DOJ-OGR-00018130.jpg

Case 1:20-cr-00330-PAE Document 749 _ Filed 08/10/22 Page 29 of 236 933 LBUCmax1 1 from the relevant time period in this case. We've already had 2 a lot of testimony about how there were frequent renovations to 3 these places, we had testimony from Juan Alessi about that, and 4 so there is no reason to believe that the interior of this iS) townhouse looked the way it did in 2019, whether it looked the 6 same way in 1994 to 2004, which is the time period of the 7 conspiracy. In fact, quite the opposite. We hav very reason 8 to believe that there were significant changes based on the 9 testimony. 10 So my objection is, your Honor, I don't think, unless 11 they have a witness who can say that these photographs taken in 12 2019 look Like those rooms that I saw back in '94, '95, or 2002 13 or some time period that's actually in the conspiracy, and I 14 don't think they do, then these are irrelevant and they 15 shouldn't be admitted to the jury because there is no basis to 16 believe that this is what the place looked like on the inside 17 back 15 years before. I believe the only witness they have 18 testified so far, and maybe the only one they can offer, is 19 Jane, who testified very, very generally and very briefly about 20 how the New York townhouse looked on the inside. She said 21 something to the effect of, there was old wood, it was dark, 22 there were creepy animal pictures on the wall. That's all we 23 had. I think she said she may have slept on the eighth floor 24 in the guest room, but there certainly wasn't a room-—by-room 25 description of what this place looked like. And my SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018130