523.pdf

Type

pdf

Source set

house-oversight-doj

Pages

9

Text status

Searchable text available

OCR confidence

0.9429706525053179

Original source

Extracted text

Case 1:20-cr-00330-PAE Document523 Filed 12/04/21 Page1lof9 U.S. Department of Justice United States Attorney Southern District of New York   The Silvio J. Mollo Building One Saint Andrew’s Plaza New York, New York 10007 December 4, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter moving to admit photographs from the interior of Jeffrey Epstein’s house in New York. As explained below, particular images are corroborative of testimony by the witness using the pseudonym “Jane.” They are therefore relevant to the issues before the Court.! 1. Applicable Law Evidence is relevant if “it has any tendency to make a fact more or less probable than it would be without the evidence,” and the fact “is of consequence in determining the action.” Fed. R. Evid. 401; see Fed. R. Evid. 402 (“Relevant evidence is unless [another law] provides otherwise   ' The Government has redacted the exhibits from this letter entirely to avoid publicizing photographs which may not be exhibits at trial. The Government is prepared to file publicly a version that contains redacted versions of the exhibits if the Court so orders. 1 DOJ-OGR-00008214 

Case 1:20-cr-00330-PAE Document523 Filed 12/04/21 Page2of9 ....”). The “standard of relevance established by the Federal Rules of Evidence is not high.” United States v. Southland Corp., 760 F.2d 1366, 1375 (2d Cir. 1985) (Friendly, J.) (internal quotation marks omitted). A district court’s “evidentiary rulings” are reviewed on appeal “under a deferential abuse of discretion standard,” and are disturbed only if “manifestly erroneous.” United States v. Skelos, 988 F.3d 645, 662 (2d Cir. 2021) (internal quotation marks omitted). “TA] suggestion that an item of evidence relates to a period that is too remote goes to b…

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