DOJ-OGR-00008217.jpg

Case 1:20-cr-00330-PAE Document523 Filed 12/04/21 Page4of9 As depicted in Government Exhibit 928, the massage room in fact has a large built-in bookcase with a stereo system: [Redacted] Jane also testified that the massage room was approximately the size of a “giant walk-in closet.” (11/30/21 Tr. at 320). And more generally, she testified that the building itself had “Lots of stone, you know, old wood.” (/d. at 317-18). As depicted in Government Exhibits 904 and 917, the massage room is about the size of a walk-in closet, and the moldings in the massage room were made of wood: [Redacted] Finally, Jane explained that the artwork in the house included “Paintings of naked women and orgies and things like that.” So much so, in fact, that “[i]t didn’t seem very unusual at this point.” (11/30/2021 Tr. at 318). That description is accurate, as evident from the above photos. It is also accurate with respect to other photos of the massage room, including Government Exhibit 902, a photo of the entrance to the massage room: [Redacted] These photos readily surmount the low bar of relevance. They specifically corroborate Jane’s memories of the room in which she was sexually abused, showing that in fact she spent time in that room, a critical fact of the case. The Government understands the Court’s point that there has not been testimony specifically comparing these particular photographs to items present during the time period of the conspiracy. But most of Jane’s testimony about the massage room does not concern “movable DOJ-OGR-00008217