I have a child porn case and need to draw up the indictment. How do you describe the images that are being indicted? I have in the past just used the file name of the images - but now I have images with the same file names but on different media. (Ex. 001.jpg on tower computer and a 001.jpg on cd and the images are different) My instinct is to describe them by file name and media but am I getting too specific? Any help appreciated.

[This message was edited by Pelikan on 11-02-10 at .]

I have included a brief description of the image or movie in the indictment counts. I think that it helps to read the description to the jury. Even a very general description of a CP image usually sounds very bad when read to a jury.

Here's an example from one of my cases:
"on or about the [date], in [your] County, Texas, [Defendant's Name], hereinafter �defendant�, intentionally or knowingly possessed visual material, namely, a physical medium that allows an image to be displayed on a computer or other video screen or any image transmitted to a computer or other video screen by telephone line, cable, satellite transmission, or other method, that visually depicted, and which the defendant knew visually depicted, a child who was younger than 18 years of age at the time the image of the child was made, engaging in sexual conduct, namely, a video named �4YoBoyMathew.avi� showing a male child involved in actual or simulated deviate sexual intercourse or lewd exhibition of the genitals."

This was one of 30 counts. If it's a photo, it would say photo rather than video. If it's 2 children, I'd say so, and if it's a child and an adult, I'd say that.