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.
This legal document, filed on February 24, 2022, is part of Ms. Maxwell's defense, arguing against the reliability of her accusers' memories. It highlights similarities between the claims of accusers (Jane, Carolyn, Kate, Annie Farmer) and those of Juror No. 50, who also claims to be a victim of abuse. The document focuses on Juror No. 50's assertion that his memory can be 'replayed like a video,' directly contradicting the expert testimony of Dr. Loftus, who stated that memory is a constructive process, thereby questioning the validity of such memory claims and suggesting potential juror bias.
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