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Hello,
These parts of your statement I would question...
Tits and ass shots are ok. "Lewd exhibition of the genitals" is also ok, this does not fall under the definition of sexually explicit conduct as defined in 18 USC section 2257.
Basically what this means is that a close up pussy shot is fine, as long as the model is not touching her pussy with her hand or a sex toy (and no other person is touching her).
Just my 2 cents...
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