DOJ-OGR-00018589.jpg
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Case 1:20-cr-00330-PAE
LC6Cmax7
topless photograph of
Document 751
Meder
this victim.
testimony at
ano
this
trial
ther victim in
this case, and I
trial, that
victim of
We
would be that that
Filed 08/10/22
direct
antic
p
believe we,
the charged conspiracy.
trial will show
the Court will
In particular,
the same person with her
flights with Maxwell and
recal
first and
other exhibits which we will of
last name,
Epstein when she was 17 years old.
Page 252 of 261
ipate that the
erson recruited
in advance of
our view that the person in this photograph is a
fer at
flight logs that will show that this person,
traveled on
As
1, Mr. Alessi
witnessing the defendant meet th
testified
come to the house and give massages.
So the
person topless
is corroborative of
fact that Mr. Eps
tein had a photograph of
consistent with
tha
the evidence at trial
t witn
that t
that he recalled
same person and asked her to
this
ess testimony and
his person, as a
minor, was a victim of the charged conspiracy.
MS. MENNINGER: Your Honor, the fact that this lawyer
is just now representing to this Court that this is minor is
contrary, one,
not a minor when this photogra
to the metadata
testimony of Mr.
Alessi
when she was no
they know is not
with respect
a minor.
her of a minor,
that he met her
to photography in this case,
on the photo
ph was taken,
in 2
that shows she was
and two, the
OOl or 2002, also
yo
So to put in evidence a photo that
when there is no charged crime
ur Honor, is
directly contrary to the evidence as the government knows it
SOUTHERN D
STR
CT RE
PORT
ERS,
(212)
805-0300
PG ew
1413
DOJ-OGR-00018589