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Case 1:20-cr-00330-PAE Document525 Filed 12/05/21 Page 8of9 The Honorable Alison J. Nathan December 5, 2021 Page 8 The government’s letter next addresses photos of vibrators and a stuffed tiger. As for the vibrators, the government does not contend the vibrators are the “particular vibrators used on Jane,” only that they are “they type” of vibrators used on Jane. Gov. Letter at 10. But there is no testimony to support that argument, because Jane did not describe the vibrators other than to say they were “different sizes.” TR 11/20/2021, p 310:14-15.3 And because the government did not show these photos to Jane, there is no evidence that they are “the type” she claims Mr. Epstein used on her. If they were “the type,” Jane could easily have said so on the stand. The tiger next. Jane testified that Mr. Epstein had “animals” and “animal heads” and “strange things” in the house that were “a little creepy personally.” /d. at 318:5-13. She did not testify or describe a tiger. There’s no foundation to admit that photograph, or the photograph of a stuffed dog, which Jane also did not describe. Gov. Letter at 11.4 The government also discusses six photos that show the so-called structural features of the house. Again, Ms. Maxwell does not challenge photos of the outside of Mr. Epstein’s apartment. But photos of the inside of the apartment are a different matter. The government has not authenticated them, and even if they were authenticated, they have minimal if any probative value, as contrasted with their potential to mislead the jury as to what the apartment looked like 3 Mr. Alessi’s testimony about back massagers in Palm Beach has no bearing on the vibrators found in New York twenty years later. See Gov. Letter at 9. * Stuffed animals and vibrators are also highly mobile. DOJ-OGR- 00008232