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Case 1:20-cr-00330-PAE Document 749 Filed 08/10/22 Page 12 of 236 916
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1 reasons that your Honor excluded. If it's displayed behind his
2 desk, yes, that may be the case, but the fact remains, we have
3 issues with this jury seeing photographs like this and making
4 assumptions about what people were doing or not doing.
5 There are no allegations in this case that Jeffrey
6 Epstein was attracted to prepubescent girls, and they will
7 potentially draw the wrong conclusion about a photograph of
8 somebody with his goddaughter in some sort of playful moment,
9 it would appear — maybe not everybody does this with their
10 goddaughters, but it's certainly nothing illegal — and they
11 will look at this and assume that his predilections strayed not
12 just to young girls, but to prepubescent girls. It's similar,
13 not just in context, this photograph is a closeup photograph of
14 that photograph, the same way that Government Exhibit 288,
15 which your Honor already excluded about the girl with the
16 underwear exposing her bottom was not in context enough to
17 respond to this argument, it is the same issue. You're looking
18 at a photograph of the photograph by itself without context
19 showing what it shows, and the jury is going to draw an
20 improper conclusion.
21 MS. COMEY: Your Honor, the jury will see the
22 photograph after seeing a series of photographs of the
23 bookshelves around Jeffrey Epstein's desk. I'm not sure I
24 understand what argument the defense is making. Is this an
25 innocent photograph that's just normal behavior between a

SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300

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