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2021 Supreme(US)(ca8) 336

COURT OF APPEALS FOR THE EIGHTH CIRCUIT
United States – Appellant
Versus
Kevin Lamm – Respondent


No. 20-1128 ___________________________

United States of America

Plaintiff - Appellee

v.

Kevin Allen Lamm, also known as Mike Malone

Defendant - Appellant ____________

Appeal from United States District Court for the District of South Dakota - Sioux Falls ____________

Submitted: November 18, 2020 Filed: July 29, 2021 ____________ Before SHEPHERD, STRAS, and KOBES, Circuit Judges. ____________ KOBES, Circuit Judge.

Kevin Lamm distributed, received, produced, and possessed child pornography using two separate Facebook accounts: one under his name, and the other under the fictitious name Mike Malone. The Government tried to authenticate evidence from Facebook using certified records, but the district court 1 required additional circumstantial evidence tyi

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