DOJ-OGR-00018591.pdf

Case 1:20-cr-00330-PAE Document 751 Filed 08/10/22 Page 254 of 261 1415 LC6Cmax7 Meder - direct 1 There are of course limitations on metadata and whether it can tell whether a file was saved on a certain date or whether a photograph was taken on a certain date or otherwise. And to the extent the defense wants to put that at issue, they're certainly welcome to do so. 2 In terms of its relevance, it shows that the nature of the relationship between the defendant, Epstein, and this victim was of a sexual nature. For example, when Mr. Alessi testified about this victim, I believe the cross examination about that was that she was a professional, that she was at Mar-a-Lago, the defendant was only there for a treatment, and I believe there was a lot of -- there were a lot of questions on cross examination designed to suggest that she was a professional masseuse. And if the defense intends to argue that this person was a professional masseuse, it is certainly relevant in response to that argument that, in fact, Epstein had a topless photograph of her in a location that appears to be a tropical island which would be consistent with flight records along those lines. Again, it goes to the relationship between the defendant, Epstein, and this victim, that it was of a sexualized nature, which is consistent with witness testimony. 3 With respect to the particular date of the photograph, that is an issue that the defense is certainly free to explore and put before the jury. I can't make a representation about SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018591