{
  "document_metadata": {
    "page_number": "1",
    "document_number": "490",
    "date": "November 15, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 490 Filed 11/22/21 Page 1 of 3\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\n\nNovember 15, 2021\n\nVIA EMAIL\n\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\n\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\n\nDear Judge Nathan,\n\nThere are two fundamental flaws with the government's evidentiary proffer regarding proposed Exhibit 52. First, as a matter of fact, Government Exhibit 52 was not something that the cooperating government witness reviewed, used, or saw during her brief employment with Jeffrey Epstein. Records produced in discovery reflect that witness began working for Epstein in\n\nAt that point, the suspect source of Government Exhibit 52, Alfredo Rodriguez, was not employed by Epstein because he had been fired in 2004.\n\nAccording to Mr. Rodriguez, when he left the Epstein home he took an address book, which he claimed was Epstein's book, and had it in his possession until 2009 when he tried to sell it to Brad Edwards for $50,000.1 The book was clearly altered by Mr. Rodriguez. The single\n\n1 Mr. Rodriguez knew the target of his intended sale which makes the likelihood of alteration all the more probable. Mr. Edwards was a lawyer with of the Fort Lauderdale law firm of Rothstein Rosenfelt Adler. The firm was under investigation by the U.S. Attorney for the\n\nDOJ-OGR-00007409",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 490 Filed 11/22/21 Page 1 of 3",
      "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": "November 15, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA EMAIL",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan,",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "There are two fundamental flaws with the government's evidentiary proffer regarding proposed Exhibit 52. First, as a matter of fact, Government Exhibit 52 was not something that the cooperating government witness reviewed, used, or saw during her brief employment with Jeffrey Epstein. Records produced in discovery reflect that witness began working for Epstein in",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "At that point, the suspect source of Government Exhibit 52, Alfredo Rodriguez, was not employed by Epstein because he had been fired in 2004.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "According to Mr. Rodriguez, when he left the Epstein home he took an address book, which he claimed was Epstein's book, and had it in his possession until 2009 when he tried to sell it to Brad Edwards for $50,000.1 The book was clearly altered by Mr. Rodriguez. The single",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 Mr. Rodriguez knew the target of his intended sale which makes the likelihood of alteration all the more probable. Mr. Edwards was a lawyer with of the Fort Lauderdale law firm of Rothstein Rosenfelt Adler. The firm was under investigation by the U.S. Attorney for the",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00007409",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey S. Pagliuca",
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jeffrey Epstein",
      "Alfredo Rodriguez",
      "Brad Edwards"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York",
      "Rothstein Rosenfelt Adler"
    ],
    "locations": [
      "Denver, Colorado",
      "New York, NY",
      "Fort Lauderdale"
    ],
    "dates": [
      "November 15, 2021",
      "11/22/21",
      "2004",
      "2009"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 490",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00007409"
    ]
  },
  "additional_notes": "The document appears to be a letter from Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses the government's evidentiary proffer and highlights two fundamental flaws with proposed Exhibit 52."
}