DOJ-OGR-00011178.jpg
Extracted Text (OCR)
Case 1:20-cr-00330-PAE Document 700 Filed 07/12/22 Page5of6
clerked for a judge in 2018, assisted with sentencing proceedings during that clerkship, and
returned to chambers for a visit in 2021 could readily identify the book on the table as the 2021
version of the same Guidelines manual with which she had become so familiar in 2018. In either
case, the witness has offered “sufficient proof... so that a reasonable juror could find in favor of
authenticity or identification.” United States v. Dhinsa, 243 F.3d 635, 658 (2d Cir. 2001). The
same is true here.
Il. GX 606
The Government also expects to offer Government Exhibit 606 during Alessi’s testimony
tomorrow. As explained on its cover page, Government Exhibit 606 is the “Household Manual”
for “358 El Brillo Way, Palm Beach, FL 33480”—Epstein’s Palm Beach residence. It is fifty-
eight pages and is dated February 14, 2005. The manual contains instructions to give staff “the
proper guidance and assistance to perform your duties to the best of your ability, while ensuring a
consistently high level of service.” GX 606 at 3. Among other things, employees are instructed
to “[t]ry and anticipate the needs of Mr Epstein, Ms Maxwell and their guests,” id. at 4, answer the
telephone a certain way, id. at 7, and contains checklists for various tasks, id.at 10-46.
Alessi is a witness with knowledge that the manual “is what it is claimed to be.” Fed. R.
Evid. 901(b)(1). He recognizes Government Exhibit 606 as a version of the household manual
that the defendant gave Alessi and his wife, in the form of a booklet, in approximately the late
1990s or early 2000s. See 3504-046. Alessi reviewed the manual and specifically recalls each
page except for certain portions on pages 7, 9, 13, 16, 19, 30, 31, and 33, such as particular phrases
or items on a shopping list. For instance, he recalls the checklists as tasks which he had to
complete, and recalls that the defendant was angry that Alessi did not fill out the checklists.
DOJ-OGR-00011178
Extracted Information
Document Details
| Filename | DOJ-OGR-00011178.jpg |
| File Size | 686.8 KB |
| OCR Confidence | 94.0% |
| Has Readable Text | Yes |
| Text Length | 2,010 characters |
| Indexed | 2026-02-03 18:05:37.511965 |