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    "page_number": "151",
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    "date": "11/23/21",
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  "full_text": "Case 1:20-cr-00330-PAE Document 499-2 Filed 11/23/21 Page 151 of 159\nLBAAMAX5ps\nRocchio - Cross\n1 THE COURT: OK.\n2 BY MR. PAGLIUCA:\n3 Q. We're going down to the bottom of page 5.\n4 A. Yes.\n5 Actually, you know what, it's on my screen properly\n6 now, so it's going to be easier for me to look there, because\n7 it's bigger.\n8 OK.\n9 Q. So I want to just highlight here one of the problems with\n10 these studies that you're relying on is, we've got a comment,\n11 \"Two-thirds of the sample did not disclose right away.\" But we\n12 don't define what \"right away\" means, do we?\n13 A. So to be clear, the article that I submitted was a summary\n14 of the literature. I'm not saying that I have read and\n15 examined every study cited in this particular article. So I\n16 really can't speak as to how those in this article identified\n17 or defined \"rate of disclosure.\" I would expect, however, that\n18 it would be defined in the full article itself. It's not\n19 defined here in the brief summary. But typically in scientific\n20 literature, it would -- the time period of disclosure that the\n21 authors were investigating, I would expect to find that in the\n22 article itself.\n23 Q. OK. But apparently you haven't gone back to look at the\n24 underlying data. Is that right?\n25 A. I have not gone back to look at every reference cited in\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00008019",
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      "content": "Case 1:20-cr-00330-PAE Document 499-2 Filed 11/23/21 Page 151 of 159",
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      "content": "LBAAMAX5ps\nRocchio - Cross",
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      "content": "1 THE COURT: OK.\n2 BY MR. PAGLIUCA:\n3 Q. We're going down to the bottom of page 5.\n4 A. Yes.\n5 Actually, you know what, it's on my screen properly\n6 now, so it's going to be easier for me to look there, because\n7 it's bigger.\n8 OK.\n9 Q. So I want to just highlight here one of the problems with\n10 these studies that you're relying on is, we've got a comment,\n11 \"Two-thirds of the sample did not disclose right away.\" But we\n12 don't define what \"right away\" means, do we?\n13 A. So to be clear, the article that I submitted was a summary\n14 of the literature. I'm not saying that I have read and\n15 examined every study cited in this particular article. So I\n16 really can't speak as to how those in this article identified\n17 or defined \"rate of disclosure.\" I would expect, however, that\n18 it would be defined in the full article itself. It's not\n19 defined here in the brief summary. But typically in scientific\n20 literature, it would -- the time period of disclosure that the\n21 authors were investigating, I would expect to find that in the\n22 article itself.\n23 Q. OK. But apparently you haven't gone back to look at the\n24 underlying data. Is that right?\n25 A. I have not gone back to look at every reference cited in",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "DOJ-OGR-00008019",
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    "dates": [
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      "499-2",
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