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Case 1:20-cr-00330-PAE
LCHVMAX2
there were thousands of photographs
only obviously a subset that was pr
MS. MENNINGER: Right. Ms.
photographs, your Honor, not to the
MS. COMEY: Your Honor,
Document 763 _— Filed 08/10/22
Page 48 of 197 2589
seized, and that there was
esented to the jury.
Meder only was speaking to
number of devices.
[ would note that that was a
Situation where we called a witness
to talk about photographic evidence
the defense properly cross-examined
evidence.
What the defense is now su
to do is bring in a whole host of o
There was Mr. Flatley, who testifie
I believe what
single hard drive.
about is all of the other devices t
this
the course of investigation.
the Court's orde
be in violation of
affirmatively in our case
that was seized; and then
that witness about that
ggesting they should be able
ther investigative steps.
d about extraction from a
Mr. Everdell is talking
hat were seized throughout
And I think that that would
r. It would also be
extremely confusing, because when we're talking about this
investigation, it's a little ambiguous what we're talking
about, as we alluded to earlier. This investigation was
broader than just what resulted in these charges.
MS. MENNINGER: Well, your Honor, there was a search
that the government elicited information about that occurred in
2019 of our alleged co-conspirator's home. The question can be
phrased because they
THE COURT: Which witness was that?
SOUTHERN D
STR
CT RE
PORTERS, Piss
(212) 805-
0300
DOJ-OGR-00014154