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    "page_number": "92",
    "document_number": "465",
    "date": "11/15/21",
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  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 92 of 127 92 LB1 TMAX3\ncame from or how it was created.\nThe government says that it has a witness that is going to say that that was Ms. Maxwell's book. I'm highly suspect of that to begin with. And secondarily, that witness wasn't around in 2004. And so we have now two witnesses for this purported foundation, both of whom were not employed during the relevant timeframe of the conspiracy. So I'm at a loss, frankly, to understand how anyone could either authenticate that document or admit it as some non-hearsay document.\nThe government says well, even if it's not admissible, then they will say as a business record -- the government says we'll admit it for some other purpose, which I don't know what that is. And if they're admitting it for another purpose, I don't understand the relevance of this, given the inability to establish a foundation and to tie it with any alleged conduct that is part of the indictment in this case.\nSo I don't think we can just leave this here and then have a discussion about this in the middle of trial. And it seems to me that in this type of hearing, a pretrial hearing, the government should say here's the witness that is going to authenticate it, here's how they're going to authenticate it, that is what we're authenticating it for, here are the pages that we think are relevant and here's why.\nWe don't have anything of that information. We are\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007143",
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    {
      "type": "printed",
      "content": "came from or how it was created.\nThe government says that it has a witness that is going to say that that was Ms. Maxwell's book. I'm highly suspect of that to begin with. And secondarily, that witness wasn't around in 2004. And so we have now two witnesses for this purported foundation, both of whom were not employed during the relevant timeframe of the conspiracy. So I'm at a loss, frankly, to understand how anyone could either authenticate that document or admit it as some non-hearsay document.\nThe government says well, even if it's not admissible, then they will say as a business record -- the government says we'll admit it for some other purpose, which I don't know what that is. And if they're admitting it for another purpose, I don't understand the relevance of this, given the inability to establish a foundation and to tie it with any alleged conduct that is part of the indictment in this case.\nSo I don't think we can just leave this here and then have a discussion about this in the middle of trial. And it seems to me that in this type of hearing, a pretrial hearing, the government should say here's the witness that is going to authenticate it, here's how they're going to authenticate it, that is what we're authenticating it for, here are the pages that we think are relevant and here's why.\nWe don't have anything of that information. We are",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00007143",
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  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "11/15/21",
      "2004"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 465",
      "DOJ-OGR-00007143"
    ]
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  "additional_notes": "The document appears to be a court transcript with a clear and readable format. There are no visible redactions or damage."
}