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- "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 96 of 158 96 LBAAMAX3ps Rocchio - Cross 1 Q. OK. 2 A. I'm not sure, though. 3 Q. Have you reviewed any of the notes taken by the government during your interviews? 4 5 A. No, I have not. 6 Q. Did you take any notes during any of your interviews? 7 A. Only on topics that I wanted to go and pursue, like subject headings of areas that they wanted me to speak about and educate the Court about. 8 9 10 Q. And did you record those topics in some sort of file? 11 A. No, I did not. 12 Q. Do you have those notes? 13 A. No, I do not. 14 Q. What did you do with those notes? 15 A. At the time that we were talking, I wrote, like, \"grooming\" as a subject matter, and then when I went and researched the literature, I threw those notes away. 16 17 18 Q. OK. So is that your practice, to take notes and then throw them away? 19 20 A. It depends on the purpose of the note. If the note is just a reminder to me, there's no reason for me to keep it. 21 22 Q. And do you have a file in connection with your retention in this case? 23 24 A. I do. 25 Q. What do you have in your file? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007275",
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- "content": "1 Q. OK. 2 A. I'm not sure, though. 3 Q. Have you reviewed any of the notes taken by the government during your interviews? 4 5 A. No, I have not. 6 Q. Did you take any notes during any of your interviews? 7 A. Only on topics that I wanted to go and pursue, like subject headings of areas that they wanted me to speak about and educate the Court about. 8 9 10 Q. And did you record those topics in some sort of file? 11 A. No, I did not. 12 Q. Do you have those notes? 13 A. No, I do not. 14 Q. What did you do with those notes? 15 A. At the time that we were talking, I wrote, like, \"grooming\" as a subject matter, and then when I went and researched the literature, I threw those notes away. 16 17 18 Q. OK. So is that your practice, to take notes and then throw them away? 19 20 A. It depends on the purpose of the note. If the note is just a reminder to me, there's no reason for me to keep it. 21 22 Q. And do you have a file in connection with your retention in this case? 23 24 A. I do. 25 Q. What do you have in your file?",
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- "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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