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    "page_number": "253",
    "document_number": "751",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 751 Filed 08/10/22 Page 253 of 261 1414 LC6Cmax7 Meder - direct exists. And I also would like to say with respect to 309, we litigated whether or not we could put in evidence photographs of this witness, and the government called us, I think it was slut shaming when I tried to argue that there were other photographs of this individual that were much like this that she had put out in newspapers, and now they want to put on a photo of her after she's gotten off the stand and not afforded us the opportunity to cross examine her about similar photographs that she has put out. MS. MODE: Your Honor, I'm surprised by all three of those arguments. THE COURT: Let's start with 332. Is the government's representation that the individual depicted in this photo is a minor at the time of the photo? MS. MODE: Your Honor, we made no representations about the metadata of the file of this photo. To be short, in direct, I don't know. There will be testimony at this trial and there has been testimony at this trial that this person was victimized as a minor. In terms of the particular date of this photograph, we're limited by the information we have in the metadata. I believe it's for this reason that the defense had noticed perhaps a metadata expert and the defense will be free to explore that issue. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00013004",
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      "content": "exists. And I also would like to say with respect to 309, we litigated whether or not we could put in evidence photographs of this witness, and the government called us, I think it was slut shaming when I tried to argue that there were other photographs of this individual that were much like this that she had put out in newspapers, and now they want to put on a photo of her after she's gotten off the stand and not afforded us the opportunity to cross examine her about similar photographs that she has put out.",
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      "type": "printed",
      "content": "MS. MODE: Your Honor, I'm surprised by all three of those arguments.",
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    {
      "type": "printed",
      "content": "THE COURT: Let's start with 332. Is the government's representation that the individual depicted in this photo is a minor at the time of the photo?",
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    {
      "type": "printed",
      "content": "MS. MODE: Your Honor, we made no representations about the metadata of the file of this photo. To be short, in direct, I don't know. There will be testimony at this trial and there has been testimony at this trial that this person was victimized as a minor. In terms of the particular date of this photograph, we're limited by the information we have in the metadata. I believe it's for this reason that the defense had noticed perhaps a metadata expert and the defense will be free to explore that issue.",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00013004",
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
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      "1:20-cr-00330-PAE",
      "751",
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