mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00007983.json

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    "page_number": "115",
    "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 115 of 159\nLBAGmax4 Rocchio - Cross\n1 Q. And is that your definition?\n2 A. It's my understanding of the definitions that have been talked about in the literature. I mean, I haven't written and published a specific set definition. It's a common definition and the one I'm using in my testimony, yes.\n3 Q. I was going to ask you that question. You have not published anything specifically about grooming; correct?\n4 A. Specifically about grooming, no. But I have certainly published made reference to grooming.\n5 Q. And you have not done any metadata studies on your own to collect data about grooming; correct?\n6 A. Correct.\n7 Q. Grooming can consist of the actions that you're talking about, can consist of -- I think we saw a list of 77 things on it as part of your testimony; is that right?\n8 A. Those were 77 specific behaviors that had been identified in the literature as potentially being part of the grooming process, yes.\n9 Q. But I think we were talking about things like taking an interest in and of itself. It would depend on the pattern of behavior and the context in which it's occurring.\n10 A. Not in and of itself. It would depend on the pattern of behavior and the context in which it's occurring.\n11 Q. Let's talk about that for a second. Because what you're saying is, it depends on the groomer's intent in doing a specific act is what, in your view, makes it grooming or not\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00007983",
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      "content": "Case 1:20-cr-00330-PAE Document 499-2 Filed 11/23/21 Page 115 of 159",
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      "content": "LBAGmax4 Rocchio - Cross",
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      "content": "1 Q. And is that your definition?\n2 A. It's my understanding of the definitions that have been talked about in the literature. I mean, I haven't written and published a specific set definition. It's a common definition and the one I'm using in my testimony, yes.\n3 Q. I was going to ask you that question. You have not published anything specifically about grooming; correct?\n4 A. Specifically about grooming, no. But I have certainly published made reference to grooming.\n5 Q. And you have not done any metadata studies on your own to collect data about grooming; correct?\n6 A. Correct.\n7 Q. Grooming can consist of the actions that you're talking about, can consist of -- I think we saw a list of 77 things on it as part of your testimony; is that right?\n8 A. Those were 77 specific behaviors that had been identified in the literature as potentially being part of the grooming process, yes.\n9 Q. But I think we were talking about things like taking an interest in and of itself. It would depend on the pattern of behavior and the context in which it's occurring.\n10 A. Not in and of itself. It would depend on the pattern of behavior and the context in which it's occurring.\n11 Q. Let's talk about that for a second. Because what you're saying is, it depends on the groomer's intent in doing a specific act is what, in your view, makes it grooming or not",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00007983",
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