DOJ-OGR-00011179.pdf

Case 1:20-cr-00330-PAE Document 700 Filed 07/12/22 Page 6 of 6 Alessi is therefore a witness able to authenticate the Government Exhibit 606. Although the manual itself is dated to 2005 on its face, Alessi is expected to testify that the exhibit is largely unchanged from the version he had when he received from the defendant and Epstein. He is therefore a witness with "knowledge that a matter is what it is claimed to be," which "is sufficient to satisfy [the authentication] standard." United States v. Gagliardi, 506 F.3d 140, 151 (2d Cir. 2007); see id. ("Based on the[] testimony [that electronic communications were accurate], a reasonable juror could have found that the exhibits did represent those conversations, notwithstanding that the e-mails and online chats were editable.").5 Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (by e-mail) 5 The Government also expects another employee of Epstein's ("Employee-2") to also be able to authenticate the household manual. 6 DOJ-OGR-00011179