|The player has taken a picture of Sander Cohen's corpse|
You can get this one of two ways. During Fort Frolic, once you finish his masterpiece, he comes down the stairs and does a speech, then just stares at the pictures. Save your game and then kill him and take his photo for the achievement, then reload your save.
The other way is to leave him alive and leave Fort Frolic, then later in Olympus Heights when you enter his apartment, kill him and take the photo here.
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