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Case 1:20-cr-00330-PAE Document 767 Filed 08/10/22 Page 142 of 257 2976
LCKVMAX6 Summation - Ms. Menninger

1 control the people around them. He used his position to
2 manipulate people and play them off against one another.
3 Juan Alessi told you -- despite their one quote the
4 government showed you about Ghislaine being the lady of the
5 house when she first started, that, in 2016, Mr. Alessi
6 testified it was Epstein who was his direct supervisor. And if
7 Epstein was in the house, he would never go to Ghislaine, he
8 would go directly to Epstein.
9 And let's talk a little bit about Mr. Alessi.
10 Mr. Alessi worked for Epstein for many years. But you
11 can tell from the one email exchange, Government Exhibit 424,
12 between Ghislaine and Sally Markham that Mr. Alessi was not
13 doing a very good job. In fact, I think she called it a truly
14 awful job. So we know the two of them weren't getting along.
15 But does being a tough boss make you an enforcer of a
16 code of silence? Mr. Alessi is simply not credible. He said
17 he didn't follow the household manual, which is dated years
18 later. He threw it away. Not one employee told you they
19 followed this household manual.
20 He's also the one that the government tried to get in
21 this little black address book from, right? He's the one. He
22 said he recognized it; it looked like the one he had seen. He
23 has no idea what year it's from. He doesn't know how accurate
24 it is; that people get added every year and taken away every
25 year. So somehow in 2021, a black address book shows up on the

SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300

DOJ-OGR-00017163