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655 KB
Extraction Summary
5
People
2
Organizations
2
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing (defense letter/motion in limine)
File Size:
655 KB
Summary
This legal filing from December 5, 2021, addressed to Judge Alison J. Nathan, argues for the exclusion of specific evidence in the case against Ghislaine Maxwell. The defense contends that 2019 photographs of Jeffrey Epstein's house are irrelevant and prejudicial because items like massage tables and artwork are 'highly mobile' and may not reflect the conditions present when the accuser, Jane, was there in 1994-1996. The document asserts that the photos are inflammatory and lack connection to Ms. Maxwell.
People (5)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | Judge |
The Honorable Judge addressed in the filing.
|
| Jane | Witness/Accuser |
Described being at Epstein's house in 1994-1996; provided descriptions of items.
|
| Mr. Epstein | Subject |
Owner of the house where the alleged events took place.
|
| Ms. Maxwell | Defendant |
Mentioned in the argument that the photos have 'no connection to Ms. Maxwell'.
|
| McCormick | Legal Authority |
Author of 'McCormick on Evid.' cited regarding evidence rules.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The government |
Attempting to introduce photographic evidence.
|
|
| The Court |
Reviewing the admissibility of evidence.
|
Timeline (3 events)
2021-12-03
Court proceeding referenced in transcript citation (TR 12/3/2021).
Courtroom
Locations (2)
| Location | Context |
|---|---|
|
Location of alleged events in 1994-1996; subject of 2019 photographs.
|
|
|
Location where the government physically carried a massage table.
|
Relationships (2)
Text mentions 'Jane was at Mr. Epstein’s house' 25 years ago.
Implied by the context of the case and the defense arguing evidence has 'no connection to Ms. Maxwell'.
Key Quotes (4)
"Artwork is highly mobile. Furniture is highly mobile. Massage tables are highly mobile."Source
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Quote #1
"(The government carried one such table into the well of the courtroom.)"Source
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Quote #2
"Indeed, the government now disavows any argument 'that the particular nude artwork in the exhibits was present while Jane was abused.'"Source
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Quote #3
"they are unfairly prejudicial because they depict something occurring fifteen years after the charged conspiracy, they have no connection to Ms. Maxwell, and they are inflammatory."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (1,852 characters)
Case 1:20-cr-00330-PAE Document 525 Filed 12/05/21 Page 7 of 9
The Honorable Alison J. Nathan
December 5, 2021
Page 7
The Honorable Alison J. Nathan
December 5, 2021
Page 7
The government attempts to marginalize this Court’s legitimate concern about highly
mobile items. But the Court’s concern is well founded. Twenty-five years have passed since Jane
was at Mr. Epstein’s house. Artwork is highly mobile. Furniture is highly mobile. Massage tables
are highly mobile. (The government carried one such table into the well of the courtroom.)
Curtains are easily changed and replaced. The list goes on. So, absent at least some testimony on
the subject, there is no reason to think that these highly mobile items depicted in the 2019 photos
are the same highly mobile items that Jane says she saw (though not in the massage room) in
1994 or 1995 or 1996.
mobile items. But the Court’s concern is well founded. Twenty-five years have passed since Jane
was at Mr. Epstein’s house. Artwork is highly mobile. Furniture is highly mobile. Massage tables
are highly mobile. (The government carried one such table into the well of the courtroom.)
Curtains are easily changed and replaced. The list goes on. So, absent at least some testimony on
the subject, there is no reason to think that these highly mobile items depicted in the 2019 photos
are the same highly mobile items that Jane says she saw (though not in the massage room) in
1994 or 1995 or 1996.
Indeed, the government now disavows any argument “that the particular nude artwork in
the exhibits was present while Jane was abused.” Gov. Letter at 8. But if that’s so, then there’s
no probative value to the unauthenticated photographs, particular when, as the Court
acknowledged, the government already “ha[s] [Jane’s] description in” evidence. TR 12/3/2021, p
1077:3.
the exhibits was present while Jane was abused.” Gov. Letter at 8. But if that’s so, then there’s
no probative value to the unauthenticated photographs, particular when, as the Court
acknowledged, the government already “ha[s] [Jane’s] description in” evidence. TR 12/3/2021, p
1077:3.
Because the government has not authenticated the 2019 photos as accurate
representations of Mr. Epstein’s house in 1994 or 1995 or 1996, they are irrelevant. But even if
they were relevant, this Court could still exclude them as unfairly misleading and prejudicial.
Fed. R. Evid. 403. They are misleading because, as McCormick recognizes, the government has
not shown the lack of changed conditions. § 215. Photographs, 2 McCormick on Evid. § 215 (8th
ed.). And they are unfairly prejudicial because they depict something occurring fifteen years
after the charged conspiracy, they have no connection to Ms. Maxwell, and they are
inflammatory. Fed. R. Evid. 403.
representations of Mr. Epstein’s house in 1994 or 1995 or 1996, they are irrelevant. But even if
they were relevant, this Court could still exclude them as unfairly misleading and prejudicial.
Fed. R. Evid. 403. They are misleading because, as McCormick recognizes, the government has
not shown the lack of changed conditions. § 215. Photographs, 2 McCormick on Evid. § 215 (8th
ed.). And they are unfairly prejudicial because they depict something occurring fifteen years
after the charged conspiracy, they have no connection to Ms. Maxwell, and they are
inflammatory. Fed. R. Evid. 403.
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