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Case 1:20-cr-00330-PAE Document535 _ Filed 12/09/21 Page4of8 exhibit and that he recognized “many, many, many, many names” amongst the entries, including some of the entries that were for “massage in Palm Beach.” /d. at 851. The Defense first objects that Mr. Alessi has no personal knowledge about the creation of this particular directory and is thus incapable of authenticating the exhibit. Mr. Alessi acknowledged that GX 52 was a different version than the directories he was familiar with because GX 52 was not as thick as those versions, and his name and his wife’s name were in the version he observed, but neither his name nor his wife’s name was in GX 52. Id. at 853, 865. But a document may be admitted under 901(b)(4) even when no witness saw the creation of the document or the particular copy admitted at trial. For example, in United States v. Al Farekh, 810 F. App’x 21 (2d Cir. 2020), the court affirmed the district court’s authentication of handwritten letters even though no testifying witness confirmed they had previously examined the letters. Instead, testimony that the “appearance, contents, substance, internal patterns, or other distinctive characteristics” of the letters were consistent with other letters previously observed was sufficient to satisfy Rule 901. Id. at 24-25. Similarly, in Tin Yat Chin, the Second Circuit affirmed the admission of copies of credit card receipts despite uncertainty about who signed the receipts and when. 371 F.3d at 38; see also United States v. Gordon, 634 F.2d 639, 643-44 (1st Cir. 1980) (referring to authenticated documents as “parallel documents” with distinctive characteristics such as being printed on the “same stationary,” to “indicate a common authorship”). Finally, cases have allowed a witness to authenticate emails under Rule 901(b)(4), even if they were not a recipient of the specific email being admitted, when the witness had a history and familiarity with the defendant’s email communication tendencies. See, e.g., United States v. Bertram, 259 F. Supp. 3d 638 (E.D. Ky. 2017); see also United States v. Gasperini, 16-CR-441 (NGG), 2017 WL DOJ-OGR-00008306