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Case 1:20-cr-00330-PAE Document397 Filed 10/29/21 Page 76 of 84 Fourth, the defendant argues that Government Exhibit 294 is irrelevant. (Def. Mot. 13 at 2-3). Government Exhibit 294 displays a box containing “Twin Torpedos”—sex toys—seized during the search of Epstein’s Palm Beach house. This photograph is corroborative of witness testimony, which is expected to describe the presence of sex toys and that the defendant and Epstein used sex toys during their abuse. Fifth, the defendant argues that Government Exhibit 313 is irrelevant. (Def. Mot. 13 at 2- 3). Government Exhibit 313 is a photograph of the defendant and Epstein swimming together while nude. This evidence corroborates witness testimony expected at trial, which will describe topless swimming in the pool at Epstein’s Palm Beach House. It is also relevant to the relationship between the defendant and Epstein. For instance, to the extent the defense at trial argues that the defendant was merely an employee of Epstein’s, this photograph is evidence to the contrary. Sixth, the defense argues that Government Exhibit 606 lacks evidentiary foundation, is hearsay, and is irrelevant because it was created after the events alleged in the Indictment. (Def. Mot. 13 at 2-3). Government Exhibit 606 is a manual governing the operations of the Palm Beach house. A witness at trial is expected to authenticate this document and explain that it was the version in effect at the house in 2005. Another witness is expected to testify about the rules in effect in the Palm Beach household during the time period of the charged conduct; those rules are 75 DOJ-OGR-00005859