DOJ-OGR-00018591.pdf

--- Page 1 --- **Document Header** * **Case Number:** 1:20-cr-00330-PAE * **Document Number:** 751 * **Filed Date:** 08/10/22 * **Page Number:** 254 of 261 **Case Details** * **Case Title:** LC6Cmax7 * **Defendant:** Meder - direct **Transcript** 1. There are of course limitations on metadata and 2. whether it can tell whether a file was saved on a certain date 3. or whether a photograph was taken on a certain date or 4. otherwise. And to the extent the defense wants to put that at 5. issue, they're certainly welcome to do so. 6. In terms of its relevance, it shows that the nature of 7. the relationship between the defendant, Epstein, and this 8. victim was of a sexual nature. For example, when Mr. Alessi 9. testified about this victim, I believe the cross examination 10. about that was that she was a professional, that she was at 11. Mar-a-Lago, the defendant was only there for a treatment, and I 12. believe there was a lot of -- there were a lot of questions on 13. cross examination designed to suggest that she was a 14. professional masseuse. And if the defense intends to argue 15. that this person was a professional masseuse, it is certainly 16. relevant in response to that argument that, in fact, Epstein 17. had a topless photograph of her in a location that appears to 18. be a tropical island which would be consistent with flight 19. records along those lines. Again, it goes to the relationship 20. between the defendant, Epstein, and this victim, that it was of 21. a sexualized nature, which is consistent with witness 22. testimony. 23. With respect to the particular date of the photograph, 24. that is an issue that the defense is certainly free to explore 25. and put before the jury. I can't make a representation about **Footer** * **Reporting Agency:** SOUTHERN DISTRICT REPORTERS, P.C. * **Phone Number:** (212) 805-0300 * **Document ID:** DOJ-OGR-00018591