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719 KB
Extraction Summary
8
People
4
Organizations
1
Locations
6
Events
6
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
719 KB
Summary
This legal document, filed on December 9, 2021, addresses the authentication and admissibility of Government Exhibit 52, described as a 'book' or 'household manual' belonging to Epstein and Maxwell. It discusses the defendant's challenge to Alessi's knowledge regarding the exhibit's origins and highlights the manual's contents, which detail practices and relationships between the defendant, Epstein, and other individuals. The document asserts that authentication does not require direct knowledge of creation or seizure, and chain of custody issues pertain to weight rather than admissibility.
People (8)
| Name | Role | Context |
|---|---|---|
| Sarah Kellen |
mentioned as having worked for Epstein shortly before Alessi left his employment.
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| Alessi |
left employment, recognized Government Exhibit 52, lacked personal knowledge of Exhibit 52's creation, identified a p...
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| Epstein |
Sarah Kellen worked for him, Government Exhibit 52 belonged to him, co-owner of telephone directories with the defend...
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| Maxwell |
Government Exhibit 52 belonged to her.
|
|
| Rodriguez |
may have added additional markings to evidence.
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|
| Defendant |
challenged Alessi's foundation, co-owner of telephone directories with Epstein, relationships with other individuals ...
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| Proponent |
claims what a piece of evidence is.
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| Defense counsel | counsel |
pointed to additional markings on evidence.
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Organizations (4)
| Name | Type | Context |
|---|---|---|
| FBI | government agency |
may have added additional markings to evidence.
|
| Prevezon Holdings, Ltd. | company |
cited in a legal case (United States v. Prevezon Holdings, Ltd.).
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| United States | government agency |
party in a legal case (United States v. Prevezon Holdings, Ltd.).
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| Government | government agency |
offering evidence, refers to Government Exhibit 52.
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Timeline (6 events)
Sarah Kellen began working for Epstein.
Telephone directories are to be updated every six months.
Locations (1)
| Location | Context |
|---|---|
|
Southern District of New York, cited in a legal case.
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Relationships (6)
Sarah Kellen worked for Epstein.
Alessi worked for Epstein (implied by 'consistent with his experience working for them').
Alessi worked for Maxwell (implied by 'consistent with his experience working for them').
Contents of Government Exhibit 52 accurately reflect relationships between the defendant and other individuals.
Key Quotes (3)
"The bottom line here, Mr. Alessi, you don’t have any personal knowledge about first how or when Exhibit 52 was created; correct?"Source
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Quote #1
"[t]elephone directories are to be updated every six months, or as the new telephone directories are available."Source
— household manual
(Instruction from the household manual regarding telephone directories.)
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Quote #2
"must be placed to the right of each telephone (except for the Guestrooms)."Source
— household manual
(Instruction from the household manual regarding placement of telephone directories.)
DOJ-OGR-00008276.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,123 characters)
Case 1:20-cr-00330-PAE Document 533 Filed 12/09/21 Page 4 of 8
the name of Sarah Kellen, who began working for Epstein shortly before Alessi left his
employment. Tr. at 832; see Fed. R. Evid. 901(b)(4) (permitting authentication based on the
“contents” of the item). Alessi recognized Government Exhibit 52 as a book that belonged to
Epstein and Maxwell, consistent with his experience working for them.
employment. Tr. at 832; see Fed. R. Evid. 901(b)(4) (permitting authentication based on the
“contents” of the item). Alessi recognized Government Exhibit 52 as a book that belonged to
Epstein and Maxwell, consistent with his experience working for them.
The defendant’s challenge to Alessi’s foundation rested largely on Alessi’s lack of
knowledge of the origins of Government Exhibit 52. (See id. at 872-73, 875 “The bottom line
here, Mr. Alessi, you don’t have any personal knowledge about first how or when Exhibit 52 was
created; correct?”).¹ But authentication does not require evidence about the circumstances of the
creation or seizure of a piece of evidence, so long as it can be identified by its distinctive markings
as what the proponent claims it is. See Al Farekh, 810 F. App’x at 24-25. It is well settled that
defects in chain of custody go to weight and not admissibility.
knowledge of the origins of Government Exhibit 52. (See id. at 872-73, 875 “The bottom line
here, Mr. Alessi, you don’t have any personal knowledge about first how or when Exhibit 52 was
created; correct?”).¹ But authentication does not require evidence about the circumstances of the
creation or seizure of a piece of evidence, so long as it can be identified by its distinctive markings
as what the proponent claims it is. See Al Farekh, 810 F. App’x at 24-25. It is well settled that
defects in chain of custody go to weight and not admissibility.
Second, the household manual—dating from 2005, the year on Government Exhibit 52—
demonstrates that the practice identified by Alessi remained in operation into 2005. The manual
explains that “[t]elephone directories are to be updated every six months, or as the new telephone
directories are available.” GX 606 at 7. And it explained that the directories in fact belong to the
defendant and Epstein: a copy of their directories “must be placed to the right of each telephone
(except for the Guestrooms).” GX 606 at 7.
demonstrates that the practice identified by Alessi remained in operation into 2005. The manual
explains that “[t]elephone directories are to be updated every six months, or as the new telephone
directories are available.” GX 606 at 7. And it explained that the directories in fact belong to the
defendant and Epstein: a copy of their directories “must be placed to the right of each telephone
(except for the Guestrooms).” GX 606 at 7.
Third, the contents of Government Exhibit 52 have been confirmed by other evidence to
accurately reflect relationships between the defendant and other individuals. See United States v.
Prevezon Holdings, Ltd., 319 F.R.D. 459, 463 (S.D.N.Y. 2017) (permitting authentication under
accurately reflect relationships between the defendant and other individuals. See United States v.
Prevezon Holdings, Ltd., 319 F.R.D. 459, 463 (S.D.N.Y. 2017) (permitting authentication under
¹ Defense counsel also pointed to the additional markings that may have been added by Rodriguez
or the FBI. Tr. at 872-73, 875. These markings are non-substantive on any page which the
Government is offering, as explained in a prior brief. (Dkt. No. 491 at 4-5).
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or the FBI. Tr. at 872-73, 875. These markings are non-substantive on any page which the
Government is offering, as explained in a prior brief. (Dkt. No. 491 at 4-5).
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