@driftdiver
How would I answer? I would definitively know whether I had sent a photo of my sex organ and I would be able to answer accordingly. Wouldn't you?
@CatherineofAragon As I pointed out before, there are several reasons why one could not definitively know.
I have ordered things online in the middle of the night without remembering it.
When I used Ambien, I never realized that I did anything but sleep, until I shared a hotel room with someone who told me I got up on my bed in the middle of the night and pretended I was riding a motorcycle. Many people report sending text messages in the night.
20 years ago, I knew a sexual trauma victim with what used to be called "Multiple Personality Disorder" (MPD), but is now known as "Dissociative Identity Disorder" (DID). She would shift between personalities under stress, and her "normal" personality wasn't aware of what her other ones had done (amnesia). Even polygraph tests don't pick this up.
I think most of us have probably known of people who drink or do drugs and don't recall all that they've done under the influence.
Finally, that could be the lawyer talking. It's common, if I'm not mistaken, to use that phrasing just in case you don't remember something and it can be used against you ("You claimed you'd never . . .") like with Mark Fuhrman in the OJ case. If you state you don't recall, then you don't have to worry about goofing up a detail and have it come back.