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Extracted Text (OCR)
Case 1:20-cr-00330-PAE Document 491 Filed 11/22/21 Page2of6
identification.” Jd. (internal quotation marks omitted); see Fed. R. Evid. 901(a). The “standard
for authentication is one of ‘reasonable likelihood’ and is ‘minimal.’ The testimony of a witness
with knowledge that a matter is what it is claimed to be is sufficient to satisfy this standard.”
United States v. Gagliardi, 506 F.3d 140, 151 (2d Cir. 2007) (citations and internal quotation
marks omitted). After this low bar is satisfied, “the other party then remains free to challenge the
reliability of the evidence, to minimize its importance, or to argue alternative interpretations of its
meaning, but these and similar other challenges to go the weight of the evidence—not to its
admissibility.” United States v. Tan Yat Chin, 371 F.3d 31, 38 (2d Cir. 2004) (emphases in
original).
The defendant’s argument suggests that Government Exhibit 52 is unique in a way
unsupported by the evidence. Government Exhibit 52 is a bound, sewn, typed address book with
a particular cover. Employee-1 will testify that, based on its appearance, contents, and distinctive
characteristics, it appears to be a copy of the defendant’s address book. She will also testify that
other bound, sewn, typed copies of the same address book with the same cover were located in
specific places in Epstein’s Palm Beach house, as was the operating practice of Epstein’s house.
That testimony is corroborated by Government Exhibit 606, the household manual, which states
that “A copy of Mr Epstein and Ms Maxwell’s telephone directories must be placed to the right of
each telephone (except for the Guestrooms).” (GX 606 at 7). And it is corroborated by Mr.
Rodriguez himself, whose counsel said at sentencing in his case that the book he possessed was “a
copy of the book, of which there were many copies, and Mr. Rodriguez had one as Mr. Epstein’s
house man.” Sent. Tr. at 10, United States v. Rodriguez, 10 Cr. 80015 (KAM) (S.D.F.L. June 18,
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Dates
Document Details
| Filename | DOJ-OGR-00007413.jpg |
| File Size | 684.9 KB |
| OCR Confidence | 94.5% |
| Has Readable Text | Yes |
| Text Length | 1,999 characters |
| Indexed | 2026-02-03 17:22:58.704338 |