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    "page_number": "114",
    "document_number": "499-2",
    "date": "11/23/21",
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  "full_text": "Case 1:20-cr-00330-PAE Document 499-2 Filed 11/23/21 Page 114 of 159\nLBAGmax4 Rocchio - Cross\n1 literature around which specific vulnerabilities have been\n2 found to be associated with which particular outcomes or\n3 adverse outcomes. So it's not that every single vulnerability\n4 has been found to increase vulnerability for every potential\n5 outcome. There's a relationship between particular types of\n6 vulnerability and particular types of outcome.\n7 Q. It's also true that there can be more than one\n8 vulnerability in a human being?\n9 A. Of course, yes.\n10 Q. One can be a victim of sexual abuse and have other\n11 vulnerability factors; correct?\n12 A. Yes.\n13 Q. Or conversely, somebody can have vulnerability factors and\n14 then become a victim of sexual abuse; correct?\n15 A. Yes.\n16 Q. I want to turn now to some of your questions about\n17 grooming, okay, some of your opinions about grooming.\n18 What is your definition of grooming?\n19 A. The definition that's commonly used in the literature is --\n20 Q. I didn't ask that question.\n21 THE COURT: You may answer. Go ahead.\n22 THE WITNESS: The term grooming refers to a set of\n23 deceptive strategies that are utilized by an individual to\n24 establish a relationship of coercion and control for the\n25 purposes of subsequent sexual exploitation and sexual abuse.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00007982",
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      "content": "Case 1:20-cr-00330-PAE Document 499-2 Filed 11/23/21 Page 114 of 159",
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    {
      "type": "printed",
      "content": "LBAGmax4 Rocchio - Cross",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 literature around which specific vulnerabilities have been\n2 found to be associated with which particular outcomes or\n3 adverse outcomes. So it's not that every single vulnerability\n4 has been found to increase vulnerability for every potential\n5 outcome. There's a relationship between particular types of\n6 vulnerability and particular types of outcome.\n7 Q. It's also true that there can be more than one\n8 vulnerability in a human being?\n9 A. Of course, yes.\n10 Q. One can be a victim of sexual abuse and have other\n11 vulnerability factors; correct?\n12 A. Yes.\n13 Q. Or conversely, somebody can have vulnerability factors and\n14 then become a victim of sexual abuse; correct?\n15 A. Yes.\n16 Q. I want to turn now to some of your questions about\n17 grooming, okay, some of your opinions about grooming.\n18 What is your definition of grooming?\n19 A. The definition that's commonly used in the literature is --\n20 Q. I didn't ask that question.\n21 THE COURT: You may answer. Go ahead.\n22 THE WITNESS: The term grooming refers to a set of\n23 deceptive strategies that are utilized by an individual to\n24 establish a relationship of coercion and control for the\n25 purposes of subsequent sexual exploitation and sexual abuse.",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00007982",
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "11/23/21"
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      "1:20-cr-00330-PAE",
      "499-2",
      "DOJ-OGR-00007982"
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}