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Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page13 of 52 "In assessing whether a district court properly admitted other act evidence, we consider whether (1) it was offered for a proper purpose; (2) it was relevant to a material issue in dispute; (3) its probative value is substantially outweighed by its prejudicial effect; and (4) the trial court gave an appropriate limiting instruction to the jury if so requested by the defendant.” United States v. Arroyo, 600 F. App'x 11, 13 (2d Cir. 2015) (summary order) (quoting United States v. LaF lam, 369 F.3d 153, 156 (2d Cir. 2004). [I are offered for improper purposes, L.c., propensity, are not relevant to any material issue in dispute and their probative value is substantially outweighed by their prejudicial effect. A. —EEE Bear No Relationship to the Charged Conspiracy, Reflect Pure Propensity Evidence, and Otherwise are Unduly Prejudicial Se The government's argument for admissibility of jg J is breathtaking in its claims and unsupported by admissible evidence. Without expert testimony or even bothering to intervicw i. the government contends ggg represent "direct evidence" of a conspiracy (to recruit, groom, and sexually abuse minor females or to entice, transport or traffic them for Jeffrey Epstein's sexual pleasure) that Resp. at 36. * The proffered evidence is found at GX 401-404, 409-410 and 413 fF DOJ-OGR- 00005968