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Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 71 of 84 prior to the incident,” or alternatively, if “if a witness gets a good look at the defendant during the course of a crime”); United States v. Reed, No. 11 Cr. 487 (RJS), 2012 WL 2053758, at *5 (S.D.N.Y. June 6, 2012) (noting that a “witness’s familiarity with a suspect may establish that the identification . . . is independently reliable’). This is not a crime in which a victim captures a fleeting glance of the perpetrator. Minor Victim-4 interacted with the defendant personally on multiple occasions between 2001 and 2004. She knew the defendant by name and gave a description. In the totality of the circumstances, it is plain that Minor Victim-4’s identification of the defendant is sufficiently independently reliable to permit the jury to decide its persuasiveness. The defense merely replies, again in conclusory fashion, that Minor Victim-4 (1) never identified the defendant as an abuser, (2) did not have an opportunity to view her during the crime because the defendant was not involved in a crime, (3) never described the defendant, and (4) the time between the abuse and the identification was extraordinarily long. (Def. Mot. 9 at 4). The first three of these points are inaccurate, as set forth above. And the delay in time is untroubling given Minor Victim-4’s contacts with the defendant and consistent references in the intervening time. The defense is free to attempt to argue these points to the jury, but none of these arguments supports a motion to suppress Minor Victim-4’s identification of the defendant. Minor Victim-4 knows who participated in the sexual abuse she experienced, as she has for the decades since it happened. This Court should deny the motion. 70 DOJ-OGR-00006779