DOJ-OGR-00008275.jpg
Extracted Text (OCR)
Case 1:20-cr-00330-PAE Document533 _ Filed 12/09/21 Page3of8
Il. Discussion
The Government has laid sufficient foundation for admission of Government Exhibit 52
through three sources: (1) the testimony of Juan Alessi, (2) the admission of Government Exhibit
606 (the household manual), and (3) evidence corroborating the fact that the contact book reflects
the contact information of multiple people who knew the defendant and Epstein. Taken together,
this evidence is more than sufficient for a reasonable juror to conclude that the contact book is in
fact a contact book from the Palm Beach house.
First, Alessi personally examined Government Exhibit 52 and recognized it. Tr. at 850.
He said it is the same “type of book,” and appeared to be one of the “directories of Ms. Maxwell
and Mr. Epstein.” /d. He said it had the “same cover,” had the “same binding,” and had layout
that was “exactly as the books” that he recalled. (/d. at 851). Although the books he saw were
thicker and had larger font, the “format was the same.” (/d. at 851-52).
As to the contents of the book, Alessi testified that he saw “many, many, many, many
names” in Government Exhibit 52 that were he recognized from the book he saw when he worked
for Epstein. (/d. at 851). He specifically recognized entries in the list for massage in Palm Beach,
which is copied in Government Exhibit 52-G. (/d.)
Although Alessi only worked in the Palm Beach house until the end of 2002, he explained
that the practice during his twelve years that he worked for Epstein was to print new directories
twice a year. Tr. at 864. He also determined that Government Exhibit 52 is a copy of a book from
sometime after he was employed because his name was not in the book, whereas his contact
information and it was “originally . . . in the information for Palm Beach information of the house.”
Id. at 853. That is confirmed by the date inside the book (2004-2005) and the fact that it contains
DOJ-OGR-00008275
Extracted Information
Dates
Document Details
| Filename | DOJ-OGR-00008275.jpg |
| File Size | 677.9 KB |
| OCR Confidence | 94.8% |
| Has Readable Text | Yes |
| Text Length | 1,971 characters |
| Indexed | 2026-02-03 17:33:16.083734 |