OF THE BASIS OR REASONING TO ADMIT ANY 404(B) EVIDENCE",
"position": "header"
},
{
"type": "printed",
"content": "The government concedes that (i) it was aware of the December 2020 Amendments to Rule 404(b) (Resp. at 34), (ii) those Amendments required it to give notice of the \"permitted purpose for which the prosecutor intends to offer the [404(b)] evidence and the reasoning that supports the purpose\" (id.) (\"Notice\"), and (iii) the October 11th \"Maxwell Rule 404 Letter\" (\"Letter\") did not identify the \"permitted purpose\" under Rule 404(b) for which the government seeks (alternative) admission of the two categories of evidence, nor the \"reasoning that supports that evidence.\"1 The government wholly fails to explain why it could not comply with these \"relatively modest\" new Notice requirements on the timeline ordered by this Court. Nowhere in response does the government seek leave for an extension to provide the appropriate Notice out of time nor justify its \"good cause\" for failure to timely comply with both the Court's Order and the Rule. Instead, they assert that \"any alleged gap in the Government's notice is remediated by this brief.\" Resp. at 39-40. To quote the government's response to Ms. Maxwell's motion in limine, \"to the extent the [government] takes issue with the rule\" requiring specific pre-trial Notice under Rule 404(b), \"that complaint is properly directed to the drafters of the Federal Rules of Evidence.\" Resp. at 61 n.15.",
"position": "body"
},
{
"type": "printed",
"content": "Having failed to comply with the Notice requirements of the Rule by the (extended) Court ordered deadline of October 11, the government belatedly argues that the tendered evidence is either direct evidence or admissible under Rule 404(b). They are wrong on both fronts.",
"position": "body"
},
{
"type": "printed",
"content": "1 Under the misleading and disingenuous sub-heading (2) (\"The Government has Met and Exceeded its Notice Obligations\"), the government points only to its (i) October 11 disclosure of certain of the evidence (which gives neither a a proper \"purpose\" or \"reasoning\"), and (ii) its Response (the required \"notice is remediated by this brief\").",
"position": "footnote"
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{
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"additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 12 of 52."
}

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@@ -0,0 +1,66 @@
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 13 of 52\n\n\"In assessing whether a district court properly admitted other act evidence, we consider whether (1) it was offered for a proper purpose; (2) it was relevant to a material issue in dispute; (3) its probative value is substantially outweighed by its prejudicial effect; and (4) the trial court gave an appropriate limiting instruction to the jury if so requested by the defendant.\" United States v. Arroyo, 600 F. App'x 11, 13 (2d Cir. 2015) (summary order) (quoting United States v. LaFlam, 369 F.3d 153, 156 (2d Cir. 2004)). are offered for improper purposes, i.e., propensity, are not relevant to any material issue in dispute and their probative value is substantially outweighed by their prejudicial effect.\n\nA. Bear No Relationship to the Charged Conspiracy, Reflect Pure Propensity Evidence, and Otherwise are Unduly Prejudicial\n\nThe government's argument for admissibility of is breathtaking in its claims and unsupported by admissible evidence. Without expert testimony or even bothering to interview , the government contends represent \"direct evidence\" of a conspiracy (to recruit, groom, and sexually abuse minor females or to entice, transport or traffic them for Jeffrey Epstein's sexual pleasure) that Resp. at 36.\n\n2 The proffered evidence is found at GX 401-404, 409-410 and 413 .",
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"content": "\"In assessing whether a district court properly admitted other act evidence, we consider whether (1) it was offered for a proper purpose; (2) it was relevant to a material issue in dispute; (3) its probative value is substantially outweighed by its prejudicial effect; and (4) the trial court gave an appropriate limiting instruction to the jury if so requested by the defendant.\" United States v. Arroyo, 600 F. App'x 11, 13 (2d Cir. 2015) (summary order) (quoting United States v. LaFlam, 369 F.3d 153, 156 (2d Cir. 2004)). are offered for improper purposes, i.e., propensity, are not relevant to any material issue in dispute and their probative value is substantially outweighed by their prejudicial effect.",
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"content": "The government's argument for admissibility of is breathtaking in its claims and unsupported by admissible evidence. Without expert testimony or even bothering to interview , the government contends represent \"direct evidence\" of a conspiracy (to recruit, groom, and sexually abuse minor females or to entice, transport or traffic them for Jeffrey Epstein's sexual pleasure) that Resp. at 36.",
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57
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 14 of 52 The government contends that reveal \"defendant's intent and motive,\" but their argument is defies logic. This is exactly the type of evidence forbidden by Rule 404(b). See United States v. Angelilli, 660 F.2d 23, 40-41 (2d Cir. 1981) (\"While we conclude that the custom and practice evidence was admissible for the purposes we have discussed, we agree with the defendants that Rule 404(b) barred its use to prove that the individual defendants acted in conformity with the custom and practice. ...\"). Even if the Court overlooks the government's failure to provide notice, absence of relevance to the charged conspiracy, and the government's failure to set forth a non-propensity ground for admissibility, should also be excluded under Rules 401 and 403, as they do not tend to make any fact of consequence more or less probable, and their probative value is substantially outweighed by the danger of unfair prejudice and confusing the issues. 8 DOJ-OGR-00005969",
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"content": "This is exactly the type of evidence forbidden by Rule 404(b). See United States v. Angelilli, 660 F.2d 23, 40-41 (2d Cir. 1981) (\"While we conclude that the custom and practice evidence was admissible for the purposes we have discussed, we agree with the defendants that Rule 404(b) barred its use to prove that the individual defendants acted in conformity with the custom and practice. ...\").",
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44
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51
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 16 of 52 Maxwell strongly disputes that suggestion. Notably, as the Court can tell, the government did not offer any evidence (or any offer of proof in their Response) that this document was in fact 10 DOJ-OGR-00005971",
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"content": "Maxwell strongly disputes that suggestion. Notably, as the Court can tell, the government did not offer any evidence (or any offer of proof in their Response) that this document was in fact",
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}

70
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{
"document_metadata": {
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 17 of 52\ndrafted by Ms. Maxwell. Compare GX 417-B, 418-B, 420-B, 420-B (all purporting to represent metadata of other emails with the author identified). Such arguments are based on outdated stereotypes and reveal a reliance on character evidence that the Rules of Evidence specifically disallow. This Court should reject the belated, insufficient, improper argument that are direct evidence of the charged conspiracy, should find they are propensity evidence barred by Rule 404(b) and should also exclude them under Rule 403 as more prejudicial than probative. B. 11 DOJ-OGR-00005972",
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"content": "drafted by Ms. Maxwell. Compare GX 417-B, 418-B, 420-B, 420-B (all purporting to represent metadata of other emails with the author identified).",
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"content": "Such arguments are based on outdated stereotypes and reveal a reliance on character evidence that the Rules of Evidence specifically disallow.",
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"content": "This Court should reject the belated, insufficient, improper argument that are direct evidence of the charged conspiracy, should find they are propensity evidence barred by Rule 404(b) and should also exclude them under Rule 403 as more prejudicial than probative.",
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}

58
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{
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 18 of 52\n\n1.\n\nMot. at 7. Defense counsel had insufficient time to review, investigate or rebut the admissibility of the materials as direct evidence less than one week later on October 18th. For that reason, the Motion did not move to exclude the evidence as direct evidence but rather sought additional time in which to do so. Given the drafting of hundreds of pages of pleadings in the last week, counsel is still unprepared to make the required showing on the direct evidence point and seeks additional time in which to do so.\n\n5 Bear in mind that the government also moved to exclude evidence that these same \"abused\" individuals reported to the police that they had no interactions or dealings with Ms. Maxwell. Gov't Motion in Limine at 42 (\"The defendant is not charged with committing crimes against [the] victims [who reported that they had no interactions or dealings with Ms. Maxwell].\") The fact that the government clearly intends to rely on how open the alleged abuse was, the relevance of evidence that even the people who claim they were abused by Epstein during the same time frame but without any knowledge or participation by Ms. Maxwell becomes highly relevant to rebut such testimony.\n\n12",
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"content": "1.\n\nMot. at 7. Defense counsel had insufficient time to review, investigate or rebut the admissibility of the materials as direct evidence less than one week later on October 18th. For that reason, the Motion did not move to exclude the evidence as direct evidence but rather sought additional time in which to do so. Given the drafting of hundreds of pages of pleadings in the last week, counsel is still unprepared to make the required showing on the direct evidence point and seeks additional time in which to do so.",
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"type": "printed",
"content": "5 Bear in mind that the government also moved to exclude evidence that these same \"abused\" individuals reported to the police that they had no interactions or dealings with Ms. Maxwell. Gov't Motion in Limine at 42 (\"The defendant is not charged with committing crimes against [the] victims [who reported that they had no interactions or dealings with Ms. Maxwell].\") The fact that the government clearly intends to rely on how open the alleged abuse was, the relevance of evidence that even the people who claim they were abused by Epstein during the same time frame but without any knowledge or participation by Ms. Maxwell becomes highly relevant to rebut such testimony.",
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}

74
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{
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"page_number": "19",
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 19 of 52\n\n2. The government has apparently abandoned efforts to introduce her testimony as Rule 404(b) evidence.\n\nIn their response, the government still fails to comply with the new Rule 404(b) notice requirements. First, they do not actually identify the evidence with any specificity, especially with respect to the \"exhibits\" that they hope to introduce through her. Second, while they use the words \"plan and preparation\" or \"knowledge,\" they fail to explain how those uses of the testimony are independent of the character / propensity inference banned by Rule 404(b). How are the process and frequency of massages or the sexual nature of massages after the period of the conspiracy proof of a plan or preparation, apart from the propensity inference? A plan or preparation usually comes before an event. Planning or preparing for something after it has occurred can only be based on an assumption that because you are the kind of person who solicits underage massages later, you must have been the kind of person to do so earlier.\n\nSimilarly, knowledge after the end of the conspiracy is not the same as knowledge at the time of or before the purported charged acts occurred, except by way of propensity. Finally, unspecified exhibits, many of which appear to have been written after the conspiracy (e.g., GX 505 - dated Feb. 14, 2005) cannot likewise be proof of the charged crimes which were allegedly completed before showed up.\n\nBecause the government makes no effort to argue the non-propensity purpose for these uses of via Rule 404(b), and failed to give notice of the purposes or reason in advance in any event, this Court should exclude the evidence on this ground.\n\n3. constitutes an impermissible constructive amendment and variance to the Indictment.\n\nFinally, what is clear from the government's proffer in their Response, the anticipated testimony of , will serve as an improper constructive \n\n13\nDOJ-OGR-00005974",
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"content": "2. The government has apparently abandoned efforts to introduce her testimony as Rule 404(b) evidence.",
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"content": "In their response, the government still fails to comply with the new Rule 404(b) notice requirements. First, they do not actually identify the evidence with any specificity, especially with respect to the \"exhibits\" that they hope to introduce through her. Second, while they use the words \"plan and preparation\" or \"knowledge,\" they fail to explain how those uses of the testimony are independent of the character / propensity inference banned by Rule 404(b). How are the process and frequency of massages or the sexual nature of massages after the period of the conspiracy proof of a plan or preparation, apart from the propensity inference? A plan or preparation usually comes before an event. Planning or preparing for something after it has occurred can only be based on an assumption that because you are the kind of person who solicits underage massages later, you must have been the kind of person to do so earlier.",
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"content": "Similarly, knowledge after the end of the conspiracy is not the same as knowledge at the time of or before the purported charged acts occurred, except by way of propensity. Finally, unspecified exhibits, many of which appear to have been written after the conspiracy (e.g., GX 505 - dated Feb. 14, 2005) cannot likewise be proof of the charged crimes which were allegedly completed before showed up.",
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"content": "Because the government makes no effort to argue the non-propensity purpose for these uses of via Rule 404(b), and failed to give notice of the purposes or reason in advance in any event, this Court should exclude the evidence on this ground.",
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73
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{
"document_metadata": {
"page_number": "20 of 52",
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 20 of 52\namendment to, and an impermissible variance of, the Indictment. As this Court previously has ruled:\n\"To prevail on a constructive amendment claim, a defendant must demonstrate that 'the terms of [an] indictment are in effect altered by the presentation of evidence and jury instructions which so modify essential elements of the offense charged that there is a substantial likelihood that the defendant may have been convicted of an offense other than that charged in the indictment.' United States v. D'Amelio, 683 F.3d 412, 416 (2d Cir. 2012) (quoting United States v. Mollica, 849 F.2d 723, 729 (2d Cir. 1988)). Because the doctrine of constructive amendment protects a defendant's Grand Jury Clause rights, a constructive amendment constitutes a \"per se violation\" of the defendant's constitutional rights-i.e. there is no requirement that a defendant make a specific showing of prejudice. Id. at 417. In contrast to a constructive amendment, \"[a] variance occurs when the charging terms of the indictment are left unaltered, but the evidence at trial proves facts materially different from those alleged in the indictment.\" Id. (quoting United States v. Salmonese, 352 F.3d 608, 621 (2d Cir. 2003)).\nUnited States v. Gross, 15-cr-769 (AJN), 2017 WL 4685111, at *20 (S.D.N.Y. Oct. 18, 2017).\nAs this Court then recognized, the Second Circuit has consistently relied on the same start and end dates of a conspiracy to find that differing trial proof did not affect a constructive amendment or variance. See id. (\"The indictment and the evidence at trial contained the same starting and ending dates of the conspiracy...\") (quoting United States v. Rigas, 490 F.3d 208, 229 (2d. Cir. 2007)); see also United States v. Dupre, 462 F.3d 131, 141 (2d Cir. 2006) (\"The starting and ending dates of the conspiracy noted in the indictment correspond to the conspiracy proven at trial...\"). Conversely, the substantial quantity of testimony - for the post-conspiracy time period of [redacted], who never met any of the four accusers as far as can be gleaned, and the documents she intends to authenticate, run a substantial risk that the government's proof at trial will not be the same core evidence charged in the Indictment because it will be based on evidence that post-dates the events charged in the Indictment.\n14\nDOJ-OGR-00005975",
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"content": "amendment to, and an impermissible variance of, the Indictment. As this Court previously has ruled:",
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"content": "\"To prevail on a constructive amendment claim, a defendant must demonstrate that 'the terms of [an] indictment are in effect altered by the presentation of evidence and jury instructions which so modify essential elements of the offense charged that there is a substantial likelihood that the defendant may have been convicted of an offense other than that charged in the indictment.' United States v. D'Amelio, 683 F.3d 412, 416 (2d Cir. 2012) (quoting United States v. Mollica, 849 F.2d 723, 729 (2d Cir. 1988)). Because the doctrine of constructive amendment protects a defendant's Grand Jury Clause rights, a constructive amendment constitutes a \"per se violation\" of the defendant's constitutional rights-i.e. there is no requirement that a defendant make a specific showing of prejudice. Id. at 417. In contrast to a constructive amendment, \"[a] variance occurs when the charging terms of the indictment are left unaltered, but the evidence at trial proves facts materially different from those alleged in the indictment.\" Id. (quoting United States v. Salmonese, 352 F.3d 608, 621 (2d Cir. 2003)).",
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"content": "As this Court then recognized, the Second Circuit has consistently relied on the same start and end dates of a conspiracy to find that differing trial proof did not affect a constructive amendment or variance. See id. (\"The indictment and the evidence at trial contained the same starting and ending dates of the conspiracy...\") (quoting United States v. Rigas, 490 F.3d 208, 229 (2d. Cir. 2007)); see also United States v. Dupre, 462 F.3d 131, 141 (2d Cir. 2006) (\"The starting and ending dates of the conspiracy noted in the indictment correspond to the conspiracy proven at trial...\"). Conversely, the substantial quantity of testimony - for the post-conspiracy time period of [redacted], who never met any of the four accusers as far as can be gleaned, and the documents she intends to authenticate, run a substantial risk that the government's proof at trial will not be the same core evidence charged in the Indictment because it will be based on evidence that post-dates the events charged in the Indictment.",
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74
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 21 of 52\n\nC. Ms. Maxwell reiterates her request to defer briefing and ruling on the admissibility of and exhibits for two weeks.\nFor the reasons already detailed, the complexity of the issues and the fact that recently disclosed testimony appears to be of utmost centrality to the government's case, Ms. Maxwell repeats and reiterates her request that she be afforded additional time to submit a comprehensive motion in limine concerning the introduction of this testimony and exhibits as supposed direct evidence of the charged conspiracy. In that there remains a full month before opening statements, Ms. Maxwell's fundamental rights to present a defense, to have the effective assistance of counsel, and to a right to confront witnesses and subpoena witnesses to testify in her defense all will be preserved by a small delay on this issue.\n\nIII. THIS COURT SHOULD EXCLUDE LISA ROCCHIO'S TESTIMONY UNDER FEDERAL RULE OF EVIDENCE 702 AND DAUBERT V. MERRELL DOW PHARMACEUTICALS, INC., 509 U.S. 579 (1993) AND GRANT A DAUBERT HEARING\nA. This Court should reject the government's arguments to the extent that they are based on newly disclosed material, which this Court ordered the government to produce six months ago.\nRecognizing that Rocchio's proposed testimony is on shaky ground (to say the least), the government belatedly tries to shore up its case and hoist up its expert witness. Two days ago, and six months after the court-imposed deadline for expert disclosures, the government first disclosed to defense counsel about 300 pages of material on which Rocchio apparently relied in reaching her conclusions. This Court should reject the government's untimely effort to save Rocchio's testimony from exclusion. See United States v. Lewis, 818 F. App'x 74, 79 (2d Cir. 2020) (unpublished) (affirming exclusion of defendant's proffered expert evidence \"that did not adhere to the discovery schedule\").\n15\nDOJ-OGR-00005976",
"text_blocks": [
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"content": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 21 of 52",
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"content": "C. Ms. Maxwell reiterates her request to defer briefing and ruling on the admissibility of and exhibits for two weeks.",
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{
"type": "printed",
"content": "For the reasons already detailed, the complexity of the issues and the fact that recently disclosed testimony appears to be of utmost centrality to the government's case, Ms. Maxwell repeats and reiterates her request that she be afforded additional time to submit a comprehensive motion in limine concerning the introduction of this testimony and exhibits as supposed direct evidence of the charged conspiracy. In that there remains a full month before opening statements, Ms. Maxwell's fundamental rights to present a defense, to have the effective assistance of counsel, and to a right to confront witnesses and subpoena witnesses to testify in her defense all will be preserved by a small delay on this issue.",
"position": "middle"
},
{
"type": "printed",
"content": "III. THIS COURT SHOULD EXCLUDE LISA ROCCHIO'S TESTIMONY UNDER FEDERAL RULE OF EVIDENCE 702 AND DAUBERT V. MERRELL DOW PHARMACEUTICALS, INC., 509 U.S. 579 (1993) AND GRANT A DAUBERT HEARING",
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"content": "A. This Court should reject the government's arguments to the extent that they are based on newly disclosed material, which this Court ordered the government to produce six months ago.",
"position": "middle"
},
{
"type": "printed",
"content": "Recognizing that Rocchio's proposed testimony is on shaky ground (to say the least), the government belatedly tries to shore up its case and hoist up its expert witness. Two days ago, and six months after the court-imposed deadline for expert disclosures, the government first disclosed to defense counsel about 300 pages of material on which Rocchio apparently relied in reaching her conclusions. This Court should reject the government's untimely effort to save Rocchio's testimony from exclusion. See United States v. Lewis, 818 F. App'x 74, 79 (2d Cir. 2020) (unpublished) (affirming exclusion of defendant's proffered expert evidence \"that did not adhere to the discovery schedule\").",
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}

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{
"document_metadata": {
"page_number": "22",
"document_number": "398",
"date": "10/29/21",
"document_type": "court document",
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 22 of 52\n\nIn any case, the newly discovered material doesn't help the government's cause. Exhibit A (literally) to the government's response is a journal article describing \"grooming\" as a \"construct.\" Resp, Ex. A, Natalie Bennett & William O'Donohue, The Construct of Grooming in Child Sexual Abuse, 23 J. Child Sexual Abuse 957, 974 (2014). (In fact, Ms. Maxwell cited this article in her motion.) Far from supporting Rocchio's conclusions, the article proves their unreliability:\n\nThere have been claims that some child molesters engage in a \"seduction stage\" prior to committing abuse. These behaviors, commonly known as \"grooming,\" are understood as methods child molesters use to gain access to and prepare future victims to be compliant with abuse. However, there is a lack of consensus regarding exactly what this process entails and how it is clearly distinguished from normal adult-child interactions. . . . Furthermore, there are no methods of known psychometrics to validly assess grooming.\n\nGov't Resp., Ex. A, p 2 (emphasis added). The article concludes:\n\nCurrently there is no consensus regarding how to define grooming. In addition, there is no valid method to assess whether grooming has occurred or is occurring. The field possesses an insufficient amount of knowledge about key issues such as the interrater reliability of these judgments or the error rates of these judgments including the frequency of false negatives or false positives. Thus currently it appears that grooming is not a construct that ought to be used in forensic settings as it does not meet some of the criteria in the Daubert standard. . . . Right now it does not appear to be the case that there are \"reliable principles and methods\" to define and detect grooming.\n\nId. at 19 (emphasis added).\n\nBecause the government cannot justify admission of Rocchio's testimony based on its prejudicially late disclosures, and because those disclosures don't support Rocchio's views, and underscore that \"grooming\" is not a scientific principle based on psychometric testing, this Court should preclude Rocchio from testifying. And as explained below, the government's other defenses of Rocchio fall far short of what is required by Rules 401, 402, 403, 404, 702, and 704.\n\n16\n\nDOJ-OGR-00005977",
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"content": "In any case, the newly discovered material doesn't help the government's cause. Exhibit A (literally) to the government's response is a journal article describing \"grooming\" as a \"construct.\" Resp, Ex. A, Natalie Bennett & William O'Donohue, The Construct of Grooming in Child Sexual Abuse, 23 J. Child Sexual Abuse 957, 974 (2014). (In fact, Ms. Maxwell cited this article in her motion.) Far from supporting Rocchio's conclusions, the article proves their unreliability:",
"position": "top"
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{
"type": "printed",
"content": "There have been claims that some child molesters engage in a \"seduction stage\" prior to committing abuse. These behaviors, commonly known as \"grooming,\" are understood as methods child molesters use to gain access to and prepare future victims to be compliant with abuse. However, there is a lack of consensus regarding exactly what this process entails and how it is clearly distinguished from normal adult-child interactions. . . . Furthermore, there are no methods of known psychometrics to validly assess grooming.",
"position": "middle"
},
{
"type": "printed",
"content": "Gov't Resp., Ex. A, p 2 (emphasis added). The article concludes:",
"position": "middle"
},
{
"type": "printed",
"content": "Currently there is no consensus regarding how to define grooming. In addition, there is no valid method to assess whether grooming has occurred or is occurring. The field possesses an insufficient amount of knowledge about key issues such as the interrater reliability of these judgments or the error rates of these judgments including the frequency of false negatives or false positives. Thus currently it appears that grooming is not a construct that ought to be used in forensic settings as it does not meet some of the criteria in the Daubert standard. . . . Right now it does not appear to be the case that there are \"reliable principles and methods\" to define and detect grooming.",
"position": "middle"
},
{
"type": "printed",
"content": "Id. at 19 (emphasis added).",
"position": "middle"
},
{
"type": "printed",
"content": "Because the government cannot justify admission of Rocchio's testimony based on its prejudicially late disclosures, and because those disclosures don't support Rocchio's views, and underscore that \"grooming\" is not a scientific principle based on psychometric testing, this Court should preclude Rocchio from testifying. And as explained below, the government's other defenses of Rocchio fall far short of what is required by Rules 401, 402, 403, 404, 702, and 704.",
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"additional_notes": "The document appears to be a court filing related to a criminal case. The text discusses the admissibility of expert testimony regarding 'grooming' in the context of child sexual abuse. The document includes citations to a journal article and references to specific rules of evidence."
}

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{
"document_metadata": {
"page_number": "23",
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 23 of 52\n\nB. Rocchio's proposed testimony is inadmissible.\nAccording to the government, Ms. Maxwell \"does not contest that Dr. Rocchio is a qualified expert.\" Resp. at 9. To the degree that Dr. Rocchio has the credentials of a potential expert, the government is right.\nBut saying that Rocchio is a \"qualified expert\" is not enough. The government must identify what Rocchio is an expert in. Fed. R. Evid. 702; Fed. R. Crim. 16. As Ms. Maxwell pointed out in her motion, the government hasn't done that. Mot. at 2.\nWhat's more, even if Rocchio is a \"qualified expert\" in something, she is not a \"qualified expert\" in everything. (For example, the government agrees that she is not an expert in the human brain or memory generally. Resp. at 30 n.7.) And as even the government admits, Rocchio has no experience or expertise in diagnosing, evaluating, or treating alleged perpetrators of sexual abuse. Resp. at 19, 23, 26. She cannot therefore speak to the psychology of alleged perpetrators and their so-called \"grooming techniques.\"\nThe government attempts a two-step to get around this problem. \"By virtue of experience treating victims,\" says the government, \"Dr. Rocchio is necessarily informed about perpetrators' actions.\" Resp. at 19.\nBut how does Rocchio know her patients were victims of sexual abuse? Because her patients told her so, and Rocchio assumes they are telling the truth. Again, Rocchio's opinions are based on her treatment of a self-selected, unrepresentative group of individuals she assumes are telling the truth and are therapeutic consumers in a financial relationship with her.\nThe government has no response to this, other than to say that Rocchio and other \"[c]linical psychologists are not so credulous.\" Resp. at 16. If this were right, though, one would expect the government to explain how clinical psychologists ensure their patients are telling the truth — in other words, how clinical psychologists like Rocchio test and verify their opinions.\n17\nDOJ-OGR-00005978",
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"content": "B. Rocchio's proposed testimony is inadmissible.",
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"content": "According to the government, Ms. Maxwell \"does not contest that Dr. Rocchio is a qualified expert.\" Resp. at 9. To the degree that Dr. Rocchio has the credentials of a potential expert, the government is right.",
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"content": "But saying that Rocchio is a \"qualified expert\" is not enough. The government must identify what Rocchio is an expert in. Fed. R. Evid. 702; Fed. R. Crim. 16. As Ms. Maxwell pointed out in her motion, the government hasn't done that. Mot. at 2.",
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"content": "What's more, even if Rocchio is a \"qualified expert\" in something, she is not a \"qualified expert\" in everything. (For example, the government agrees that she is not an expert in the human brain or memory generally. Resp. at 30 n.7.) And as even the government admits, Rocchio has no experience or expertise in diagnosing, evaluating, or treating alleged perpetrators of sexual abuse. Resp. at 19, 23, 26. She cannot therefore speak to the psychology of alleged perpetrators and their so-called \"grooming techniques.\"",
"position": "middle"
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"content": "The government attempts a two-step to get around this problem. \"By virtue of experience treating victims,\" says the government, \"Dr. Rocchio is necessarily informed about perpetrators' actions.\" Resp. at 19.",
"position": "middle"
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{
"type": "printed",
"content": "But how does Rocchio know her patients were victims of sexual abuse? Because her patients told her so, and Rocchio assumes they are telling the truth. Again, Rocchio's opinions are based on her treatment of a self-selected, unrepresentative group of individuals she assumes are telling the truth and are therapeutic consumers in a financial relationship with her.",
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"content": "The government has no response to this, other than to say that Rocchio and other \"[c]linical psychologists are not so credulous.\" Resp. at 16. If this were right, though, one would expect the government to explain how clinical psychologists ensure their patients are telling the truth — in other words, how clinical psychologists like Rocchio test and verify their opinions.",
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}

71
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{
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 24 of 52\n\nBut that's not what the government does. Instead, right after claiming that \"[c]linical psychologists are not so credulous,\" the government essentially says to Ms. Maxwell, \"How dare you?\" In the government's words, \"The Court should reject the defendant's speculative claim that Dr. Rocchio has been misled by hundreds of patients who sought professional treatment for traumatic events that did not occur.\" Resp. at 16.\n\nIn this way, and in one breath, the government attests that Rocchio is \"not so credulous.\" But in the next breath, the government asks this Court to assume that Rocchio \"has [not] been misled by hundreds of patients who sought professional treatment for traumatic events that did not occur.\" In other words, the government asks this Court to assume Rocchio's patients are telling the truth, just as Rocchio does. Apparently Rocchio is \"so credulous.\" But there is no reason this Court should be.\n\nThe government next notes that the term \"grooming-by-proxy\" \"appears nowhere in the Government's expert notice.\" Resp. at 26. That's hardly surprising, though, because there is no reliable way to assess or analyze if one individual \"grooming\" a minor to facilitate abuse by someone else, even though that is exactly what the government says Ms. Maxwell did.\n\nAs detailed today is Ms. Maxwell's Rule 412 motion, the Indictment alleges \"grooming\" or \"normalization\" of sexual behavior by Ms. Maxwell over a dozen times. The government does not, however, contend that Ms. Maxwell \"groomed\" anyone for her own benefit; instead, the government contends that she \"groomed\" them for Epstein's benefit. But as the government does not dispute, there is nothing—a journal article, and not a study, nothing—to validate Rocchio's opinions on grooming-by-proxy (even if she doesn't use that phrase).6\n\n6 The articles and cases the government cites involve alleged grooming behavior by the preparator of the abuse, not alleged grooming behavior by a third party.\n\n18\nDOJ-OGR-00005979",
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"content": "But that's not what the government does. Instead, right after claiming that \"[c]linical psychologists are not so credulous,\" the government essentially says to Ms. Maxwell, \"How dare you?\" In the government's words, \"The Court should reject the defendant's speculative claim that Dr. Rocchio has been misled by hundreds of patients who sought professional treatment for traumatic events that did not occur.\" Resp. at 16.",
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"content": "In this way, and in one breath, the government attests that Rocchio is \"not so credulous.\" But in the next breath, the government asks this Court to assume that Rocchio \"has [not] been misled by hundreds of patients who sought professional treatment for traumatic events that did not occur.\" In other words, the government asks this Court to assume Rocchio's patients are telling the truth, just as Rocchio does. Apparently Rocchio is \"so credulous.\" But there is no reason this Court should be.",
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"content": "The government next notes that the term \"grooming-by-proxy\" \"appears nowhere in the Government's expert notice.\" Resp. at 26. That's hardly surprising, though, because there is no reliable way to assess or analyze if one individual \"grooming\" a minor to facilitate abuse by someone else, even though that is exactly what the government says Ms. Maxwell did.",
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"content": "As detailed today is Ms. Maxwell's Rule 412 motion, the Indictment alleges \"grooming\" or \"normalization\" of sexual behavior by Ms. Maxwell over a dozen times. The government does not, however, contend that Ms. Maxwell \"groomed\" anyone for her own benefit; instead, the government contends that she \"groomed\" them for Epstein's benefit. But as the government does not dispute, there is nothing—a journal article, and not a study, nothing—to validate Rocchio's opinions on grooming-by-proxy (even if she doesn't use that phrase).6",
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}

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{
"document_metadata": {
"page_number": "25 of 52",
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 25 of 52\n\nRecognizing that Rocchio's opinions are thus unreliable, the government says: \"If the victim experienced attachment and grooming, it makes no analytical difference whether the perpetrator intends to engage in sexual contact with the victim or, instead, is preparing the victim for abuse by a third party.\" Resp. at 26.\n\nHardly. It makes all the difference in the world because Ms. Maxwell is on trial, not Mr. Epstein. The logic (such as it is) of grooming evidence is that the perpetrator normalizes sexual behavior to facilitate his latter abuse of the victim. But because Ms. Maxwell did not abuse anyone, there is no basis to conclude that anything she did was \"grooming.\" The government thus intends to have Rocchio characterize innocent conduct by Ms. Maxwell as something more nefarious, thereby further blurring the line that experts are already unable to draw reliably. Resp. Ex. A, p 2 (\"There is a lack of consensus regarding exactly what [the grooming] process entails and how it is clearly distinguished from normal adult-child interactions.\")\n\nThe government's additional arguments fail.\n\n* A psychologist who treats alleged victims of abuse but does not treat alleged perpetrators is nothing like a urologist who treats urology patients. Resp. at 11 (citing Bosco v. United States, No. 14 CIV. 3525 (JFK), 2016 WL 5376205 (S.D.N.Y. Sept. 26, 2016)). Rocchio assumes her patients are telling the truth, and she never hears or credits the other side of the story. The urologist, by contrast, has scientific means to verify what her patients tell her, and there isn't another person whose side of the story she needs to hear.\n\n* The government repeatedly says that \"courts have frequently admitted testimony about the psychological relationship between victims of sexual abuse and their perpetrators.\" Resp. at 13. See also id. at 7-8. But those cases do not address the 19\n\nDOJ-OGR-00005980",
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"content": "Recognizing that Rocchio's opinions are thus unreliable, the government says: \"If the victim experienced attachment and grooming, it makes no analytical difference whether the perpetrator intends to engage in sexual contact with the victim or, instead, is preparing the victim for abuse by a third party.\" Resp. at 26.\n\nHardly. It makes all the difference in the world because Ms. Maxwell is on trial, not Mr. Epstein. The logic (such as it is) of grooming evidence is that the perpetrator normalizes sexual behavior to facilitate his latter abuse of the victim. But because Ms. Maxwell did not abuse anyone, there is no basis to conclude that anything she did was \"grooming.\" The government thus intends to have Rocchio characterize innocent conduct by Ms. Maxwell as something more nefarious, thereby further blurring the line that experts are already unable to draw reliably. Resp. Ex. A, p 2 (\"There is a lack of consensus regarding exactly what [the grooming] process entails and how it is clearly distinguished from normal adult-child interactions.\")",
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"content": "* A psychologist who treats alleged victims of abuse but does not treat alleged perpetrators is nothing like a urologist who treats urology patients. Resp. at 11 (citing Bosco v. United States, No. 14 CIV. 3525 (JFK), 2016 WL 5376205 (S.D.N.Y. Sept. 26, 2016)). Rocchio assumes her patients are telling the truth, and she never hears or credits the other side of the story. The urologist, by contrast, has scientific means to verify what her patients tell her, and there isn't another person whose side of the story she needs to hear.",
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"content": "* The government repeatedly says that \"courts have frequently admitted testimony about the psychological relationship between victims of sexual abuse and their perpetrators.\" Resp. at 13. See also id. at 7-8. But those cases do not address the",
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{
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"page_number": "26 of 52",
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 26 of 52\nsituation here, in which the alleged \"groomer\" was not the person who perpetrated the alleged abuse.\n- Even where the \"groomer\" and \"perpetrator\" are the same person, courts have recognized the unreliability of grooming testimony. United States v. Gonyer, No. 1:12-CR-00021-JAW, 2012 WL 3043020, at *2-3 (D. Me. July 24, 2012); United States v. Raymond, 700 F. Supp. 2d 142, 146-47 (D. Me. 2010); United States v. Schneider, No. CRIM.A. 10-29, 2010 WL 3734055, at *4 (E.D. Pa. Sept. 22, 2010); see also United States v. Raniere, No. 18-CR-2041-NGG-VMS, 2019 WL 2212639, at *7 (E.D.N.Y. May 22, 2019); United States v. Burns, No. 07 CR 556, 2009 WL 3617448, at *5 (N.D. Ill. Oct. 27, 2009) (criticizing the \"grooming theory\" in the context of a sentencing guidelines calculation).\n- The government tries to distinguish United States v. Raymond by saying that the expert's own book in that case \"disavow[ed] [its] reliability . . . for legal use.\" Resp. at 14. But that is exactly the situation here, because the primary article on which the government relies—Exhibit A to its response—flatly says \"that grooming is not a construct that ought to be used in forensic settings as it does not meet some of the criteria in the Daubert standard.\" Resp., Ex. A, p 19.\n- The government says Rocchio's opinions are not \"anecdotal.\" But that's not right either, as her endorsement makes clear: Rocchio's opinions are based \"on her education and training on psychological trauma, traumatic stress, interpersonal violence, and sexual abuse [and her] extensive clinical experience treating individuals who suffered sexual abuse and trauma in childhood and adolescence,\n20\nDOJ-OGR-00005981",
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"content": "situation here, in which the alleged \"groomer\" was not the person who perpetrated the alleged abuse.",
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"content": "- Even where the \"groomer\" and \"perpetrator\" are the same person, courts have recognized the unreliability of grooming testimony. United States v. Gonyer, No. 1:12-CR-00021-JAW, 2012 WL 3043020, at *2-3 (D. Me. July 24, 2012); United States v. Raymond, 700 F. Supp. 2d 142, 146-47 (D. Me. 2010); United States v. Schneider, No. CRIM.A. 10-29, 2010 WL 3734055, at *4 (E.D. Pa. Sept. 22, 2010); see also United States v. Raniere, No. 18-CR-2041-NGG-VMS, 2019 WL 2212639, at *7 (E.D.N.Y. May 22, 2019); United States v. Burns, No. 07 CR 556, 2009 WL 3617448, at *5 (N.D. Ill. Oct. 27, 2009) (criticizing the \"grooming theory\" in the context of a sentencing guidelines calculation).",
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"content": "- The government tries to distinguish United States v. Raymond by saying that the expert's own book in that case \"disavow[ed] [its] reliability . . . for legal use.\" Resp. at 14. But that is exactly the situation here, because the primary article on which the government relies—Exhibit A to its response—flatly says \"that grooming is not a construct that ought to be used in forensic settings as it does not meet some of the criteria in the Daubert standard.\" Resp., Ex. A, p 19.",
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"content": "- The government says Rocchio's opinions are not \"anecdotal.\" But that's not right either, as her endorsement makes clear: Rocchio's opinions are based \"on her education and training on psychological trauma, traumatic stress, interpersonal violence, and sexual abuse [and her] extensive clinical experience treating individuals who suffered sexual abuse and trauma in childhood and adolescence,",
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}

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{
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 27 of 52\n\nas well as [her] experience conducting forensic psychological evaluations of people who have experienced sexual abuse and trauma.\" Mot. Ex. 1, p 2.\n\nThe government tries to disclaim the importance of error rates. Resp. at 15-17. But it's not just that Rocchio cannot identify an error rate, it's that her implicit conclusion is that she doesn't have an error rate. That is, all her patients are telling the truth when they say they were groomed, so any evidence that matches what her patients have told her is therefore evidence of grooming.\n\nBut even if the error-rate discussion were misplaced, that doesn't mean Rocchio's opinions are reliable. As a \"qualitative\" matter, and as the government's own Exhibit A concedes, there are no \"reliable principles and methods' to define and detect grooming.\" Govt. Resp., Ex. A, p 19 (quoting Fed. R. Evid. 702).\n\nThe government apparently expects that, \"somehow, a lay jury without guidance [will] apply [Rocchio's] analyses reliably to the facts of a case in determining guilt.\" See Raymond, 700 F. Supp. 2d at 150 (rejecting argument that a jury could do just that). This Court should not, as the government request, simply punt the matter to the jury. Resp. at 17-18. The Court is the gatekeeper. It must ensure the evidence is reliable and relevant. If it's not both, it has no place in a criminal jury trial, because it will \"radically simplify\" an otherwise complex case, Burns, 2009 WL 3617448, at *5, and it will, as the United States Supreme Court has cautioned, prejudicially mislead the jury, Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579, 595 (1993) (\"Expert evidence can be both powerful and quite misleading because of the difficulty in evaluating it.\")",
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"content": "as well as [her] experience conducting forensic psychological evaluations of people who have experienced sexual abuse and trauma.\" Mot. Ex. 1, p 2.\n\nThe government tries to disclaim the importance of error rates. Resp. at 15-17. But it's not just that Rocchio cannot identify an error rate, it's that her implicit conclusion is that she doesn't have an error rate. That is, all her patients are telling the truth when they say they were groomed, so any evidence that matches what her patients have told her is therefore evidence of grooming.\n\nBut even if the error-rate discussion were misplaced, that doesn't mean Rocchio's opinions are reliable. As a \"qualitative\" matter, and as the government's own Exhibit A concedes, there are no \"reliable principles and methods' to define and detect grooming.\" Govt. Resp., Ex. A, p 19 (quoting Fed. R. Evid. 702).\n\nThe government apparently expects that, \"somehow, a lay jury without guidance [will] apply [Rocchio's] analyses reliably to the facts of a case in determining guilt.\" See Raymond, 700 F. Supp. 2d at 150 (rejecting argument that a jury could do just that). This Court should not, as the government request, simply punt the matter to the jury. Resp. at 17-18. The Court is the gatekeeper. It must ensure the evidence is reliable and relevant. If it's not both, it has no place in a criminal jury trial, because it will \"radically simplify\" an otherwise complex case, Burns, 2009 WL 3617448, at *5, and it will, as the United States Supreme Court has cautioned, prejudicially mislead the jury, Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579, 595 (1993) (\"Expert evidence can be both powerful and quite misleading because of the difficulty in evaluating it.\")",
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65
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{
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 28 of 52\n\nThe government denies Ms. Maxwell's argument that \"a lay jury will be unable to apply Dr. Rocchio's analyses to the facts of this case\" because \"[t]hat is not how Rule 702 works.\" Resp. at 20. Responds the government: \"That is precisely how Rule 702 works in cases where experts testify about general principles, which the Rule contemplates.\" Id. at 21. Surely that is not right when, as here, the \"general principles\" are unreliable. Fed. R. Evid. 702, Advisory Committee Note (if expert testifies to general principles but not apply them, \"the testimony [must] be reliable\"). See also Mot. at 10; Raymond, 700 F. Supp. 2d at 150 n.12 (expert testimony about general principles is helpful only when it \"describe[s] widely recognized and highly predictable and verifiable phenomena\").\n\nThe government attempts to fault Ms. Maxwell for making \"no argument that the minor victims in this case are distinctive in some way such that general principles of psychology may diverge as to them.\" Resp. at 18. This argument flips the proper analysis on its head. It's the government's burden to prove reliability. E.g., United States v. Williams, 506 F.3d 151, 160 (2d Cir. 2007). It's not Ms. Maxwell's burden to prove unreliability (though if it were her burden, she would have met it).\n\nThe government says that \"the causal connection between . . . psychological problems and child sexual abuse is outside the experience of the average juror\" and is relevant to the alleged victims' credibility. Resp. at 24. It's not, and any minor probative value the evidence has is substantially outweighed by the danger of unfair prejudice. Fed. R. Evid. 401, 403. And as explained in the Rule 412 motion today, if Rocchio offers testimony and the government presents argument\n\n22\nDOJ-OGR-00005983",
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"content": "The government denies Ms. Maxwell's argument that \"a lay jury will be unable to apply Dr. Rocchio's analyses to the facts of this case\" because \"[t]hat is not how Rule 702 works.\" Resp. at 20. Responds the government: \"That is precisely how Rule 702 works in cases where experts testify about general principles, which the Rule contemplates.\" Id. at 21. Surely that is not right when, as here, the \"general principles\" are unreliable. Fed. R. Evid. 702, Advisory Committee Note (if expert testifies to general principles but not apply them, \"the testimony [must] be reliable\"). See also Mot. at 10; Raymond, 700 F. Supp. 2d at 150 n.12 (expert testimony about general principles is helpful only when it \"describe[s] widely recognized and highly predictable and verifiable phenomena\").",
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"content": "The government attempts to fault Ms. Maxwell for making \"no argument that the minor victims in this case are distinctive in some way such that general principles of psychology may diverge as to them.\" Resp. at 18. This argument flips the proper analysis on its head. It's the government's burden to prove reliability. E.g., United States v. Williams, 506 F.3d 151, 160 (2d Cir. 2007). It's not Ms. Maxwell's burden to prove unreliability (though if it were her burden, she would have met it).",
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"content": "The government says that \"the causal connection between . . . psychological problems and child sexual abuse is outside the experience of the average juror\" and is relevant to the alleged victims' credibility. Resp. at 24. It's not, and any minor probative value the evidence has is substantially outweighed by the danger of unfair prejudice. Fed. R. Evid. 401, 403. And as explained in the Rule 412 motion today, if Rocchio offers testimony and the government presents argument",
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}

65
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{
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 29 of 52\nalong these lines, that will open the door to other sexual behavior evidence. That door can remain at least partially closed if Rocchio is not permitted to offer her irrelevant and unfairly prejudicial testimony.\n- The government still hasn't explained how it helps the jury to be told that a victim of sexual abuse might make an immediate disclosure, or she might make an incremental disclosure, or she might make a delayed disclosure. Resp. at 27-30. And when the government says, \"[s]exual abuse also impacts the way memory is encoded,\" that opinion is far outside Rocchio's expertise because the parties agree that she is not an expert in \"the human brain or memory generally.\" Resp. at 30 n.7.\nC. At a minimum, this Court should hold a Daubert hearing.\nThere is ample reason for this Court to exclude Rocchio's testimony outright. At the very least, Ms. Maxwell is entitled to a Daubert hearing. The government implicitly concedes as much. In a footnote, the government acknowledges the decision in United States v. Raniere, in which Judge Garaufis ordered a Daubert hearing on the government's proposed expert testimony on grooming. 2019 WL 2212639, at *7-8. In that case, however, the government withdrew its endorsement rather than submit to a Daubert hearing. Resp. at 19 n.3.\nJudge Garaufis reasoned that even if other courts in other cases had admitted testimony about grooming, \"that [did] not make Dr. Hughes's opinion about grooming techniques reliable under the Daubert standard,\" if only because \"her extensive academic and clinical experience appears focused on victims of sexual abuse, not perpetrators.\" See id. at *7. The same is true here, particularly because Rocchio has no experience in, and there is no authority supporting her opinions on, grooming-by-proxy. Quite the contrary. The government's late-breaking disclosure states:\n23\nDOJ-OGR-00005984",
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"content": "along these lines, that will open the door to other sexual behavior evidence. That door can remain at least partially closed if Rocchio is not permitted to offer her irrelevant and unfairly prejudicial testimony.\n- The government still hasn't explained how it helps the jury to be told that a victim of sexual abuse might make an immediate disclosure, or she might make an incremental disclosure, or she might make a delayed disclosure. Resp. at 27-30. And when the government says, \"[s]exual abuse also impacts the way memory is encoded,\" that opinion is far outside Rocchio's expertise because the parties agree that she is not an expert in \"the human brain or memory generally.\" Resp. at 30 n.7.",
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"content": "C. At a minimum, this Court should hold a Daubert hearing.",
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"content": "There is ample reason for this Court to exclude Rocchio's testimony outright. At the very least, Ms. Maxwell is entitled to a Daubert hearing. The government implicitly concedes as much. In a footnote, the government acknowledges the decision in United States v. Raniere, in which Judge Garaufis ordered a Daubert hearing on the government's proposed expert testimony on grooming. 2019 WL 2212639, at *7-8. In that case, however, the government withdrew its endorsement rather than submit to a Daubert hearing. Resp. at 19 n.3.\nJudge Garaufis reasoned that even if other courts in other cases had admitted testimony about grooming, \"that [did] not make Dr. Hughes's opinion about grooming techniques reliable under the Daubert standard,\" if only because \"her extensive academic and clinical experience appears focused on victims of sexual abuse, not perpetrators.\" See id. at *7. The same is true here, particularly because Rocchio has no experience in, and there is no authority supporting her opinions on, grooming-by-proxy. Quite the contrary. The government's late-breaking disclosure states:",
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}

85
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{
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 30 of 52\n\nThus currently it appears that grooming is not a construct that ought to be used in forensic settings as it does not meet some of the criteria in the Daubert standard. . . . Right now it does not appear to be the case that there are \"reliable principles and methods\" to define and detect grooming.\n\nId. at 19 (emphasis added).\n\nAt a minimum, therefore, this Court should hold a Daubert hearing.\n\nIV. THE COURT SHOULD EXCLUDE EVIDENCE RELATED\n\nThe government's arguments in favor of admitting evidence related as direct evidence of the charged conspiracies all but concede that the evidence is more appropriately considered under Rule 404(b). In an effort to bolster their position, the government makes the sweeping assertion that as long as was under the age of 18, her evidence is admissible as direct evidence of the conspiracy. That is a fundamentally incorrect statement of the law and should be rejected. The government's arguments for admitting evidence under Rule 404(b) and for denying the defense's requested limiting instruction are similarly baseless. The Court should therefore exclude evidence related to or, if it is admitted, give the jury the requested limiting instruction.7\n\nThe government advances four principal arguments for why evidence related to should be admitted as direct evidence of the charged conspiracies: (1) her testimony allegedly shows a \"pattern\" of how Epstein and Ms. Maxwell sexually abused young women and establishes Ms. Maxwell's \"intent\" to participate in the charged conspiracies (Resp. at 45-46),\n\n(2) her allegations are included in the S2 Indictment and are therefore not covered by Rule\n\n7 As it pertains to and the other accusers, the defense will be submitting proposed jury instructions and special verdict findings.\n\n24\n\nDOJ-OGR-00005985",
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"content": "Thus currently it appears that grooming is not a construct that ought to be used in forensic settings as it does not meet some of the criteria in the Daubert standard. . . . Right now it does not appear to be the case that there are \"reliable principles and methods\" to define and detect grooming.",
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{
"type": "printed",
"content": "Id. at 19 (emphasis added).",
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"content": "At a minimum, therefore, this Court should hold a Daubert hearing.",
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"content": "IV. THE COURT SHOULD EXCLUDE EVIDENCE RELATED",
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"content": "The government's arguments in favor of admitting evidence related as direct evidence of the charged conspiracies all but concede that the evidence is more appropriately considered under Rule 404(b). In an effort to bolster their position, the government makes the sweeping assertion that as long as was under the age of 18, her evidence is admissible as direct evidence of the conspiracy. That is a fundamentally incorrect statement of the law and should be rejected. The government's arguments for admitting evidence under Rule 404(b) and for denying the defense's requested limiting instruction are similarly baseless. The Court should therefore exclude evidence related to or, if it is admitted, give the jury the requested limiting instruction.7",
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"content": "The government advances four principal arguments for why evidence related to should be admitted as direct evidence of the charged conspiracies: (1) her testimony allegedly shows a \"pattern\" of how Epstein and Ms. Maxwell sexually abused young women and establishes Ms. Maxwell's \"intent\" to participate in the charged conspiracies (Resp. at 45-46),",
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}

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{
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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 31 of 52\n404(b) (id. at 46-47), (3) her evidence is \"intrinsic\" proof of the charged conspiracies and necessary to \"complete the story\" of the charged offenses (id. at 47-49), and (4) was under the age of 18, the age of consent under federal law, when the alleged sexual abuse took place, and that is \"all that is required for evidence relating to the defendant's exploitation of Minor Victim-3 to be direct evidence of the charged offenses\" (id. at 50). The first is an argument for admission of this evidence under Rule 404(b), not as direct evidence of the conspiracy. The second simply begs the question and assumes that the government can circumvent Rule 404(b) by alleging \"other act\" evidence in the indictment. The third overlooks the numerous precedents in this Circuit finding that evidence of criminal offenses that are separate and distinct from the charged offenses are not admissible as direct evidence of a conspiracy. And the fourth completely misstates the law. These arguments should be rejected.\nFirst, the government argues that evidence is admissible as direct evidence of the charged conspiracies because it is relevant to show the \"pattern\" of abuse—including \"grooming\" the accusers, encouraging them to give massages to Epstein, and asking them to recruit others—and her \"intent\" to participate in the charged conspiracies. (Id. at 45-46). But \"pattern\" is just another word for \"modus operandi,\" which along with \"intent\" are bases for admission under Rule 404(b), not as direct evidence of the conspiracies. See Fed. R. Evid. 404(b) (\"other act\" evidence may be admissible to prove \"motive, opportunity, intent, preparation, plan, knowledge, identity, absence of mistake, or lack of accident\") (emphasis added); United States v. Walia, No. 14-CR-213 (MKB), 2014 WL 3734522, at *13 (S.D.N.Y. Jul. 25, 2014) (Rule 404(b) permits \"other act\" evidence to be admitted to prove \"modus operandi\").\n25\nDOJ-OGR-00005986",
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"content": "404(b) (id. at 46-47), (3) her evidence is \"intrinsic\" proof of the charged conspiracies and necessary to \"complete the story\" of the charged offenses (id. at 47-49), and (4) was under the age of 18, the age of consent under federal law, when the alleged sexual abuse took place, and that is \"all that is required for evidence relating to the defendant's exploitation of Minor Victim-3 to be direct evidence of the charged offenses\" (id. at 50). The first is an argument for admission of this evidence under Rule 404(b), not as direct evidence of the conspiracy. The second simply begs the question and assumes that the government can circumvent Rule 404(b) by alleging \"other act\" evidence in the indictment. The third overlooks the numerous precedents in this Circuit finding that evidence of criminal offenses that are separate and distinct from the charged offenses are not admissible as direct evidence of a conspiracy. And the fourth completely misstates the law. These arguments should be rejected.",
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"content": "First, the government argues that evidence is admissible as direct evidence of the charged conspiracies because it is relevant to show the \"pattern\" of abuse—including \"grooming\" the accusers, encouraging them to give massages to Epstein, and asking them to recruit others—and her \"intent\" to participate in the charged conspiracies. (Id. at 45-46). But \"pattern\" is just another word for \"modus operandi,\" which along with \"intent\" are bases for admission under Rule 404(b), not as direct evidence of the conspiracies. See Fed. R. Evid. 404(b) (\"other act\" evidence may be admissible to prove \"motive, opportunity, intent, preparation, plan, knowledge, identity, absence of mistake, or lack of accident\") (emphasis added); United States v. Walia, No. 14-CR-213 (MKB), 2014 WL 3734522, at *13 (S.D.N.Y. Jul. 25, 2014) (Rule 404(b) permits \"other act\" evidence to be admitted to prove \"modus operandi\").",
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}

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"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 32 of 52\n\nThe very case the government cites in support of their position, United States v. Curley, 639 F.3d 50 (2d Cir. 2011), affirmed the district court's decision to admit \"other act\" evidence of prior spousal abuse to prove \"intent\" and \"pattern\" under Rule 404(b) \"with an appropriate instruction on this evidence's limited purpose,\" not as direct evidence of the conspiracy. See Curley, 639 F.3d at 59 (citing United States v. Von Foelkel, 136 F.3d 339, 340-41 (2d Cir. 1998) (per curiam) (affirming district court's decision to admit evidence of prior domestic violence to prove defendant's intent under Rule 404(b)). Indeed, the evidence could not have been admitted as direct evidence of a conspiracy because Curley was not charged with a conspiracy. See United States v. Curley, No. S1 08 Cr. 404 (SCR), 2009 WL 10688209, at *1 (S.D.N.Y. Jul. 15, 2009) (defendant was convicted of two counts of stalking and one count of interstate violation of a protection order). Curley therefore supports the defense's position that the admissibility of evidence must be evaluated under Rule 404(b).\n\nSecond, the government does not confront the defense's point that simply including \"other act\" evidence in the indictment does not necessarily mean it is direct evidence of the conspiracy. See Mot. at 9-10. Instead, the government engages in circular reasoning by effectively arguing that (i) allegations in an indictment are not 404(b) evidence, (ii) allegations are in the indictment, (iii) therefore they are not 404(b) evidence. See Resp. at 46-47. But as the defense pointed out in its Motion, \"other acts\" are only admissible as evidence of a conspiracy \"as long as they are within the scope of the conspiracy.\" United States v. Cummings, 60 F. Supp. 3d 434, 437 (S.D.N.Y. 2014), vacated on other grounds 858 F.3d 763 (2d Cir. 2017) (quoting United States v. Bagaric, 706 F.2d 42, 64 (2d Cir. 1983)). The government has not explained why evidence provides any proof that Ms. Maxwell \"furthered\" an alleged conspiracy to cause minors (she did not) to travel (she did not)\n\n26\n\nDOJ-OGR-00005987",
"text_blocks": [
{
"type": "printed",
"content": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 32 of 52",
"position": "header"
},
{
"type": "printed",
"content": "The very case the government cites in support of their position, United States v. Curley, 639 F.3d 50 (2d Cir. 2011), affirmed the district court's decision to admit \"other act\" evidence of prior spousal abuse to prove \"intent\" and \"pattern\" under Rule 404(b) \"with an appropriate instruction on this evidence's limited purpose,\" not as direct evidence of the conspiracy. See Curley, 639 F.3d at 59 (citing United States v. Von Foelkel, 136 F.3d 339, 340-41 (2d Cir. 1998) (per curiam) (affirming district court's decision to admit evidence of prior domestic violence to prove defendant's intent under Rule 404(b)). Indeed, the evidence could not have been admitted as direct evidence of a conspiracy because Curley was not charged with a conspiracy. See United States v. Curley, No. S1 08 Cr. 404 (SCR), 2009 WL 10688209, at *1 (S.D.N.Y. Jul. 15, 2009) (defendant was convicted of two counts of stalking and one count of interstate violation of a protection order). Curley therefore supports the defense's position that the admissibility of evidence must be evaluated under Rule 404(b).",
"position": "main body"
},
{
"type": "printed",
"content": "Second, the government does not confront the defense's point that simply including \"other act\" evidence in the indictment does not necessarily mean it is direct evidence of the conspiracy. See Mot. at 9-10. Instead, the government engages in circular reasoning by effectively arguing that (i) allegations in an indictment are not 404(b) evidence, (ii) allegations are in the indictment, (iii) therefore they are not 404(b) evidence. See Resp. at 46-47. But as the defense pointed out in its Motion, \"other acts\" are only admissible as evidence of a conspiracy \"as long as they are within the scope of the conspiracy.\" United States v. Cummings, 60 F. Supp. 3d 434, 437 (S.D.N.Y. 2014), vacated on other grounds 858 F.3d 763 (2d Cir. 2017) (quoting United States v. Bagaric, 706 F.2d 42, 64 (2d Cir. 1983)). The government has not explained why evidence provides any proof that Ms. Maxwell \"furthered\" an alleged conspiracy to cause minors (she did not) to travel (she did not)",
"position": "main body"
},
{
"type": "printed",
"content": "26",
"position": "footer"
},
{
"type": "printed",
"content": "DOJ-OGR-00005987",
"position": "footer"
}
],
"entities": {
"people": [
"Curley",
"Von Foelkel",
"Cummings",
"Bagaric",
"Maxwell"
],
"organizations": [
"United States"
],
"locations": [
"S.D.N.Y.",
"2d Cir."
],
"dates": [
"10/29/21",
"Jul. 15, 2009",
"2011",
"1998",
"2014",
"2017"
],
"reference_numbers": [
"Case 1:20-cr-00330-PAE",
"Document 398",
"639 F.3d 50",
"136 F.3d 339",
"2009 WL 10688209",
"60 F. Supp. 3d 434",
"858 F.3d 763",
"706 F.2d 42",
"S1 08 Cr. 404 (SCR)",
"DOJ-OGR-00005987"
]
},
"additional_notes": "The document appears to be a court filing related to the case United States v. Maxwell. The text discusses the admissibility of 'other act' evidence under Rule 404(b) and references several legal precedents. There are redactions in the text, likely to protect sensitive information."
}

61
results/IMAGES003/DOJ-OGR-00005988.json Normal file
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@@ -0,0 +1,61 @@
{
"document_metadata": {
"page_number": "33",
"document_number": "398",
"date": "10/29/21",
"document_type": "court document",
"has_handwriting": false,
"has_stamps": false
},
"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 33 of 52\nfor the purpose of engaging in unlawful sexual activity (it was not). Moreover, allowing the government to circumvent Rule 404(b) by charging \"other act\" evidence in the Indictment would swallow the rule and allow the jury to broadly consider evidence that should only be considered for a limited purpose and with an appropriate limiting instruction regarding propensity. The Court should not allow this.\nThird, the government claims that evidence can be admitted as intrinsic proof of the charged conspiracies to show Ms. Maxwell's (1) \"relationship with Epstein, including her willingness to procure teenagers to give Epstein massages,\" (2) \"knowledge of both the sexual nature of those massages and the need to procure additional victims,\" and (3) \"willingness to transport minors to further their abuse.\" Resp. at 47. The government further argues that evidence is necessary to \"complete the story\" of the charged offenses. Id. at 48-49. In its Motion, the defense cited numerous cases in this Circuit holding that evidence of other conduct involving alleged co-conspirators—even conduct that was similar to the charged offenses—was not admissible as intrinsic proof of the conspiracies if the other conduct was separate and distinct from the charged offenses. See Mot. at 9 (citing cases). The government concedes that these cases so hold and points out that these cases admitted some of the proffered evidence under Rule 404(b). Resp. at 48 n.11. This just proves the point; the admissibility of evidence should be evaluated under Rule 404(b).\nFourth, the government asserts that the defense \"misunderstands\" the law and that the government simply needs to prove that Ms. Maxwell \"took steps to provide Jeffrey Epstein with access to girls under the age of 18, knowing that Epstein intended to have sexual contact with those girls.\" Id. at 50 (emphasis added). In the government's view, it is totally irrelevant that\n27\nDOJ-OGR-00005988",
"text_blocks": [
{
"type": "printed",
"content": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 33 of 52",
"position": "header"
},
{
"type": "printed",
"content": "for the purpose of engaging in unlawful sexual activity (it was not). Moreover, allowing the government to circumvent Rule 404(b) by charging \"other act\" evidence in the Indictment would swallow the rule and allow the jury to broadly consider evidence that should only be considered for a limited purpose and with an appropriate limiting instruction regarding propensity. The Court should not allow this.",
"position": "top"
},
{
"type": "printed",
"content": "Third, the government claims that evidence can be admitted as intrinsic proof of the charged conspiracies to show Ms. Maxwell's (1) \"relationship with Epstein, including her willingness to procure teenagers to give Epstein massages,\" (2) \"knowledge of both the sexual nature of those massages and the need to procure additional victims,\" and (3) \"willingness to transport minors to further their abuse.\" Resp. at 47. The government further argues that evidence is necessary to \"complete the story\" of the charged offenses. Id. at 48-49. In its Motion, the defense cited numerous cases in this Circuit holding that evidence of other conduct involving alleged co-conspirators—even conduct that was similar to the charged offenses—was not admissible as intrinsic proof of the conspiracies if the other conduct was separate and distinct from the charged offenses. See Mot. at 9 (citing cases). The government concedes that these cases so hold and points out that these cases admitted some of the proffered evidence under Rule 404(b). Resp. at 48 n.11. This just proves the point; the admissibility of evidence should be evaluated under Rule 404(b).",
"position": "middle"
},
{
"type": "printed",
"content": "Fourth, the government asserts that the defense \"misunderstands\" the law and that the government simply needs to prove that Ms. Maxwell \"took steps to provide Jeffrey Epstein with access to girls under the age of 18, knowing that Epstein intended to have sexual contact with those girls.\" Id. at 50 (emphasis added). In the government's view, it is totally irrelevant that",
"position": "middle"
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"type": "printed",
"content": "27",
"position": "bottom"
},
{
"type": "printed",
"content": "DOJ-OGR-00005988",
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}
],
"entities": {
"people": [
"Ms. Maxwell",
"Jeffrey Epstein",
"Epstein"
],
"organizations": [],
"locations": [],
"dates": [
"10/29/21"
],
"reference_numbers": [
"1:20-cr-00330-PAE",
"Document 398",
"DOJ-OGR-00005988"
]
},
"additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, with discussions around the admissibility of certain evidence under Rule 404(b). The text is mostly printed, with no visible handwriting or stamps. The document is from a legal proceeding and contains legal terminology and references to specific court rules and cases."
}

66
results/IMAGES003/DOJ-OGR-00005989.json Normal file
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@@ -0,0 +1,66 @@
{
"document_metadata": {
"page_number": "34 of 52",
"document_number": "398",
"date": "10/29/21",
"document_type": "court document",
"has_handwriting": false,
"has_stamps": false
},
"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 34 of 52. See id. at 49-50. According to the government, \"all that is required\" for evidence to be admissible as direct evidence of the charged conspiracies is that she was under the age of 18, the age of consent under U.S. federal law, and that Ms. Maxwell knew that Epstein intended to engage in sexual contact with her. See id. It is the government, not the defense, that apparently does not understand the law. The Mann Act conspiracies charged in the S2 Indictment each require proof that Ms. Maxwell acted with the intent that the alleged victim would \"engage in sexual activity for which a person can be charged with a criminal offense.\" S2 Ind. ¶¶ 12 (citing 18 U.S.C. § 2422), 18 (citing 18 U.S.C. § 2423(a)). That element incorporates offenses under state law. See United States v. Lincoln, No. 19-CR-6047 (CJS), 2019 WL 719822, at *4 (W.D.N.Y. Dec. 23, 2019) (collecting § 2422 cases); United States v. Vickers, 708 F. App'x 732, 735 (2d Cir. 2017) (summary order) (criminal sexual activity under § 2423 includes crimes \"under federal, state, or foreign law\"). Indeed, the Mann Act conspiracies in the S2 Indictment charge a violation of a New York State misdemeanor as the \"sexual activity for which a person can be charged with a criminal offense.\" S2 Ind. ¶¶ 13b, 19b (citing N.Y. Penal Law § 130.55). Section 130.55 prohibits \"subject[ing] another person to sexual contact without the latter's consent.\" N.Y. Penal Law § 130.55. To be guilty of Section 130.55 based on the victim's incapacity to consent due to age, the victim must be under the age of 17. Id. § 130.05(3)(a). The government itself acknowledged this in its draft proposed jury instructions, as well as the fact that Ms. Maxwell cannot be convicted of the Mann Act conspiracies unless she knew that the alleged victim was under 17. See Gov't Proposed Jury Instructions (\"[I]n order to find that the intended acts were nonconsensual solely because of the victim's age...\"). 28 DOJ-OGR-00005989",
"text_blocks": [
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"content": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 34 of 52",
"position": "header"
},
{
"type": "printed",
"content": ". See id. at 49-50. According to the government, \"all that is required\" for evidence to be admissible as direct evidence of the charged conspiracies is that she was under the age of 18, the age of consent under U.S. federal law, and that Ms. Maxwell knew that Epstein intended to engage in sexual contact with her. See id.",
"position": "top"
},
{
"type": "printed",
"content": "It is the government, not the defense, that apparently does not understand the law. The Mann Act conspiracies charged in the S2 Indictment each require proof that Ms. Maxwell acted with the intent that the alleged victim would \"engage in sexual activity for which a person can be charged with a criminal offense.\" S2 Ind. ¶¶ 12 (citing 18 U.S.C. § 2422), 18 (citing 18 U.S.C. § 2423(a)). That element incorporates offenses under state law. See United States v. Lincoln, No. 19-CR-6047 (CJS), 2019 WL 719822, at *4 (W.D.N.Y. Dec. 23, 2019) (collecting § 2422 cases); United States v. Vickers, 708 F. App'x 732, 735 (2d Cir. 2017) (summary order) (criminal sexual activity under § 2423 includes crimes \"under federal, state, or foreign law\"). Indeed, the Mann Act conspiracies in the S2 Indictment charge a violation of a New York State misdemeanor as the \"sexual activity for which a person can be charged with a criminal offense.\" S2 Ind. ¶¶ 13b, 19b (citing N.Y. Penal Law § 130.55). Section 130.55 prohibits \"subject[ing] another person to sexual contact without the latter's consent.\" N.Y. Penal Law § 130.55. To be guilty of Section 130.55 based on the victim's incapacity to consent due to age, the victim must be under the age of 17. Id. § 130.05(3)(a). The government itself acknowledged this in its draft proposed jury instructions, as well as the fact that Ms. Maxwell cannot be convicted of the Mann Act conspiracies unless she knew that the alleged victim was under 17. See Gov't Proposed Jury Instructions (\"[I]n order to find that the intended acts were nonconsensual solely because of the",
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"position": "bottom"
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{
"type": "printed",
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],
"entities": {
"people": [
"Ms. Maxwell",
"Epstein"
],
"organizations": [
"U.S. government",
"New York State"
],
"locations": [
"New York"
],
"dates": [
"10/29/21",
"Dec. 23, 2019"
],
"reference_numbers": [
"Case 1:20-cr-00330-PAE",
"Document 398",
"S2 Indictment",
"18 U.S.C. § 2422",
"18 U.S.C. § 2423(a)",
"N.Y. Penal Law § 130.55",
"No. 19-CR-6047 (CJS)",
"DOJ-OGR-00005989"
]
},
"additional_notes": "The document appears to be a court filing related to the case against Ms. Maxwell. The text discusses the requirements for evidence admissibility and the elements of the Mann Act conspiracies charged in the S2 Indictment. The document includes citations to various laws and court cases."
}

57
results/IMAGES003/DOJ-OGR-00005990.json Normal file
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@@ -0,0 +1,57 @@
{
"document_metadata": {
"page_number": "35",
"document_number": "398",
"date": "10/29/21",
"document_type": "court document",
"has_handwriting": false,
"has_stamps": false
},
"full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 35 of 52\nvictim's age, you must find that the defendant knew that the victim was less than seventeen years old.\") (emphasis added).\nIt is unclear whether the government is now claiming that to admit evidence as proof of the Mann Act conspiracies, it only needs to prove that was under the age of 18 at the time of the alleged abuse and that Ms. Maxwell did not need to know anything about age, or that Ms. Maxwell only needed to know that was under the age of 18. Either one is a misstatement of the law. For \"sexual activity\" to be \"criminal,\" it must be illegal under the laws of the jurisdiction where the sex acts allegedly took place. If those crimes are based on lack of consent due to age, it is only illegal if the alleged victim is under the age of consent in that jurisdiction. And according to the government's own proposed jury instructions, Ms. Maxwell can only be found guilty of the Mann Act conspiracies if she knew (and the other alleged victims) were under the age of consent in the particular jurisdictions where the sex acts allegedly took place. Because was, at all times, over the age of consent in the relevant jurisdictions, her evidence is not within the scope of the charged conspiracies and is therefore not admissible as direct evidence. At the very least, because it is not \"manifestly clear\" that evidence is proof of the charged conspiracies, \"the proper course is to proceed under Rule 404(b).\" United States v. Townsend, No. S1 06 CR. 34 (JFK), 2007 WL 1288597, at *1 (S.D.N.Y. May 1, 2007) (citing United States v. Nektalov, 325 F. Supp. 2d 367, 372 (S.D.N.Y. 2004)).\nevidence should also be excluded under Rule 404(b) and Rule 403.\nAs argued in our initial Motion, evidence that Ms. Maxwell allegedly encouraged an adult to engage in legal sexual activity is not, in any way, evidence of her intent to facilitate Epstein's\n29\nDOJ-OGR-00005990",
"text_blocks": [
{
"type": "printed",
"content": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 35 of 52",
"position": "header"
},
{
"type": "printed",
"content": "victim's age, you must find that the defendant knew that the victim was less than seventeen years old.\") (emphasis added).\nIt is unclear whether the government is now claiming that to admit evidence as proof of the Mann Act conspiracies, it only needs to prove that was under the age of 18 at the time of the alleged abuse and that Ms. Maxwell did not need to know anything about age, or that Ms. Maxwell only needed to know that was under the age of 18. Either one is a misstatement of the law. For \"sexual activity\" to be \"criminal,\" it must be illegal under the laws of the jurisdiction where the sex acts allegedly took place. If those crimes are based on lack of consent due to age, it is only illegal if the alleged victim is under the age of consent in that jurisdiction. And according to the government's own proposed jury instructions, Ms. Maxwell can only be found guilty of the Mann Act conspiracies if she knew (and the other alleged victims) were under the age of consent in the particular jurisdictions where the sex acts allegedly took place. Because was, at all times, over the age of consent in the relevant jurisdictions, her evidence is not within the scope of the charged conspiracies and is therefore not admissible as direct evidence. At the very least, because it is not \"manifestly clear\" that evidence is proof of the charged conspiracies, \"the proper course is to proceed under Rule 404(b).\" United States v. Townsend, No. S1 06 CR. 34 (JFK), 2007 WL 1288597, at *1 (S.D.N.Y. May 1, 2007) (citing United States v. Nektalov, 325 F. Supp. 2d 367, 372 (S.D.N.Y. 2004)).\nevidence should also be excluded under Rule 404(b) and Rule 403.\nAs argued in our initial Motion, evidence that Ms. Maxwell allegedly encouraged an adult to engage in legal sexual activity is not, in any way, evidence of her intent to facilitate Epstein's",
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{
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"entities": {
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"locations": [
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"reference_numbers": [
"Case 1:20-cr-00330-PAE",
"Document 398",
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]
},
"additional_notes": "The document appears to be a court filing with redactions. The text is mostly printed, with no handwritten content or stamps visible."
}

Some files were not shown because too many files have changed in this diff Show More