{
  "document_metadata": {
    "page_number": "1",
    "document_number": "521",
    "date": "December 3, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 521 Filed 12/03/21 Page 1 of 5\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 3, 2021\nVIA ECF\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,\nDuring her cross-examination, Jane denied knowing that cooperating with the government in the prosecution of Ms. Maxwell and testifying against her would help her civil case against Ms. Maxwell and her claim for compensation from the Epstein Victims' Compensation Program (EVCP). Because Jane denied having this knowledge, Ms. Maxwell has a constitutional right to call Jane's attorney (Robert Glassman) as a witness and to ask him whether he told Jane that cooperating and testifying against her would \"help her case.\" U.S. Const. amends. V, VI. This issue is relevant to Jane's motive to cooperate and testify,1 and it's\n1 Davis v. Alaska, 415 U.S. 308, 316 (1974) (\"A more particular attack on the witness' credibility is effected by means of cross-examination directed toward revealing possible biases, prejudices, or ulterior motives of the witness as they may relate directly to issues or personalities in the case at hand. The partiality of a witness is subject to exploration at trial, and is always relevant as discrediting the witness and affecting the weight of his testimony.\" (quotation omitted)).\nDOJ-OGR-00008206",
  "text_blocks": [
    {
      "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 3, 2021\nVIA ECF\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": "During her cross-examination, Jane denied knowing that cooperating with the government in the prosecution of Ms. Maxwell and testifying against her would help her civil case against Ms. Maxwell and her claim for compensation from the Epstein Victims' Compensation Program (EVCP). Because Jane denied having this knowledge, Ms. Maxwell has a constitutional right to call Jane's attorney (Robert Glassman) as a witness and to ask him whether he told Jane that cooperating and testifying against her would \"help her case.\" U.S. Const. amends. V, VI. This issue is relevant to Jane's motive to cooperate and testify,1 and it's",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 Davis v. Alaska, 415 U.S. 308, 316 (1974) (\"A more particular attack on the witness' credibility is effected by means of cross-examination directed toward revealing possible biases, prejudices, or ulterior motives of the witness as they may relate directly to issues or personalities in the case at hand. The partiality of a witness is subject to exploration at trial, and is always relevant as discrediting the witness and affecting the weight of his testimony.\" (quotation omitted)).",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008206",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey S. Pagliuca",
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jane",
      "Robert Glassman"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Epstein Victims' Compensation Program"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "December 3, 2021",
      "1974"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 521",
      "20 Cr. 330 (AJN)",
      "415 U.S. 308",
      "DOJ-OGR-00008206"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from a law firm to a judge, discussing a legal case involving Ghislaine Maxwell. The text is well-formatted and printed, with no visible handwriting or stamps. The document includes a reference to a specific court case and legal precedents."
}