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Oo oa .S wo 1) 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 143 of 223 142 the witness has posted on Facebook in a way that's publically available not only the photo of her house, the exact street address. She posted her children up on Facebook. I didn't inject those children into this case, I don't plan to, but there's no basis when a witness has made a Facebook page profile available to the world to say that I'm supposed to collect copies of something that's on the Internet and seal them. That's not my obligation and I think that is inappropriate, and this is something that the witness has put out there that is inconsistent with the testimony. MS. MCCAWLEY: I want to make clear, the date on that is November of 2013. She has received threats to her safety since that date. So it is inappropriate to put her address on the record or anything with respect to her children. MS. BORJA: I did not read her address into the record. MR. SCAROLA: May I make a suggestion? I understand the point that is attempted to be made with regard to the relevancy of these matters, and the relevancy is the suggestion that posting pictures of her children and her address would CONFIDENTIAL