{
  "document_metadata": {
    "page_number": "3",
    "document_number": "532",
    "date": "December 9, 2021",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 532 Filed 12/09/21 Page 3 of 8\nThe Honorable Alison J. Nathan\nDecember 8, 2021\nPage 3\n(D) all these conditions are shown by the testimony of the custodian or another qualified witness, or by a certification that complies with Rule 902(11) or (12) or with a statute permitting certification; and\n(E) the opponent does not show that the source of information or the method or circumstances of preparation indicate a lack of trustworthiness.\nFed. R. Evid. 803(6).\nPages 3 to 6 of the government's letter rehash arguments the government has already made and this Court has already rejected. Ms. Maxwell will not repeat here why these arguments fail. (Ms. Maxwell incorporates those arguments by reference.)\nWhat's new is the government's attempt to rely on Ms. Maxwell's April 2016 deposition testimony and in particular the questions she was asked and the answers she gave concerning Deposition Exhibit 13. The government's reliance is not persuasive.\nFirst, Deposition Exhibit 13 is not the same thing as Exhibit 52. Deposition Exhibit 13 is a photocopy of some pages of some document. There is no explanation from where the photocopy came, when it was made, who made it, what it purports to be a copy of, whether it is a complete copy, or whether it is an accurate copy. Whatever it is, it is not a copy of Exhibit 52. (It has, for example, several handwritten pages that aren't contained in the government's trial exhibit.) Quite simply, Ms. Maxwell was not asked and did not testify about Exhibit 52 or its authenticity.\nThis is no trivial matter. As Mr. Alessi explained in testimony this Court deemed inadequate to authenticate the exhibit, Exhibit 52 is not the same as the books he saw during his employment with Mr. Epstein. The books in use when he was an employee were two inches thick. Exhibit 52 is 1/4 inch thick.\nDOJ-OGR-00008267",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 532 Filed 12/09/21 Page 3 of 8",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nDecember 8, 2021\nPage 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "(D) all these conditions are shown by the testimony of the custodian or another qualified witness, or by a certification that complies with Rule 902(11) or (12) or with a statute permitting certification; and\n(E) the opponent does not show that the source of information or the method or circumstances of preparation indicate a lack of trustworthiness.\nFed. R. Evid. 803(6).",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Pages 3 to 6 of the government's letter rehash arguments the government has already made and this Court has already rejected. Ms. Maxwell will not repeat here why these arguments fail. (Ms. Maxwell incorporates those arguments by reference.)",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "What's new is the government's attempt to rely on Ms. Maxwell's April 2016 deposition testimony and in particular the questions she was asked and the answers she gave concerning Deposition Exhibit 13. The government's reliance is not persuasive.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "First, Deposition Exhibit 13 is not the same thing as Exhibit 52. Deposition Exhibit 13 is a photocopy of some pages of some document. There is no explanation from where the photocopy came, when it was made, who made it, what it purports to be a copy of, whether it is a complete copy, or whether it is an accurate copy. Whatever it is, it is not a copy of Exhibit 52. (It has, for example, several handwritten pages that aren't contained in the government's trial exhibit.) Quite simply, Ms. Maxwell was not asked and did not testify about Exhibit 52 or its authenticity.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "This is no trivial matter. As Mr. Alessi explained in testimony this Court deemed inadequate to authenticate the exhibit, Exhibit 52 is not the same as the books he saw during his employment with Mr. Epstein. The books in use when he was an employee were two inches thick. Exhibit 52 is 1/4 inch thick.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008267",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell",
      "Mr. Alessi",
      "Mr. Epstein"
    ],
    "organizations": [
      "Court"
    ],
    "locations": [],
    "dates": [
      "December 8, 2021",
      "April 2016",
      "December 9, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 532",
      "Exhibit 13",
      "Exhibit 52",
      "DOJ-OGR-00008267"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is well-formatted and legible. There are no visible redactions or damages."
}