mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00008270.json

{
  "document_metadata": {
    "page_number": "6",
    "document_number": "532",
    "date": "December 8, 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 6 of 8\nThe Honorable Alison J. Nathan December 8, 2021 Page 6\nId. at 331. The government's attempt to authenticate Exhibit 52 through Ms. Maxwell's testimony about something else entirely fails.\nThe flaws in the government's argument don't end with these two problems, though each problem itself is dispositive of the government's request. The government's letter focuses exclusively on the authentication question. The government does not address the business records exception or even attempt to justify the admission of Exhibit 52 despite it being hearsay.\nThe government also conveniently ignores all it said before about why Exhibit 52 was relevant and how it would be admitted and used as evidence. The government first said Exhibit 52 was Ms. Maxwell's book. That was the entire premise of the government's November 12 letter and its opposition to Ms. Maxwell's motion in limine. But no witness has testified that it was Ms. Maxwell's book, and the government has abandoned that argument.1\nThe government next said it would call Employee-1 as a witness to authenticate the exhibit and lay the foundation for its admission and, in turn, to testify that Exhibit 52 belonged to Ms. Maxwell. But no more. The government's decision not to call Employee-1 confirms what Ms. Maxwell has been saying all along: Exhibit 52 did not belong to her, and Employee-1 was never going to testify that it did.\nFinally, it would be exceedingly unfair were the government to admit Exhibit 52 at this late stage in its case, having now abandoned its earlier arguments for admissibility and relevance.\nAs this Court recognized earlier today, Mr. Alessi is done testifying, and Ms. Maxwell cannot be\n1 We know the government has abandoned this argument because it relies on Ms. Maxwell's deposition testimony as the basis for admitting Exhibit 52. But in that testimony, Ms. Maxwell unequivocally denied being the owner of or responsible for Deposition Exhibit 13.\nDOJ-OGR-00008270",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 532 Filed 12/09/21 Page 6 of 8",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan December 8, 2021 Page 6",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Id. at 331. The government's attempt to authenticate Exhibit 52 through Ms. Maxwell's testimony about something else entirely fails.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The flaws in the government's argument don't end with these two problems, though each problem itself is dispositive of the government's request. The government's letter focuses exclusively on the authentication question. The government does not address the business records exception or even attempt to justify the admission of Exhibit 52 despite it being hearsay.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government also conveniently ignores all it said before about why Exhibit 52 was relevant and how it would be admitted and used as evidence. The government first said Exhibit 52 was Ms. Maxwell's book. That was the entire premise of the government's November 12 letter and its opposition to Ms. Maxwell's motion in limine. But no witness has testified that it was Ms. Maxwell's book, and the government has abandoned that argument.1",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government next said it would call Employee-1 as a witness to authenticate the exhibit and lay the foundation for its admission and, in turn, to testify that Exhibit 52 belonged to Ms. Maxwell. But no more. The government's decision not to call Employee-1 confirms what Ms. Maxwell has been saying all along: Exhibit 52 did not belong to her, and Employee-1 was never going to testify that it did.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Finally, it would be exceedingly unfair were the government to admit Exhibit 52 at this late stage in its case, having now abandoned its earlier arguments for admissibility and relevance.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As this Court recognized earlier today, Mr. Alessi is done testifying, and Ms. Maxwell cannot be",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 We know the government has abandoned this argument because it relies on Ms. Maxwell's deposition testimony as the basis for admitting Exhibit 52. But in that testimony, Ms. Maxwell unequivocally denied being the owner of or responsible for Deposition Exhibit 13.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008270",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell",
      "Mr. Alessi",
      "Employee-1"
    ],
    "organizations": [
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "December 8, 2021",
      "November 12"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 532",
      "Exhibit 52",
      "Deposition Exhibit 13",
      "DOJ-OGR-00008270"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 6 of an 8-page document."
}