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Extracted Text (OCR)
Case 1:20-cr-00330-PAE Document 491 Filed 11/22/21 Page5of6
(“During the meeting, the defendant produced a small bound book and several sheets of legal pad
paper containing hand-written notes.”). Again, the book is sewn and bound, like the other copies
seen by Employee-1, and is not amenable to easy insertion of pages. These “alterations” do not
undermine the authenticity of the book in the slightest, but at most, they go to weight and not
admissibility. See Tan Yat Chin, 371 F.3d at 38; cf, Gagliardi, 506 F.3d 140, 151 (“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.”).
The defense is correct that Employee-1 cannot say that she saw the specific address book
that is Government Exhibit 52 while she worked for Epstein. But she can recognize Government
Exhibit 52 as one of the many copies of the defendant’s address book that she did see, and she can
testify to the practice that, close in time to when Government Exhibit 52 left Epstein’s house, the
address book was regularly kept in specific places around Epstein’s house. That testimony is
enough to satisfy the low bar for authentication, and it is supported by Government Exhibit 606
and by testimony that corroborates private information inside the address book.
DOJ-OGR-00007416
Extracted Information
Dates
Document Details
| Filename | DOJ-OGR-00007416.jpg |
| File Size | 527.9 KB |
| OCR Confidence | 94.5% |
| Has Readable Text | Yes |
| Text Length | 1,428 characters |
| Indexed | 2026-02-03 17:22:59.521406 |