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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. 7 DOJ-OGR-00008220

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Filename DOJ-OGR-00008220.jpg
File Size 715.6 KB
OCR Confidence 94.8%
Has Readable Text Yes
Text Length 2,078 characters
Indexed 2026-02-03 17:32:41.573255