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- "full_text": "Case 1:20-cr-00330-PAE Document 747 Filed 08/10/22 Page 72 of 228 LC2VMAX2 Rocchio - Direct for the Court because we think that such questions would be inappropriate on cross-examination. THE COURT: So beyond the scope. MS. POMERANTZ: Yes, your Honor. MR. PAGLIUCA: Would you like me to respond, your Honor? THE COURT: Please. MR. PAGLIUCA: So I guess first with regard to the memory issue, Dr. Rocchio talked about delayed disclosure and memory impacts delayed disclosure. And it's not as simple to say that there are only a couple of reasons why disclosure is delayed. I mean they can say, Well, there are these factors that result -- THE COURT: So is the cross -- Dr. Rocchio, you talked about delayed disclosure. Are there other reasons? MR. PAGLIUCA: Exactly. THE COURT: And then what? MR. PAGLIUCA: Well, like memory and things like confabulation and the process of storing memories and retrieving memories, the effect of alcohol on memories. Those are the kinds of things that would impact memory and, therefore, delayed disclosure, which I think are fair game on cross-examination; psychological conditions that may impact delayed disclosure is fair game on cross-examination. So those are some of the topics. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00012357",
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- "content": "for the Court because we think that such questions would be inappropriate on cross-examination. THE COURT: So beyond the scope. MS. POMERANTZ: Yes, your Honor. MR. PAGLIUCA: Would you like me to respond, your Honor? THE COURT: Please. MR. PAGLIUCA: So I guess first with regard to the memory issue, Dr. Rocchio talked about delayed disclosure and memory impacts delayed disclosure. And it's not as simple to say that there are only a couple of reasons why disclosure is delayed. I mean they can say, Well, there are these factors that result -- THE COURT: So is the cross -- Dr. Rocchio, you talked about delayed disclosure. Are there other reasons? MR. PAGLIUCA: Exactly. THE COURT: And then what? MR. PAGLIUCA: Well, like memory and things like confabulation and the process of storing memories and retrieving memories, the effect of alcohol on memories. Those are the kinds of things that would impact memory and, therefore, delayed disclosure, which I think are fair game on cross-examination; psychological conditions that may impact delayed disclosure is fair game on cross-examination. So those are some of the topics.",
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