{
  "document_metadata": {
    "page_number": "1",
    "document_number": "532",
    "date": "December 8, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 532 Filed 12/09/21 Page 1 of 8\nHaddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com\nDecember 8, 2021\nVIA Email\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan,\nThis is at least the third attempt by the government to admit an unreliable exhibit of unknown origin. The problems are manifold, as this Court is aware.\nWhen the government last sought admission, after the testimony of Juan Alessi, this Court reserved ruling, recognizing that Mr. Alessi had neither authenticated Exhibit 52 nor laid the required foundation for its admission under Rule 803(6).\nRest assured, promised the government, it would fill in the blanks through the testimony of Employee-1. But the government no longer plans to call Employee-1 as a witness, so it's left with a record this Court already deemed inadequate to justify admission of the exhibit.\nUndeterred, the government now, for the very first time, points to something else—Ms. Maxwell's April 2016 civil deposition. The government claims that Ms. Maxwell's deposition testimony authenticates Exhibit 52.\nThe government is wrong, for at least two obvious reasons. First, the exhibit Ms. Maxwell was shown in her deposition (Deposition Exhibit 13) is not the same thing as Exhibit 52.\nDOJ-OGR-00008265",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 532 Filed 12/09/21 Page 1 of 8",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Haddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "December 8, 2021\nVIA Email\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan,",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "This is at least the third attempt by the government to admit an unreliable exhibit of unknown origin. The problems are manifold, as this Court is aware.\nWhen the government last sought admission, after the testimony of Juan Alessi, this Court reserved ruling, recognizing that Mr. Alessi had neither authenticated Exhibit 52 nor laid the required foundation for its admission under Rule 803(6).\nRest assured, promised the government, it would fill in the blanks through the testimony of Employee-1. But the government no longer plans to call Employee-1 as a witness, so it's left with a record this Court already deemed inadequate to justify admission of the exhibit.\nUndeterred, the government now, for the very first time, points to something else—Ms. Maxwell's April 2016 civil deposition. The government claims that Ms. Maxwell's deposition testimony authenticates Exhibit 52.\nThe government is wrong, for at least two obvious reasons. First, the exhibit Ms. Maxwell was shown in her deposition (Deposition Exhibit 13) is not the same thing as Exhibit 52.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008265",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey S. Pagliuca",
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Juan Alessi"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "December 8, 2021",
      "April 2016"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "Document 532",
      "Exhibit 52",
      "Deposition Exhibit 13",
      "DOJ-OGR-00008265"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from a law firm to a judge regarding a court case. The text is well-formatted and printed, with no visible handwriting or stamps."
}