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Case 1:20-cr-00330-PAE Document523 Filed 12/04/21 Page6of9 evidence on a material matter, and they should be admitted. B. Other Photographs Many of the remaining photographs of Epstein’s house corroborate other testimony by Jane. As with the nude pictures in the massage room, each of these photographs is consistent with testimony about Epstein’s practices, so they are probative corroboration of that testimony. First, Jane testified that Epstein used vibrators and back massagers of sizes while abusing her. (11/30/21 Tr. at 310). Juan Alessi, whose testimony corroborated Jane, also testified that he found two different kinds of vibrating back massagers after Epstein received massages, and that those massagers were kept in Epstein’s bathroom in Palm Beach. (12/02/21 Tr. at 894-95). The Government recovered two vibrating massagers in the bathroom of the New York home adjacent to the massage room. The Government therefore seeks admission of two photos, Government Exhibits 918 and 921, depicting those two devices: [Redacted] The point of this evidence is not to show that these vibrators are the particular vibrators used on Jane. It is to show that they are the type that were used on Jane, and corroborate Jane’s testimony by showing that Epstein did, consistent with the modus operandi of the conspiracy from the mid- 1990s through the early 2000s, possess this sort of massager device. Second, Jane testified that the home contained “creepy looking animals.” (11/30/21 Tr. at 3 The Government could not elicit testimony from Jane about these photographs without substantially diminishing the probative force of the evidence. Before showing the photographs to Jane on the stand, the Government would surely need to show her the photographs in advance. Doing so would permit an inference that Jane tailored her testimony about her memories of the massage room to the photographs, thereby vitiating the photographs’ value as independent corroboration. 6 DOJ-OGR-00008219