DOJ-OGR-00018592.jpg
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just made
representat
indications.
representation was that the pictur
THE
MS.
MS. MENN
COURT:
that this person was a minor victim,
Based on the testimony,
00330-PAE Document 751 Filed 08/10/22
Meder direct
date because there ar
MS. MENNINGER: Your Honor
Page 255 of 261
1416
limitations on digital
, the representation was
and
that
tion has been made to this Court on previous
I don't think the
represented her as a minor.
MOE: —-—
NGER:
—-— nature of
the relationship.
think the quote just was between my client and her and
Mr.
Epstein.
establishes any relationship having
client.
Epstein in 2019,
It's something that was in
and it was
when she was above the age of
we're going to put
going to be -- she's not going to
don't want her to testify because
problems.
victim but without having her get
now they want to ge
and no one's going
I think
So they want to put in
the 403 problem looms
t in a photograph of
testify,
she has a lot of
evidence that
There is nothing about this photograph
to do anything with
that
my
the possession of
Jeffrey
taken by any available data
consent.
large
your
Honor.
in 2002
in this case where
someone who there is not
They
on the stand and testify.
to say when that photograph was taken.
credibility
she was a
So
t in evidence that she had a topless photo
The
available evidence on the photo is that it was taken when sh
SOUTHERN D
STR
CT RE
PORTERS, Piss
(212)
805-0300
DOJ-OGR-00018592