{ "document_metadata": { "page_number": "254", "document_number": "751", "date": "08/10/22", "document_type": "court transcript", "has_handwriting": false, "has_stamps": false }, "full_text": "Case 1:20-cr-00330-PAE Document 751 Filed 08/10/22 Page 254 of 261 1415 LC6Cmax7 Meder - direct\n1 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.\n2 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.\n3 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\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00013005", "text_blocks": [ { "type": "printed", "content": "Case 1:20-cr-00330-PAE Document 751 Filed 08/10/22 Page 254 of 261 1415 LC6Cmax7 Meder - direct", "position": "header" }, { "type": "printed", "content": "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.\n2 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.\n3 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", "position": "main body" }, { "type": "printed", "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300", "position": "footer" }, { "type": "printed", "content": "DOJ-OGR-00013005", "position": "footer" } ], "entities": { "people": [ "Epstein", "Alessi" ], "organizations": [ "SOUTHERN DISTRICT REPORTERS, P.C." ], "locations": [ "Mar-a-Lago" ], "dates": [ "08/10/22" ], "reference_numbers": [ "1:20-cr-00330-PAE", "751", "DOJ-OGR-00013005" ] }, "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage." }