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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

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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