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Case 1:20-cr-00330-PAE Document 751 Filed 08/10/22 Page 12 of 261 1152 these photos have both the dog and tos taken in 2019 the dog and tiger are highly Fairly prejudicial because LC6Cmaxl 1 massagers to which Jane testified. In short, 2 little, if any, relevance and they're likely prejudicial 3 because they are likely to confuse the jury. 4 The four sets of photos that the government seeks to a admit, photos 936 and 938, depict a room with a stuffed tiger 6 and a stuffed dog. The government argues that these photos 7 corroborate Jane's testimony that Epstein's apartment 8 contained, quote, creepy-looking animals and animal heads and 9 strange things. Trial transcript at 305 to 318. 10 [ will exclude these photos, first, 11 tiger are moveable items such that the pho 12 are, without additional testimony, not probative of what Jane 13 would have seen years earlier. Second, though Jane described 14 artwork of animals, she did not describe a stuffed dog or 15 tiger. The photos therefore have little corroborative value, 16 even if, as the government argues, 17 idiosyncratic. And the photos are uni 18 they're likely to confuse the jury by suggesting that these 19 same items were in Epstein's apartment at the time that Jane 20 was there. Further, the idiosyncratic nature of the items is 2] likely to distract the jury, it could delay trial as the 22 connection to Jane's testimony is tenuous at best. 23 IT'll note that, as I've said, the schoolgirl outfits 24 found in the New York apartment in 2019 that the government 25 intends to introduce, as said on Friday, SOUTHERN D STR CT REPORT ERS, (212) 805-0300 2) anticipate these DOJ-OGR-00012763