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- "full_text": "Case 1:20-cr-00330-PAE Document 749 Filed 08/10/22 Page 8 of 236 912 LBUCmax1 decorated his home and his private spaces contradicted the public persona that has been presented through the defense arguments and cross examination. And the point here is that the defendant knew not only the public persona, but the private persona, and the private persona included prominently displaying art that sexualized an underage girl THE COURT: All right. Anything further? MR. EVERDELL: Your Honor, I don't think that this is connected in one way at all. I think if you asked any parent about, do they have like a photograph of their child as a toddler or their goddaughter as a toddler, like in the swimming pool or something where they're not wearing any clothe, they probably have one of those things. Now, whether they display that on their walls, that's another question, but these are not photographs that are indicative of his lifestyle. The problem is in this case, because of the nature of the subject matter, if a juror sees that, they're probably going to leap that to that assumption, that it's not just -- the allegations in this case are women -- are girls that are under the age, but just under the age of consent, 15, 16, 17, not girls that are 5, 6, 7, prepubescent females. If they see that, then they're going to drew an inappropriate conclusion, which I don't think the government is even arguing, and that is a really big 403 prejudice problem. And that's the issue we're trying to avoid, which is why we moved in limine and why we SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018109",
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- "content": "decorated his home and his private spaces contradicted the public persona that has been presented through the defense arguments and cross examination. And the point here is that the defendant knew not only the public persona, but the private persona, and the private persona included prominently displaying art that sexualized an underage girl THE COURT: All right. Anything further? MR. EVERDELL: Your Honor, I don't think that this is connected in one way at all. I think if you asked any parent about, do they have like a photograph of their child as a toddler or their goddaughter as a toddler, like in the swimming pool or something where they're not wearing any clothe, they probably have one of those things. Now, whether they display that on their walls, that's another question, but these are not photographs that are indicative of his lifestyle. The problem is in this case, because of the nature of the subject matter, if a juror sees that, they're probably going to leap that to that assumption, that it's not just -- the allegations in this case are women -- are girls that are under the age, but just under the age of consent, 15, 16, 17, not girls that are 5, 6, 7, prepubescent females. If they see that, then they're going to drew an inappropriate conclusion, which I don't think the government is even arguing, and that is a really big 403 prejudice problem. And that's the issue we're trying to avoid, which is why we moved in limine and why we",
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