November 4, 2021 WebEx with Dr. Rocchio • Prepared for hearing • Clarification after reading our brief: o Will testify about generally well accepted principles in memory. Foundational principles, some derived from Loftus, well accepted in literature o Not an expert on memory o Key principles are in agreement o LR has gone to a training by Loftus • Very difficult to distinguish grooming/non-grooming ex ante -> models require conscious intention, but context matters. Grooming is not a single act, it's a series of behaviors • Described articles o "Observing Coercive Control" by Duron, Johnson, et al. o 2009 study by Leclerc, et al. o "Toward a Universal Definition of Childhood Grooming" in June 2021 in Deviant Behavior by Winters. She looks at criteria in literature, not common tactics or definitions. Responds to Bennett & O'Donohue o "Validation of the Sexual Grooming Model of Child Sexual Abusers" in 2020 in J. Child Sexual Abuse by Winters • Bennett and O'Donohue o list 13 specific exemplars of grooming o Captures commonalities and tactics in literature as well as measurement problems o Agrees that there's no universally agreed upon definition but there are a variety of tactics that appear consistently, etc. Studies use slightly different definitions, but core is there -> general consensus that these behaviors are part of dynamic of childhood sexual abuse, which is different than a settled definition o Grooming is much easier to recognize after the fact. Very nature is that the offender is hiding grooming as its happening. o There are studies where people have trouble understanding hypos on the page. But the way to do it is to identify replicated commonalities. Can't give a test. o Interrater reliability — whether or not separate individuals agree on how to code behaviors o Does not agree with Bennett & O'Donohue opinion about whether grooming should be used in forensic settings. • In such settings, does not take anything at fac