I have prosecuted several child pornographers in my career, but I'm presented with a difficult situation in my newest case. Among other things, the defendant had in his possession two dozen Polaroids of my victim that he snapped himself. I like charging these quys with everything under the sun. So I'm charging him with promotion of child porn, and I want a separate count for each photo. Normally I achieve that by including a brief description of the individual photos. In this case, however, the photos, for the most part, are all quite similar. Any suggestions as to how I can distinguish the counts?

We've batted some ideas around the office, like including the photo with the indictment, or referencing the photos as individual Grand Jury exhibits. But all of our ideas result in either the production of child porn by our office, or they place the photos in the public realm (directly or indirectly) or both.

I'd appreciate any help.

Thanks.

Did Frank and I start you on this path all those years ago. Still stuck reviewing dirty pictures. Alas.

Each photo can get its own count. I would reference them and attach a sealed attachment to the indictment. Absoluely no authority under Texas Law to do so, but I can't imagine a better case to make law on sealing issues.

Well, well, well . . . seems my pervert left me a surprise. He numbered the Polaroids on the back. Nothing like a little old fashioned investigation - i.e., actually examining the evidence - to kick start a case. :-)

Clay, at least the moniker of "Porn Boy" didn't follow me out of Lubbock.

We would have to work so much harder if they weren't so DUUUUUUUMB