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The problem is what is a depiction. All images that portray the same subject matter shot in the session could be part of the same depiction. While it is not clear how they slice it, the requirement to have ONE model release and ONE ID for the entire package of images basically implies that the images are together as a "work".
Model releases and 2257 info tend to be integral. You get both the rights to the images and a statement from the model that they are over 18. To fulfill 2257 you must have the required IDs. The model release is the document that attaches the 2257 items to the photoshoot in question. They are three parts of the same puzzle. When I say model release, for me there is a direct assumption that the model IDs are with it.
Read 75.7 more closely...
Alex
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