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Case 1:20-cr-00330-PAE Document523 Filed 12/04/21 Page/7of9
305). This comment about Epstein’s distinct decorating style may seem implausible to jurors. But
the Government observed and photographed more than one stuffed animal that could fairly be
described as “creepy looking” during its search of Epstein’s house, including as depicted in
Government Exhibit 9387:
[Redacted]
The fact that this stuffed tiger is movable property is counterbalanced by the fact that it is
highly idiosyncratic. While the Government would not argue that Epstein had this particular
stuffed tiger in his home in the mid-1990s, it is probative of Jane’s testimony that—at any point in
time—Epstein possessed the kind of “creepy looking animals” that she described.
Third, the Government would offer six photos—Government Exhibits 909 through 911,
913, 915, and 933—to demonstrate structural features of the house. Some of these photographs
will provide context for the law enforcement officer’s testimony by showing the entrance areas of
the house which she searched. And all of them will corroborate Jane’s testimony that the house
was intimidating and contains significant amounts of wood and stone, as Jane stated. (11/30/21
Tr. at 317-18 (describing the house as “massive” and made her feel “Intimidated.”); 320
(explaining that the house had “Lots of stone, you know, old wood.”)). Neither of these theories
involve movable property of any kind, and the Government would not argue that any movable
furniture or artwork was present when Jane visited the house.°
Fourth, Epstein’s home contained a large number of photographs of celebrities, including
* A stuffed dog is also depicted in Government Exhibit 936.
> The Government also notes that the Court has already ruled that it will reserve, subject to
connection, on the admissibility of costumes from the search, which are marked as physical
exhibits and depicted in Government Exhibits 919 and 920. (12/03/21 Tr. at 929). The
Government similarly will offer Government Exhibits 919 and 920 subject to connection.
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