{
  "document_metadata": {
    "page_number": "74 of 84",
    "document_number": "397",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 74 of 84\n\nFirst, the defendant moves to exclude Government Exhibit 52, which it says was obtained by the Government \"as part of discovery in Guiffre v. Maxwell civil litigation . . . with no explanation about its origin.\" (Def. Mot. 7 at 1). The defendant misidentifies the exhibit. Government Exhibit 52 is a physical contact book belonging to the defendant. The records attached by the defense as Exhibit 1 appear to be a scan of Government Exhibit 52 that was produced in discovery in Giuffre v. Maxwell. But the Government will not offer that scan at trial. It will offer the physical book itself, along with scans taken by the Government of the physical book. A witness with personal knowledge of the physical book is expected to testify to its authenticity.\n\nThe defendant takes issue with the history of the Government's acquisition of Government Exhibit 52. The defendant is correct that the Government came into custody of this exhibit after a former employee of Jeffrey Epstein attempted to sell it to a civil lawyer suing Epstein. (Id.). The defense calls this \"particularly troubling\" (Def. Mot. 7 at 2), but that argument is misplaced. How the Government acquired the exhibit goes, if anything, to its weight and not its admissibility. If a witness can identify the exhibit based on its contents, that is sufficient to pass the relatively low bar for authentication of evidence.\" See Al Farekh, 810 F. App'x at 24-25.\n\nFinally, the defendant argues that the contents of Government Exhibit 52 are hearsay because they are not a business record. (Def. Mot. 7 at 4-6). The exhibit is separately admissible not for the truth of the matters asserted therein (such as the accuracy of the contact information for victims), but to establish that the defendant kept contact information for relevant individuals at trial, including victims. The exhibit has evidentiary value in showing that the defendant\n\n73\n\nDOJ-OGR-00005857",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 74 of 84",
      "position": "header"
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    {
      "type": "printed",
      "content": "First, the defendant moves to exclude Government Exhibit 52, which it says was obtained by the Government \"as part of discovery in Guiffre v. Maxwell civil litigation . . . with no explanation about its origin.\" (Def. Mot. 7 at 1). The defendant misidentifies the exhibit. Government Exhibit 52 is a physical contact book belonging to the defendant. The records attached by the defense as Exhibit 1 appear to be a scan of Government Exhibit 52 that was produced in discovery in Giuffre v. Maxwell. But the Government will not offer that scan at trial. It will offer the physical book itself, along with scans taken by the Government of the physical book. A witness with personal knowledge of the physical book is expected to testify to its authenticity.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The defendant takes issue with the history of the Government's acquisition of Government Exhibit 52. The defendant is correct that the Government came into custody of this exhibit after a former employee of Jeffrey Epstein attempted to sell it to a civil lawyer suing Epstein. (Id.). The defense calls this \"particularly troubling\" (Def. Mot. 7 at 2), but that argument is misplaced. How the Government acquired the exhibit goes, if anything, to its weight and not its admissibility. If a witness can identify the exhibit based on its contents, that is sufficient to pass the relatively low bar for authentication of evidence.\" See Al Farekh, 810 F. App'x at 24-25.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Finally, the defendant argues that the contents of Government Exhibit 52 are hearsay because they are not a business record. (Def. Mot. 7 at 4-6). The exhibit is separately admissible not for the truth of the matters asserted therein (such as the accuracy of the contact information for victims), but to establish that the defendant kept contact information for relevant individuals at trial, including victims. The exhibit has evidentiary value in showing that the defendant",
      "position": "middle"
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    {
      "type": "printed",
      "content": "73",
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    {
      "type": "printed",
      "content": "DOJ-OGR-00005857",
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  ],
  "entities": {
    "people": [
      "Jeffrey Epstein"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 397",
      "Government Exhibit 52",
      "Def. Mot. 7",
      "Al Farekh, 810 F. App'x at 24-25",
      "DOJ-OGR-00005857"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 74 of 84."
}