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Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 39 of 84
conduct between adults! only highlights that this evidence does “not involve conduct any more
sensational or disturbing than the crimes with which [the defendant] was charged,” which weighs
in favor of admitting these exhibits under Rule 404(b)(2). United States v. Roldan-Zapata, 916
F.2d 795, 804 (2d Cir. 1990).
b. Testimony of Employee-1
Employee-1 worked as a personal assistant for Epstein for approximately (tid
a. (October 11, 2021 Letter, Def. Mot. 2 Ex. A at 1). During that time, Employee-1
reported directly to another employee (“Employee-2”), who worked for Epstein during the
timeframe of the charged conspiracy, and who is referenced in the Second Superseding Indictment
(the Indictment”). (ECF No. 187, 4{ 6, 7(b)). The Government expects that Employee-1 will
testify about Employee-1’s observations of the close relationship between the defendant and
Epstein. Indeed, Employee-1 will testify that Employee-1 worked out of the defendant’s
townhouse in Manhattan during the weeks that Employee-1 worked in New York City. The
Government also expects Employee-1 to testify about her observations at Epstein’s properties,
including observations of minor girls at the properties, as well as her knowledge of Epstein’s
practice to arrange multiple sexualized massages per day. In addition, although Employee-1’s
employment post-dates the defendant’s conduct with the victims in this case, Employee-1 became
familiar with certain items in Epstein’s residences during her tenure there, and thus Employee-1
will authenticate certain exhibits relating to the Minor Victims. Finally, the Government expects
‘0 On this point, the Government notes that the exhibits do not specify the ages of the individuals
involved.
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Document Details
| Filename | DOJ-OGR-00006747.jpg |
| File Size | 642.8 KB |
| OCR Confidence | 93.2% |
| Has Readable Text | Yes |
| Text Length | 1,813 characters |
| Indexed | 2026-02-03 17:14:00.724180 |