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Case 1:20-cr-00330-PAE Document 700 Filed 07/12/22 Page4of6 Alessi’s testimony is sufficient to authenticate Government Exhibit 52. He will testify that, for many years, the defendant and Epstein maintained copies of a contact book. They had a practice of annually updating it. And Alessi can identify Government Exhibit 52 as one of those books, based on its distinctive characteristics, including its contents, internal patterns, and binding. See Fed. R. Evid. 901(b)(4) (listing, as a basis of authentication, “[t]he appearance, contents, substance, internal patterns or other distinctive characteristics of the item, taken together with all the circumstances”).* Alessi’s testimony also confirms that Government Exhibit 52 reflects information from the time period of the conspiracy. (See 11/01/21 Tr. at 61). Alessi will testify that it was the practice of the Palm Beach house, during the time period of the conspiracy, to maintain an address book like this one. (Cf 11/01/21 Tr. at 61 (“THE COURT: If the evidence were that it wasn’t created or maintained until after the charged conspiracy, is it relevant?”)). And Alessi specifically recalls the fact that the address book had an entry for “Jane” and an entry for Florida masseuses during the time period of the conspiracy. Consider if an employer gives a “history of the firm” book to each new employee. A 2021 version of the book could be authenticated by an employee who worked at the firm for a decade until 2019, was aware of the firm’s practice of giving out books, saw many copies of the book, identifies the distinctive markings of the 2021 version, and recalls specific portions of the 2021 version as being the same as portions included in the 2019 version. Similarly, a young lawyer who * As discussed in the Government’s prior letter, this evidence is corroborated by Government Exhibit 606, discussed below, and other evidence at trial showing that the address book in fact contains the nonpublic information of persons listed therein who in fact knew the defendant at the time. (Dkt. No. 491 at 2-4). 4 DOJ-OGR-00011177