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Evidence Keyed to Sklansky
United States v. Browne
Citation:
834 F.3d 403 (3d Cir. 2016)Facts
Browne (Appellant) was charged with child pornography and sexual offenses against minors. At trial, the government sought to introduce five Facebook chat logs into evidence. Four of the logs reflected the chats of “Billy Button,” which had been established as Browne’s online chat name, with three minors, and one reflected a chat about Browne’s sexual assault of a minor. Facebook’s records custodian certified that the logs were created and kept by Facebook as part of Facebook’s regular practices. The government argued that the logs were self-authenticating and that normal authentication procedures were not required, and the district court admitted the logs into evidence. Browne was convicted.
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