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Extraction Summary
5
People
2
Organizations
3
Locations
1
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing (defense letter to judge)
File Size:
627 KB
Summary
This document is page 8 of a defense filing in the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), dated December 5, 2021. The defense argues against the admission of government evidence, specifically photos of vibrators, a stuffed tiger, and a stuffed dog, claiming 'Jane' did not identify these specific items in her testimony. The defense also challenges photos of the interior of Epstein's New York apartment, arguing they are unauthenticated and potentially misleading.
People (5)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | Judge |
Recipient of the letter, presiding over the case.
|
| Jane | Witness/Victim |
Testified about Epstein's abuse and items in the house; prosecution witness.
|
| Jeffrey Epstein | Deceased/Perpetrator |
Owner of the apartment/house; alleged to have used vibrators on Jane.
|
| Ghislaine Maxwell | Defendant |
Referenced as 'Ms. Maxwell'; challenging the admissibility of photographic evidence.
|
| Juan Alessi | Witness |
Referenced in footnote 3 regarding testimony about back massagers in Palm Beach.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Government |
Seeking to admit photos as evidence.
|
|
| DOJ |
Indicated by footer 'DOJ-OGR'.
|
Locations (3)
| Location | Context |
|---|---|
|
Where vibrators were found 'twenty years later' (Epstein's apartment).
|
|
|
Location associated with Mr. Alessi's testimony about back massagers.
|
|
|
Subject of photos (structural features, interior vs exterior).
|
Relationships (2)
References to Epstein using vibrators on Jane.
Testimony regarding items in Epstein's Palm Beach property.
Key Quotes (4)
"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."Source
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Quote #1
"Stuffed animals and vibrators are also highly mobile."Source
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Quote #2
"Jane testified that Mr. Epstein had “animals” and “animal heads” and “strange things” in the house that were “a little creepy personally.”"Source
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Quote #3
"Mr. Alessi’s testimony about back massagers in Palm Beach has no bearing on the vibrators found in New York twenty years later."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (1,822 characters)
Case 1:20-cr-00330-PAE Document 525 Filed 12/05/21 Page 8 of 9
The Honorable Alison J. Nathan
December 5, 2021
Page 8
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.
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.” Id. 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
“strange things” in the house that were “a little creepy personally.” Id. 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
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.
vibrators found in New York twenty years later. See Gov. Letter at 9.
⁴ Stuffed animals and vibrators are also highly mobile.
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