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be NO Ww ws Oo OY ~] oO Ke} 20 21 22 23 24 25 Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 102 of 158102 LBAAMAX3ps Rocchio - Cross Q. Did you recall discussing this with Ms. Comey, Ms. Moe, Ms. Pomerantz, Mr. Rohrbach, and telling them that "child" is anyone below the age of consent? Do you recall that? A. I don't have anything on the screen in front of me, so I -- I'm not sure what you're referring to. Q. I'm just asking if you recall that at this point. A. No. Sorry. I don't. Q. OK. Do you have any reason to believe that any of those AUSAs would take that down incorrectly? A, I'm not sure of for think, you know, chance to correct it. QO. OK. Also, nonconsensual sexual touch. [ haven't reviewed it. I you used the term "sexual ab Is that correct the context under which it was taken. , really have no idea. LE? didn't have a use," and that's 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? A. I don't recall specifically what said during the phone call in April, no. Q. Do you recall defining -- do you define "nonconsensual" as -- when someone says no or the person is too intoxicated to give consent or the person is below the age of consent, is that a definition of "nonconsensual"? A. Those are examples of "nonconsensual." It's not an SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007281