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Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 75 of 84 maintained a contact book containing what purports to be this list of names and associated contact information. Second, the defendant moves to preclude any items seized during the 2005 search of Epstein’s home in Palm Beach, Florida. The defense claims, in a conclusory fashion, that “no witness has sufficient personal knowledge about the proposed exhibits” to demonstrate authenticity, because “the evidence collection and retention in this matter is an unreliable mess.” (Def. Mot. 8 at 3-5). The defense further speculates that the Government intends to offer these exhibits without any testimony about their authenticity, in part because the original custodian— Detective Recarey—is dead. (/d. at 4-5). The defense is mistaken. The Government intends to call live witnesses to establish the authenticity of the evidence at trial.!® Third, the defendant argues that the photographs in Government Exhibit 251 and 288 are irrelevant. (Def. Mot. 13 at 2). These photographs, [Jin '8 As to Government Exhibit 295 specifically, that exhibit was written by both Detective Recarey and another witness who is expected to testify at trial. The exhibit is primarily marked for identification, although portions of that document may be offered as a past recollection recorded by that other witness. See Fed. R. Evid. 803(5). The Government will not offer statements from Detective Recarey. 74 DOJ-OGR-00006783