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Case 1:20-cr-00330-PAE Document525 Filed 12/05/21 Page2of9 The Honorable Alison J. Nathan December 5, 2021 Page 2 claims she was at the apartment) or even in 2004, when the charged conspiracy ended. Without testimony from a witness that the interior photos accurately reflect the inside of Mr. Epstein’s apartment as it existed during the charged conspiracy, they are not admissible.! Jane alleges that she visited Mr. Epstein’s New York apartment when she was 14 or 15 or 16 years old (1994 or 1995 or 1996), TR 11/20/2021, p 316-17, and that he assaulted her in the massage room, id. at 320:12-14. Although the government never showed Jane the 900 series photos during her testimony, the government now says the photos (taken 2019, fifteen years after any conspiracy ended) corroborate what Jane claims to have seen inside Mr. Epstein’s house twenty-five years earlier. Gov. Letter at 3. The government relies only on Jane’s testimony, pointing to pages 317-320 of the transcript. With the exception of the massage room, here was what Jane said about the inside of the house: e The apartment was more like a building than a house; it had eight stories. TR 11/20/2021, p 317:16-22. ® Inside, it was “very dark,” “very, very -- like an old building.” /d. at 317:24-25. e It had “fabric wallpaper, like red curtains, lots of artwork, statues, paintings.” /d. at 318:1-2. e The artwork was “a little creepy personally,” with a “dark theme,” “intimidating” with “animal heads and strange things.” /d. at 318:5-13. e The artwork included “[p]aintings of naked women and orgies and things like that.” /d. at 318:18. ' As counsel stated on Friday, Ms. Maxwell does not object to the exterior photographs. TR 12/3/2021, p 932:17-21. DOJ-OGR-00008226