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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 499-2 Filed 11/23/21 Page 103 of 159102 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. the context under which it was taken. [ haven't reviewed it. I you used the term "sexual ab Is that correct didn't have a , really have no idea. use," and that's LE? t doesn't have to the government during the phone "nonconsensual" too intoxicated to is that consent, It's not an A. That is one of the definitions, yes. I be. Q. Well, is that the definition that you gav in April of 2021; do you recall? A. I don't recall specifically what 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 a definition of "nonconsensual"? A. Those are examples of "nonconsensual." SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007971