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Case 1:20-cr-00330-PAE Document 700 Filed 07/12/22 Page6of6
Alessi is therefore a witness able to authenticate the Government Exhibit 606. Although
the manual itself is dated to 2005 on its face, Alessi is expected to testify that the exhibit is largely
unchanged from the version he had when he received from the defendant and Epstein. He is
therefore a witness with “knowledge that a matter is what it is claimed to be,” which “is sufficient
to satisfy [the authentication] standard.” United States v. Gagliardi, 506 F.3d 140, 151 (2d Cw.
2007); see id. (“Based on the[] testimony [that electronic communications were accurate], a
reasonable juror could have found that the exhibits did represent those conversations,
notwithstanding that the e-mails and online chats were editable.”).°
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By: __s/
Maurene Comey
Alison Moe
Lara Pomerantz
Andrew Rohrbach
Assistant United States Attorneys
Southern District of New York
Cc: Defense Counsel (by e-mail)
> The Government also expects another employee of Epstein’s (“Employee-2”) to also be able to
authenticate the household manual.
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DOJ-OGR-00011179
Extracted Information
Dates
Document Details
| Filename | DOJ-OGR-00011179.jpg |
| File Size | 405.8 KB |
| OCR Confidence | 93.0% |
| Has Readable Text | Yes |
| Text Length | 1,169 characters |
| Indexed | 2026-02-03 18:05:38.647245 |