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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 Document 782 Filed 01/15/25 Page 109 of 158109 LBAGmax4 Rocchio - Cross BY MR. PAGLIUCA: Q. I want to talk a little bit about some of the opinions that are in your letter from the government of April 23rd, 2021. So I think the first opinion that I have identified relates to individuals with particular vulnerabilities are often targeted by perpetrators of sexual abuse. Do you recall that? > I do. Q. So let's identify some of the categories of people that have particular vulnerabilities. So that could include economically and disadvantaged people; right? A. Yes. Q. That would include people who don't have any family at all; correct? A. It could, sure. Q. It could include people who have one parent; correct? > Yes. Q. It could include people who have two parents but one of them is abusive; right? > Yes. Q. It could include people who have cognitive disabilities; correct? > Yes. Q. It could include people who have emotional disabilities; SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014985