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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 113 of 158113 LBAGmax4 Rocchio - Cross literature around which specific vulnerabilities have been found to be associated with which particular outcomes or adverse outcomes. So it's not that every single vulnerability has been found to increase vulnerability for every potential outcome. There's a relationship between particular types of vulnerability and particular types of outcome. Q. It's also true that there can be more than one vulnerability in a human being? A. Of course, yes. Q. One can be a victim of sexual abuse and have other vulnerability factors; correct. > Yes. Q. Or conversely, somebody can have vulnerability factors and then become a victim of sexual abuse; correct? > Yes. Q. I want to turn now to some of your questions about grooming, okay, some of your opinions about grooming. What is your definition of grooming? A. The definition that's commonly used in the literature is -- Q. I didn't ask that question. THE COURT: You may answer. Go ahead. THE WITNESS: The term grooming refers to a set of deceptive strategies that are utilized by an individual to establish a relationship of coercion and control for the purposes of subsequent sexual exploitation and sexual abuse. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014989