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Case 1:20-cr-00330-PAE Document 499-2 Filed 11/23/21 Page 102 of 159101 LBAAMAX3ps Rocchio - Cross 1 for testimony. 2 THE COURT: You can submit authority on that. I mean, 3 certainly appropriate grounds for cross. I'm not sure, absent 4 some specific motion for discovery, that I'v ver seen expert 5) time records turned over. 6 MR. PAGLIUCA: Understood, your Honor. / BY MR. PAGLIUCA: 8 Q. Dr. Rocchio, I'd like to talk to you about some of the 9 terms that you've been using here today. The first one I want 10 to ask you about is the definition of "child." Do you recall, 11 when you discussed this case with the government on April 9th 12 of this year, that you defined "child" for the government as 13 someone under the age of consent? Do you recall that? 14 A. I don't specifically recall that, no, I'm sorry. 15 On Is that a definition of "child," someone under the age of 16 consent? 17 A. I would -- I would define "child" as someone under the ag 18 of 18. 19 Q. Well, I'm looking at page 3 of the interview notes produced 20 in connection with your interview on April 9, 2021. 21 THE COURT: Do you have a 3500? 22 MR. PAGLIUCA: I do, your Honor. I'm at page 23 3502-004. That's the beginning of this interview, April 9, 24 2021. And if we go to -- well, that's the page 3 of that 25 interview. The top of the page. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007970