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Case 1:20-cr-00330-PAE Document 751 Filed 08/10/22 Page 253 of 261
LC6Cmax7
Meder - direct
1414
1 exists.
2 And I also would like to say with respect to 309, we
3 litigated whether or not we could put in evidence photographs
4 of this witness, and the government called us, I think it was
5 slut shaming when I tried to argue that there were other
6 photographs of this individual that were much like this that
7 she had put out in newspapers, and now they want to put on a
8 photo of her after she's gotten off the stand and not afforded
9 us the opportunity to cross examine her about similar
10 photographs that she has put out.
11 MS. MOE: Your Honor, I'm surprised by all three of
12 those arguments.
13 THE COURT: Let's start with 332. Is the government's
14 representation that the individual depicted in this photo is a
15 minor at the time of the photo?
16 MS. MOE: Your Honor, we made no representations about
17 the metadata of the file of this photo. To be short, in
18 direct, I don't know. There will be testimony at this trial
19 and there has been testimony at this trial that this person was
20 victimized as a minor.
21 In terms of the particular date of this photograph,
22 we're limited by the information we have in the metadata. I
23 believe it's for this reason that the defense had noticed
24 perhaps a metadata expert and the defense will be free to
25 explore that issue.

SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300

DOJ-OGR-00018590