This amicus brief was written to support Plaintiff’s writ for mandamus, to receive restitution after Defendant pled guilty to possessing material involving the sexual exploitation of children. Issues include whether sexual abuse, its memorialization, distribution, and viewing are psychologically intertwined with and compound the impact of abuse for victims; whether pornography is a common element of grooming; whether child sex victims typically experience long-term harm and need lifelong care; and whether child pornography victims experience exacerbated negative effects. The final opinion is Paroline v. United States, 572 U.S. 434 (2014).