EXIF Data Written Over, Under, Sideways Down on FBI Forensic Examiner Booth Testimony — But Is It Really Hard to Change?

To Alanzo:

“They [OSA] will also be contacting Frank and some other commenters here back-channel, feeding them “dead agent” (discrediting) material on me to make them think they have the ‘lowdown’ on Alanzo”
(Alanzo)

Alanzo, I took this quote from one of your last comments. Clearly, you are suffering from PTSD. OSA is not harassing you. I made comments directed at you because you are an asshole. I made a few of those comments with a couple of aliases. I most certainly did not make all the comments.

I am letting you know a few of the comments came from because you are being paranoid and likely suffering from PTSD. I guarantee the other comments are from other FrankReport regular commenters.

Alanzo, no one at Frank Report is working with OSA. It’s very simple, you act like an asshole so people treat you like an asshole.

You have been out of Scientology for over 21 years! Unlike Rathborn, Rinder, etc — you are not mentioned on any Scientology website.

Scientology sent Frank a message a while back, and Frank published it on this website. Frank doesn’t give a shit what they say and neither does anyone else. The Frank Report is a news blog, not a social club.

Important Fact:

Alanzo — you, Shadow, myself and a bunch of other guys on the Frank Report — are a bunch of middle-age schmucks with too much free time, posting nonsense on Frank’s website.

My point is no one is out to get you! No BackChannels, but after you mentioned BackChannels, I’m sure Shadowstate will be in contact with you. That’s your problem. 😉

Lastly, I’m still gonna treat you like an asshole because you are an asshole. 😉

Changing EXIF data is as easy as photoshopping an image which according to the experts who have certified Suneel’s findings, the FBI also did. Sounds like they photoshopped Camis scar.

Warning! Don’t get sick in New York State!

New Opportunity for Doctor Brandon Porter to return to New York and practice medicine!

New York State’s Nazi Governor Kathy Hochul plans to fire over 70,000 medical workers because they refuse Anthony Fauci’s bogus vaccine.
Why do they refuse the “Kill Shot”?
Because many medical workers know Fauci’s history of promoting vaccines that fail to protect the recipient from disease.
Can you say “AZT caused AIDS”?

So New York’s Nazi Governor will fire over 70,000 medical workers and replace them with National Guard troops, retired workers, unlicensed foreign workers, and former medical workers who lost their licenses as a result of disciplinary action.

Here’s your opportunity for a comeback, Doctor Brandon Porter!
Kathy Hochul vs. NY Nurses

Answer:
Many commentators are probably wondering; how did Alonzo arrive on the Frank Report?

Oddly enough, we have Sultan of Six to thank. Sultan and Alonzo crossed paths on Twitter….

…And as usual, when two lunatics collide on Twitter, a battle of the minds ensued.

Sultan, to his credit, is a cult hater and as we all know, Alonzo is a cult-sycophant… At some point during their debate, Sultan cited the Frank Report, Alanzo then did a Google search, and as the cliché goes, “The rest – as they say is history.”

Somewhere out there, Sultan of Six is laughing his ass-off, because he finally got his sweet revenge on the Frank Report. Sultan released Alonzo on us!

*Please Note: Sultan follows tautologically and Alanzo adheres to Torquemada, and I believe both men make Gary Busey seem sane.

Why does shadowstate1958 hate America?

ROTHMAN, SCHNEIDER, SOLOWAY & STERN, LLP
Attorneys at Law
100 Lafayette Street, Suite 501 New York, NY 10013
Franklin A. Rothman Jeremy Schneider
Robert A. Soloway David Stern

Rachel Perillo
Tel: (212) 571-5500
Fax: (212) 571-5507

BY ECF

Hon. Nicholas G. Garaufis United States District Court Eastern District of New York 225 Cadman Plaza East Brooklyn, New York 11201
September 27, 2021

Re: United States v. Nancy Salzman Ind No.: 18 Cr. 204 (NGG)

Dear Judge Garaufis:

I am one of the attorneys for Nancy Salzman in the above referenced matter. I write in response to the Court’s order of September 20, 2021 which directs the defendant to explain her legal justification for redacting sections of her sentencing memorandum, as well as the entirety of her exhibits which are comprised of supporting letters (exhibits A, B, C, and G) and medical information (exhibits D, E, and F).

Generally, the defense redactions are based upon the privacy rights of the innocent third parties who have come forward to support Ms. Salzman, but who wish their support to remain outside the public domain to prevent injury to their commercial interests and livelihoods, and to also avoid vexatious publicity and public scorn if their statements become public. We seek to maintain the sealing of both the content of the letters submitted, and the identities of the authors. Should the Court, however, deny our application for complete redaction of the exhibits, we submit under cover of a separate sealed letter to be filed contemporaneously with the instant filing, as Exhibit 1, redacted versions of each supporting letter with highlighting to enable the Court to visualize those sections we seek to redact for the purpose only of protecting the identity of each writer, if not the content. Exhibit G to our submission we respectfully submit should remain entirely under seal, because any portion of its content will reveal the identity of the letter writer.

In support of continued sealing, we rely upon judicial principles which endorse the protection of privacy rights of innocent third parties who came forward in support of Ms. Salzman, but who would suffer avoidable injury were their statements and identities revealed. Founded on such
principles, we urge that the three categories of letters presented — family members, close friends, and Nxivm associates — are all subject to complete sealing.

Applicable Law

The Supreme Court has recognized “a general right to inspect and copy public records and documents, including judicial records and documents.” Nixon v. Warner Communications, Inc., 435
U.S. 589 (1978). And we do not dispute that Ms. Salzman’s sentence submission is a judicial document presumptively “subject to public inspection.” United States v. Amodeo, 71 F.3d 1044, 1046 (2d Cir. 1995). The Second Circuit has noted, however, that, “[c]ourts have given various descriptions of the weight to be given to the presumption of access, ranging from an especially strong presumption requiring extraordinary circumstances to justify restrictions, to merely one of the interests that may bow before good reasons to deny the requested access.” Amodeo, 71 F.3d at 1046 [internal citations and quotation marks omitted].

In Amodeo, supra, a factually and procedurally complex matter, the Second Circuit considered a request by the press to review a report completed in connection with a judicial proceeding. The report was not issued in the context of a criminal proceeding, but the general rules for determination of when access to judicial records should be granted or denied furnish guidance here, and they counsel against release of the currently sealed portions of Ms. Salzman’s sentencing memorandum. Such portions relate personal medical information of the defendant and others, and summarize some content of the letters submitted by supporters, as well as identifying them by name.

The submission’s purpose was to assist the Court in determining the appropriate sentence to impose pursuant to 18 U.S.C. § 3553(a). As noted, supporters of Ms. Salzman, if their support is made public, will likely suffer injury. A criminal defendant facing sentencing should not be placed in the position of having to choose between providing the sentencing court with less than complete information about relevant sentencing factors, or forfeiting the important privacy rights of innocent third parties who desire to provide the Court with information in their possession about the defendant’s history and characteristics:

In determining the weight to be accorded an assertion of a right of privacy, courts should first consider the degree to which the subject matter is traditionally considered private rather than public. Financial records of a wholly owned business, family affairs, illnesses, embarrassing conduct with no public ramifications, and similar matters will weigh more heavily against access than conduct affecting a substantial portion of the public.
Id. at 1051.
As to Ms. Salzman’s privacy rights in her own medical conditions, this is information traditionally considered private. While her need for medical care has been publically discussed in general as a § 3553 factor, medical details have been kept private through redaction. Such details in no way affect any portion of the public, much less a substantial portion. Some indication of

2
society’s traditional respect for personal privacy in one’s medical records is evidenced by the HIPPA laws, which require the explicit permission of the patient before his or her medical records can be revealed. The same interests are invoked by Ms. Salzman on behalf of the third parties whose medical conditions have been liberally discussed in her sentencing submission, including particularly her close family members.
Regarding the fully redacted letters presented in Ms. Salzman’s filed submission, they should remain as submitted and fully protected from the public. The Second Circuit has held that “[t]he privacy interests of innocent third parties … should weigh heavily in a court’s balancing equation.” Application of Newsday, Inc., 895 F.2d 74, 79–80 (2d Cir. 1990) (quoting, United States v. Biaggi, 828 F.2d 110, 116 (2d Cir.1987), cert. denied, 485 U.S. 977 (1988). Such interests, while not always fitting comfortably under the rubric “privacy,” are a common law exception to the presumption of access. Courts have long declined to allow unlimited public access to public records. Indeed venerable rules pronounce long-recognized limitations:

[I]t is clearly within the rule to hold that no one has a right to examine or obtain copies of public records from mere curiosity, or for the purpose of creating public scandal. To publish broadcast the painful, and sometimes disgusting, details of a divorce case, not only fails to serve any useful purpose in the community, but, on the other hand, directly tends to the demoralization and corruption thereof, by catering to a morbid craving for that which is sensational and impure. The judicial records of the state should always be accessible to the people for all proper purposes, under reasonable restrictions as to the time and mode of examining the same; but they should not be used to gratify private spite or promote public scandal. And, in the absence of any statute regulating this matter, there can be no doubt as to the power of the court to prevent such improper use of its records.

In re Caswell’s Request, 18 R.I. 835, 29 A. 259 (1893).

In this case, many of those who wrote letters on behalf of Ms. Salzman did so fearfully, not because of any reluctance whatsoever to support her, but because of the scandalous, hurtful uses to which their sentiments, if made public, would likely be put. As this Court is aware, the Frank Report weaponizes statements made in support of the Nxivm defendants, and exists for virtually no purpose other than to damage the reputation and fortunes of remaining “loyalists.” Revealing the identities and supportive views memorialized in letters to the Court will add little to the record that has not already been stated publicly by the Court and counsel, and will potentially result in harm to those whose aim was to furnish the Court with firsthand information about Ms. Salzman to facilitate a fully informed sentencing proceeding.

Revealing the content of the letters and names of such individuals will likely have a chilling effect on those who wish to assist other defendants and courts in future high-profile cases.

CONCLUSION

For all of the foregoing reasons, it is respectfully requested that the redactions now in place with respect to the defense sentencing submission and exhibits remain as they are at this time, and that no public disclosures other than those already made be ordered by this Honorable Court.

Sincerely,

Robert A. Soloway

Robert A. Soloway
cc: AUSA Tanya Hajjar (by ECF)
RAS:sc

EXIF data being very hard to change is COMPLETE B.S. I’m not a computer expert but a digital photography enthusiast and I changed the EXIF data all the time on my pictures so that my competitors (in online photography contests etc) couldn’t look at the EXIF data to see exactly what my secret special sauce of camera settings/time of day, etc, was for the specific images I captured. Also I know for a fact that people change the EXIF data on photos so that other people won’t know how old that dating profile picture of them really is etc. It’s easy to do. Or at least it was back when I was heavily involved in the online digital photography community and everyone was doing it. Changing the EXIF data never did anything to corrupt any image files of mine that I’m aware of.

I understand why Suneel is pointing this out because obviously the child porn accusation was extremely prejudicial to Raniere’s case. Why would someone lie to say it’s very hard to change? Or maybe they were just innocently mistaken, although that seems unlikely. Raniere’s lawyer should have known it was B.S. Maybe he didn’t point it out because he didn’t want to spend any more time than necessary on the child porn issue since it’s such a horrendous accusation he figured it’s just better to move along “nothing to see here” as quickly as possible. ?

Okay, Frank, I know you like to be provocative and play Devil’s advocate. But here you’re getting into misrepresentation and deception.

You’re deliberately confusing “removing” with “altering” EXIF data. As I’ve pointed out in previous comments, standard photo editing software used by millions of photographers lets you selectively delete EXIF data. There are legitimate reasons for doing this, mainly privacy.

Altering EXIF files- inserting fake data- requires downloading special hacking software and is not the kind of thing done by typical photo hobbyists or professionals. It’s like downloading keylogging software to hack into someone else’s computer. Is that easy to do? Depends on your definition of “easy”.

It makes sense that Nxivm loyalists would think hacking and faking EXIF files is simple and ordinary. Look at their attitude toward installing spy software on Edgar Bronfman’s computer. Or hiring shady private detectives to spy on rivals. Look at their moral and ethical standards in general.

Agent Booth testified that it would be difficult for the consumer to alter EXIF data. That EXIF files can be altered but it requires downloading special software. He never claimed it was impossible,

Booth never said it was “incredibly complicated”, as you claim. He said it would involve specialized software (which is true). He said it would be “very hard for the consumer” to modify EXIF data. (Which is true. Standard photo editing software doesn’t let you insert fake data in those fields).

Read carefully what the man actually said.

“Very hard for the consumer” doesn’t mean “impossible for a computer hacker”. (So Suneel’s little demonstration proves nothing).

Of course, if you want to misrepresent Booth’s testimony in order to be provocative, that’s fine, it’s your blog. Your bias is showing though, underscored by the picture you shared of Brian Booth as Pinocchio. Let’s just not pretend that this is any sort of objective inquiry meant to get at the truth.