DOJ-OGR-00008218.pdf

--- Page 1 --- **Document Header** * **Case Number:** Case 1:20-cr-00330-PAE * **Document Number:** Document 523 * **Filing Date:** Filed 12/04/21 * **Page Number:** Page 5 of 9 **Text Extraction** **Paragraph 1** Much of it concerns fixtures: the room's size, its dark and reddish wallpaper and curtains, its built-in bookcase, and its wooden molding. Those cannot be removed from the room without a renovation—in some cases, a significant renovation. Even those items that are "movable" are consistent with Epstein's longstanding practices, and therefore still probative. Jane did not testify to any art in the massage room, and the Government would not argue that the particular nude artwork in the exhibits was present while Jane was abused. But there is evidence of Epstein's practice of displaying depictions of naked women in his homes from the mid-1990s through the mid-2000s, through both Jane's testimony and evidence of the search of his Palm Beach house. The artwork in Epstein's home at the time of the search is a continuation of that practice and tends to make it more likely that Jane's testimony was accurate. That is all that is required to show relevance. At a more general level, this evidence is probative that Jane knew how Epstein decorated his New York massage room. It was dark, red, with curtains, a built-in bookcase, and a stereo system. It was in a house decorated with wood, wallpaper, and artwork showing nude women. The jury will know full well, and the defense will surely argue, that time has passed since the mid-1990s. But that argument goes to weight, not whether the evidence is relevant at all. A jury could reasonably conclude that it is no coincidence that these photos match Jane's description—it is because Jane has been in this room. If the Court remains concerned about the relevance of movable property, the Government can offer photos that redact the artwork. But the photographs of the massage room are probative **Footer** * **DOJ-OGR-00008218** **Note** There are no handwritten notes visible in the document image.