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622 KB
Extraction Summary
4
People
1
Organizations
2
Locations
5
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
622 KB
Summary
This legal document, dated December 5, 2021, is a filing to Judge Alison J. Nathan arguing against the admissibility of interior photographs of Mr. Epstein's apartment. The author contends the photos, taken in 2019, cannot be proven to accurately represent the apartment's state during the charged conspiracy, which ended in 2004. The document highlights that the government's case for the photos' relevance relies solely on the testimony of a witness, "Jane," who described the apartment's interior based on her memory from an alleged visit in the mid-1990s.
People (4)
| Name | Role | Context |
|---|---|---|
| The Honorable Alison J. Nathan | Judge |
The document is addressed to her.
|
| Mr. Epstein | Accused |
Owner of the New York apartment where an alleged assault took place.
|
| Jane | Accuser/Witness |
Alleges she was assaulted by Mr. Epstein in his apartment; her testimony about the apartment's interior is quoted.
|
| Ms. Maxwell | Party to the case |
Mentioned in a footnote as not objecting to exterior photographs, implying she is a defendant or related party.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| government | government agency |
Mentioned as a party in the legal case, seeking to use photos as evidence.
|
Timeline (5 events)
1994-1996
Jane alleges she visited Mr. Epstein's New York apartment when she was 14, 15, or 16 years old and that he assaulted her in the massage room.
Mr. Epstein’s New York apartment
2021-12-03
Counsel for Ms. Maxwell stated that she does not object to the exterior photographs of the apartment.
Court
counsel
Ms. Maxwell
Locations (2)
| Location | Context |
|---|---|
|
The central location discussed, where an alleged assault occurred and whose interior is described.
|
|
|
The city where Mr. Epstein's apartment is located.
|
Relationships (2)
Jane alleges that Mr. Epstein assaulted her in his New York apartment when she was a teenager.
Ms. Maxwell is a party in a case involving a conspiracy that took place at Mr. Epstein's apartment, suggesting a close connection in the context of the legal proceedings.
Key Quotes (5)
"The apartment was more like a building than a house; it had eight stories."Source
— Jane
(Quoted from her testimony (TR 11/20/2021, p 317:16-22) describing Mr. Epstein's apartment.)
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Quote #1
"Inside, it was “very dark,” “very, very -- like an old building.”"Source
— Jane
(Quoted from her testimony (Id. at 317:24-25) describing the interior of Mr. Epstein's apartment.)
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Quote #2
"It had “fabric wallpaper, like red curtains, lots of artwork, statues, paintings.”"Source
— Jane
(Quoted from her testimony (Id. at 318:1-2) describing the decor of Mr. Epstein's apartment.)
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Quote #3
"The artwork was “a little creepy personally,” with a “dark theme,” “intimidating” with “animal heads and strange things.”"Source
— Jane
(Quoted from her testimony (Id. at 318:5-13) describing the artwork in Mr. Epstein's apartment.)
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Quote #4
"The artwork included “[p]aintings of naked women and orgies and things like that.”"Source
— Jane
(Quoted from her testimony (Id. at 318:18) describing the subject matter of the artwork in Mr. Epstein's apartment.)
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Quote #5
Full Extracted Text
Complete text extracted from the document (1,753 characters)
Case 1:20-cr-00330-PAE Document 525 Filed 12/05/21 Page 2 of 9
The Honorable Alison J. Nathan
December 5, 2021
Page 2
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.¹
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:
• 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.” Id. at 317:24-25.
• It had “fabric wallpaper, like red curtains, lots of artwork, statues, paintings.” Id. at 318:1-2.
• The artwork was “a little creepy personally,” with a “dark theme,” “intimidating” with “animal heads and strange things.” Id. at 318:5-13.
• The artwork included “[p]aintings of naked women and orgies and things like that.” Id. at 318:18.
• Inside, it was “very dark,” “very, very -- like an old building.” Id. at 317:24-25.
• It had “fabric wallpaper, like red curtains, lots of artwork, statues, paintings.” Id. at 318:1-2.
• The artwork was “a little creepy personally,” with a “dark theme,” “intimidating” with “animal heads and strange things.” Id. at 318:5-13.
• The artwork included “[p]aintings of naked women and orgies and things like that.” Id. at 318:18.
¹ 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
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