DOJ-OGR-00014978.jpg

a No Go wd on OY ~] (ee) Ke) a © a a No (ee) = ws On a OY a ~] a co a Ke) 20 21 22 ae 24 ae Case 1:20-cr-00330-PAE LBAAMAX3ps 1O Ms. anyone below the age of! A. Le) A. Q. AUSAsS would take that Document 782 Pomerantz, Mr. Rohrbach, Rocchio - Cross Did you recall discussing this with Ms. I don't have anything on the screen in I'm just asking if Filed 01/15/25 Page 102 of 158 102 Comey, Ms. Moe, and telling them that "child" is F consent? Do you recall that? I'm not sure what you're referring to. front of me, so I -- you recall that at this point. No. Sorry. I don't. OK. Do you have any reason to believe that any of those t down incorrectly? A. I'm not sure of the context under which it was taken. think, you know, for -- I haven't reviewed it. I didn't have a chance to correct it. 7 really have no idea. Q. OK. Also, you used the term "sexual abuse," and that's nonconsensual sexual touch. Is that correct? A. That is one of the definitions, yes. It doesn't have to be. Q. Well, is that the definition that you gave the government in April of 2021; do you recall? during the phone "nonconsensual" too intoxicated to A. I don't recall specifically what I said call in April, no. Q. Do you recall defining -- do you define as -- when someone says no or the person is give consent or the person is below the age of consent, is that a definition of "nonconsensual"? A. Those are examples of "nonconsensual." SOUTHERN DISTRICT REPORTERS, (212) 805-0300 It's not an DOJ-OGR-00014978