mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00008225.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "525",
    "date": "December 5, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 525 Filed 12/05/21 Page 1 of 9\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 5, 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,\nI write in response to the government's December 4, 2021 letter—the latest example of the government's inability to take no for an answer. This is the government's modus operandi. It disagrees with the Court's ruling and seeks to relitigate the issue under the guise of uncertainty (either the government claims not to understand, or the Court wasn't clear enough) or confusion (the Court didn't understand the government's argument). But isn't any uncertainty or confusion here. The government has, so far, failed to authenticate the 900 series photos, and unless it does, the photos are irrelevant under Rule 401 and misleading and prejudicial under Rule 403. This Court should reaffirm its ruling from December 3.\nBACKGROUND\nThe 900 series of photos depict the exterior and portions of the interior of Mr. Epstein's New York apartment as it existed in 2019. That much the government can show.\nBut the government has admitted no testimony that the 2019 photographs accurately depict the interior of Mr. Epstein's apartment as it existed in 1994 or 1995 or 1996 (when Jane\nDOJ-OGR-00008225",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 525 Filed 12/05/21 Page 1 of 9",
      "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": "December 5, 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": "I write in response to the government's December 4, 2021 letter—the latest example of the government's inability to take no for an answer. This is the government's modus operandi. It disagrees with the Court's ruling and seeks to relitigate the issue under the guise of uncertainty (either the government claims not to understand, or the Court wasn't clear enough) or confusion (the Court didn't understand the government's argument). But isn't any uncertainty or confusion here. The government has, so far, failed to authenticate the 900 series photos, and unless it does, the photos are irrelevant under Rule 401 and misleading and prejudicial under Rule 403. This Court should reaffirm its ruling from December 3.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "BACKGROUND\nThe 900 series of photos depict the exterior and portions of the interior of Mr. Epstein's New York apartment as it existed in 2019. That much the government can show.\nBut the government has admitted no testimony that the 2019 photographs accurately depict the interior of Mr. Epstein's apartment as it existed in 1994 or 1995 or 1996 (when Jane",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008225",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey S. Pagliuca",
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Mr. Epstein",
      "Jane"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "December 5, 2021",
      "December 4, 2021",
      "December 3",
      "2019",
      "1994",
      "1995",
      "1996"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00008225"
    ]
  },
  "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 is dated December 5, 2021, and is in response to a government letter dated December 4, 2021. The document is a printed letter with no handwritten text or stamps."
}