{
  "document_metadata": {
    "page_number": "5",
    "document_number": "457",
    "date": "11/13/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 457 Filed 11/13/21 Page 5 of 8 Page 5 seizure of the USB drive, Federal Rule of Evidence 901(b)(4) permits authentication based on '[t]he appearance, contents, substance, internal patterns, or other distinctive characteristics of the item, taken together with all the circumstances.' Id. (alteration in original) (quoting Fed. R. Evid 901(b)(4)). Witness testimony about the content of the letters was 'sufficient to pass the relatively low bar for authentication of evidence,' and the Second Circuit explained that 'any remaining questions as to the reliability of the letters go to their evidentiary weight, not their admissibility.' Id. at 24-25; see United States v. Bagaric, 706 F.2d 42, 67 (2d Cir. 1983), abrogated on other grounds by Nat'l Org. for Women, Inc. v. Scheidler, 510 U.S. 249 (1994) (letter's contents were sufficient to authenticate it under Rule 901(b)(4)). The same is true here. Employee-1 will identify Government Exhibit 52 as the defendant's contact book based on its appearance and contents. Moreover, Employee-1's testimony will be corroborated by the contents of the book itself, which includes (a) contact information for the defendant's family, and (b) contact information for victims who interacted with the defendant during the relevant time period. That is more than sufficient to establish the authenticity of the exhibit under Rule 901. To the extent the defense disputes Employee-1's testimony, or takes issue with the circumstances under which Government Exhibit 52 came into the Government's possession,3 those arguments are for the jury. The anticipated testimony satisfies Rule 901, and the evidence should be admitted. 3 It is a matter of public record that in 2009, an employee of Jeffrey Epstein, Alfredo Rodriguez, attempted to sell Government Exhibit 52 to a plaintiff's attorney. The attorney contacted the Federal Bureau of Investigation, and agents seized Government Exhibit 52 from Rodriguez, who was arrested. Rodriguez has stated that he took the book from Epstein's Palm Beach residence during his employment for Epstein from 2004 to early 2005. Government Exhibit 52 has remained in the possession of the FBI since that time. Rodriguez pleaded guilty to obstruction of justice and acknowledged that he was obligated to turn this evidence over to the FBI years earlier, when he was interviewed during the course of the FBI's investigation of Epstein. See United States v. Alfredo Rodriguez, 10 Cr. 80015 (KAM). Rodriguez passed away following the conclusion of the DOJ-OGR-00006967",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 457 Filed 11/13/21 Page 5 of 8",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 5 seizure of the USB drive, Federal Rule of Evidence 901(b)(4) permits authentication based on '[t]he appearance, contents, substance, internal patterns, or other distinctive characteristics of the item, taken together with all the circumstances.' Id. (alteration in original) (quoting Fed. R. Evid 901(b)(4)). Witness testimony about the content of the letters was 'sufficient to pass the relatively low bar for authentication of evidence,' and the Second Circuit explained that 'any remaining questions as to the reliability of the letters go to their evidentiary weight, not their admissibility.' Id. at 24-25; see United States v. Bagaric, 706 F.2d 42, 67 (2d Cir. 1983), abrogated on other grounds by Nat'l Org. for Women, Inc. v. Scheidler, 510 U.S. 249 (1994) (letter's contents were sufficient to authenticate it under Rule 901(b)(4)). The same is true here. Employee-1 will identify Government Exhibit 52 as the defendant's contact book based on its appearance and contents. Moreover, Employee-1's testimony will be corroborated by the contents of the book itself, which includes (a) contact information for the defendant's family, and (b) contact information for victims who interacted with the defendant during the relevant time period. That is more than sufficient to establish the authenticity of the exhibit under Rule 901. To the extent the defense disputes Employee-1's testimony, or takes issue with the circumstances under which Government Exhibit 52 came into the Government's possession,3 those arguments are for the jury. The anticipated testimony satisfies Rule 901, and the evidence should be admitted.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "3 It is a matter of public record that in 2009, an employee of Jeffrey Epstein, Alfredo Rodriguez, attempted to sell Government Exhibit 52 to a plaintiff's attorney. The attorney contacted the Federal Bureau of Investigation, and agents seized Government Exhibit 52 from Rodriguez, who was arrested. Rodriguez has stated that he took the book from Epstein's Palm Beach residence during his employment for Epstein from 2004 to early 2005. Government Exhibit 52 has remained in the possession of the FBI since that time. Rodriguez pleaded guilty to obstruction of justice and acknowledged that he was obligated to turn this evidence over to the FBI years earlier, when he was interviewed during the course of the FBI's investigation of Epstein. See United States v. Alfredo Rodriguez, 10 Cr. 80015 (KAM). Rodriguez passed away following the conclusion of the",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006967",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein",
      "Alfredo Rodriguez",
      "Employee-1"
    ],
    "organizations": [
      "Federal Bureau of Investigation"
    ],
    "locations": [
      "Palm Beach"
    ],
    "dates": [
      "11/13/21",
      "2004",
      "2005",
      "2009"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 457",
      "10 Cr. 80015 (KAM)",
      "DOJ-OGR-00006967"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case United States v. [defendant's name]. The text discusses the authentication of evidence under Federal Rule of Evidence 901(b)(4) and the admissibility of Government Exhibit 52, a contact book belonging to the defendant. The document includes citations to relevant case law and statutory authority."
}