DOJ-OGR-00006697.pdf

--- Page 1 --- The extracted text is: **Case 1:20-cr-00330-PAE** **Document 449** **Filed 11/12/21** **Page 4 of 8** The Government has proffered a number of exhibits that it apparently intends to introduce at trial. It is difficult to assess the admissibility of some of the exhibits pretrial. Others, however, such as the ones described below, are not relevant in the context of this case, have no probative value, and are extremely prejudicial. Accordingly, Ms. Maxwell objects to the following exhibits pursuant to Federal Rules of Evidence 401, 403 and 404(b): **I. The Exhibits** Government Exhibit 251 and 288 are framed photographs The photographs have no nexus to Ms. Maxwell The photographs have no probative value to any allegation in this case and appear to be offered to demonstrate some character flaw in Mr. Epstein and, by association, Ms. Maxwell. Government Exhibit 294 is a box containing an item described as "Twin Torpedos." This box was apparently seized during the execution of a search warrant at 358 El Brillo Way, Palm Beach, Florida, on October 20, 2005. These items are inadmissible for the reasons discussed in Ms. Maxwell's Motion to Exclude Items Purportedly Seized During Search of 358 El Brillo Way on October 20, 2005. In addition to problems related to the evidentiary foundation of these items, they are not relevant to any issue in this case. The unopened boxes were purportedly seized in 2005, after the end of any conspiracy alleged here. No witness will identify these items as having been in Ms. Maxwell's possession or used in connection with any crime alleged in the indictment.