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Case 1:20-cr-00330-PAE Document523 Filed 12/04/21 Page2of9
....”’). The “standard of relevance established by the Federal Rules of Evidence is not high.”
United States v. Southland Corp., 760 F.2d 1366, 1375 (2d Cir. 1985) (Friendly, J.) (internal
quotation marks omitted). A district court’s “evidentiary rulings” are reviewed on appeal “under
a deferential abuse of discretion standard,” and are disturbed only if “manifestly erroneous.”
United States v. Skelos, 988 F.3d 645, 662 (2d Cir. 2021) (internal quotation marks omitted).
“TA] suggestion that an item of evidence relates to a period that is too remote goes to both
the item’s relevance and its weight.” United States v. Certified Env. Services, Inc., 753 F.3d 72,
90 (2d Cir. 2014) (internal quotation marks omitted.). But evidence of continuity between the time
of the consequential fact and the time of the proffered evidence supports a finding of relevance.
See, e.g., id. (evidence that predated the charged conspiracy by five years relevant because it
concemed “a pattern of activity that continued up to the time of the charged conduct,” and evidence
that postdated acts charged in the indictment provided evidence “of a longstanding continuous
mental process” (internal quotation marks omitted)); United States v. Roux, 715 F.3d 1019, 1027
(7th Cir. 2013) (rejecting a relevance challenge to prior acts evidence because they “were offered
to establish Roux’s sexual interest in minors, a proclivity that . . . is unlikely to vanish with the
passage of time”). And evidence that corroborates earlier evidence is “admissible for the same
reasons.” Certified Env. Servs., 753 F.3d at 91 (“[B]ecause the 2009 guidance document
memorialized the 2006 email exchange, it served to corroborate that evidence, and therefore was
admissible for the same reasons.’’).
Il. Discussion
Certain photographs in the 900 series are strongly corroborative of specific statements
made by Jane. In defense counsel’s words, Jane’s recollection “of everything . . . is critical to the
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Dates
Document Details
| Filename | DOJ-OGR-00008215.jpg |
| File Size | 698.6 KB |
| OCR Confidence | 93.8% |
| Has Readable Text | Yes |
| Text Length | 2,052 characters |
| Indexed | 2026-02-03 17:32:38.423341 |