DOJ-OGR-00008221.jpg
Extracted Text (OCR)
Case 1:20-cr-00330-PAE Document523 Filed 12/04/21 Page8sof9
photos of the defendant and Epstein with celebrities, and additional artwork depicting nude
women. The Government does not currently intend to offer exhibits depicting those photographs
or artwork, but it does intend to elicit testimony from the law enforcement witness that the home
contained those items. That testimony is further corroboration of Jane’s general knowledge of
categories of decorations Epstein preferred, but it contains no suggestion that any particular exhibit
corroborates Jane’s testimony.
Finally, the Government notes that the defense has not raised a Rule 403 prejudice
argument, and for good reason. None of the evidence in this category is prejudicial to the defense.
There will be no suggestion that the defendant or Epstein possessed these particular items during
the time period of the conspiracy, and the defense is free to argue that the distance in time
undermines the probative force of the evidence. But whether that probative force is significant (as
the Government suggests) or minimal (as the defense suggests), the defense is not prejudiced by
pictures of a massager, a stuffed tiger, or photos of structural features of Epstein’s home.
I. Conclusion
For the foregoing reasons, photographs from the 900 series of Government Exhibits should
be admitted.
DOJ-OGR-00008221
Extracted Information
Dates
Document Details
| Filename | DOJ-OGR-00008221.jpg |
| File Size | 516.7 KB |
| OCR Confidence | 95.2% |
| Has Readable Text | Yes |
| Text Length | 1,374 characters |
| Indexed | 2026-02-03 17:32:41.261527 |