DOJ-OGR-00007288.pdf

--- Page 1 --- **Case 1:20-cr-00330-PAE** * **Document 467** * **Filed 11/15/21** * **Page 109 of 158** * **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?** * A. 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? * A. Yes. * Q. It could include people who have two parents but one of them is abusive; right? * A. Yes. * Q. It could include people who have cognitive disabilities; correct? * A. Yes. * Q. It could include people who have emotional disabilities; correct? * A. Yes. **SOUTHERN DISTRICT REPORTERS, P.C.** * (212) 805-0300 **DOJ-OGR-00007288**