mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00007281.json

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  "full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 102 of 158 102 LBAAMAX3ps Rocchio - Cross\n\n1 Q. Did you recall discussing this with Ms. Comey, Ms. Moe,\n2 Ms. Pomerantz, Mr. Rohrbach, and telling them that \"child\" is\n3 anyone below the age of consent?  Do you recall that?\n4 A. I don't have anything on the screen in front of me, so I --\n5 I'm not sure what you're referring to.\n6 Q. I'm just asking if you recall that at this point.\n7 A. No. Sorry. I don't.\n8 Q. OK. Do you have any reason to believe that any of those\n9 AUSAs would take that down incorrectly?\n10 A. I'm not sure of the context under which it was taken.  I\n11 think, you know, for -- I haven't reviewed it. I didn't have a\n12 chance to correct it. I, I really have no idea.\n13 Q. OK. Also, you used the term \"sexual abuse,\" and that's\n14 nonconsensual sexual touch. Is that correct?\n15 A. That is one of the definitions, yes. It doesn't have to\n16 be.\n17 Q. Well, is that the definition that you gave the government\n18 in April of 2021; do you recall?\n19 A. I don't recall specifically what I said during the phone\n20 call in April, no.\n21 Q. Do you recall defining -- do you define \"nonconsensual\"\n22 as -- when someone says no or the person is too intoxicated to\n23 give consent or the person is below the age of consent,  is that\n24 a definition of \"nonconsensual\"?\n25 A. Those are examples of \"nonconsensual.\" It's not an\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00007281",
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      "content": "1 Q. Did you recall discussing this with Ms. Comey, Ms. Moe,\n2 Ms. Pomerantz, Mr. Rohrbach, and telling them that \"child\" is\n3 anyone below the age of consent?  Do you recall that?\n4 A. I don't have anything on the screen in front of me, so I --\n5 I'm not sure what you're referring to.\n6 Q. I'm just asking if you recall that at this point.\n7 A. No. Sorry. I don't.\n8 Q. OK. Do you have any reason to believe that any of those\n9 AUSAs would take that down incorrectly?\n10 A. I'm not sure of the context under which it was taken.  I\n11 think, you know, for -- I haven't reviewed it. I didn't have a\n12 chance to correct it. I, I really have no idea.\n13 Q. OK. Also, you used the term \"sexual abuse,\" and that's\n14 nonconsensual sexual touch. Is that correct?\n15 A. That is one of the definitions, yes. It doesn't have to\n16 be.\n17 Q. Well, is that the definition that you gave the government\n18 in April of 2021; do you recall?\n19 A. I don't recall specifically what I said during the phone\n20 call in April, no.\n21 Q. Do you recall defining -- do you define \"nonconsensual\"\n22 as -- when someone says no or the person is too intoxicated to\n23 give consent or the person is below the age of consent,  is that\n24 a definition of \"nonconsensual\"?\n25 A. Those are examples of \"nonconsensual.\" It's not an",
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