mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00008276.json

{
  "document_metadata": {
    "page_number": "4",
    "document_number": "533",
    "date": "12/09/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 533 Filed 12/09/21 Page 4 of 8\nthe name of Sarah Kellen, who began working for Epstein shortly before Alessi left his employment. Tr. at 832; see Fed. R. Evid. 901(b)(4) (permitting authentication based on the \"contents\" of the item). Alessi recognized Government Exhibit 52 as a book that belonged to Epstein and Maxwell, consistent with his experience working for them.\nThe defendant's challenge to Alessi's foundation rested largely on Alessi's lack of knowledge of the origins of Government Exhibit 52. (See id. at 872-73, 875 \"The bottom line here, Mr. Alessi, you don't have any personal knowledge about first how or when Exhibit 52 was created; correct?\"). 1 But authentication does not require evidence about the circumstances of the creation or seizure of a piece of evidence, so long as it can be identified by its distinctive markings as what the proponent claims it is. See Al Farekh, 810 F. App'x at 24-25. It is well settled that defects in chain of custody go to weight and not admissibility.\nSecond, the household manual—dating from 2005, the year on Government Exhibit 52— demonstrates that the practice identified by Alessi remained in operation into 2005. The manual explains that \"[t]elephone directories are to be updated every six months, or as the new telephone directories are available.\" GX 606 at 7. And it explained that the directories in fact belong to the defendant and Epstein: a copy of their directories \"must be placed to the right of each telephone (except for the Guestrooms).\" GX 606 at 7.\nThird, the contents of Government Exhibit 52 have been confirmed by other evidence to accurately reflect relationships between the defendant and other individuals. See United States v. Prevezon Holdings, Ltd., 319 F.R.D. 459, 463 (S.D.N.Y. 2017) (permitting authentication under\n1 Defense counsel also pointed to the additional markings that may have been added by Rodriguez or the FBI. Tr. at 872-73, 875. These markings are non-substantive on any page which the Government is offering, as explained in a prior brief. (Dkt. No. 491 at 4-5).\nDOJ-OGR-00008276",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 533 Filed 12/09/21 Page 4 of 8",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "the name of Sarah Kellen, who began working for Epstein shortly before Alessi left his employment. Tr. at 832; see Fed. R. Evid. 901(b)(4) (permitting authentication based on the \"contents\" of the item). Alessi recognized Government Exhibit 52 as a book that belonged to Epstein and Maxwell, consistent with his experience working for them.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The defendant's challenge to Alessi's foundation rested largely on Alessi's lack of knowledge of the origins of Government Exhibit 52. (See id. at 872-73, 875 \"The bottom line here, Mr. Alessi, you don't have any personal knowledge about first how or when Exhibit 52 was created; correct?\"). 1 But authentication does not require evidence about the circumstances of the creation or seizure of a piece of evidence, so long as it can be identified by its distinctive markings as what the proponent claims it is. See Al Farekh, 810 F. App'x at 24-25. It is well settled that defects in chain of custody go to weight and not admissibility.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Second, the household manual—dating from 2005, the year on Government Exhibit 52— demonstrates that the practice identified by Alessi remained in operation into 2005. The manual explains that \"[t]elephone directories are to be updated every six months, or as the new telephone directories are available.\" GX 606 at 7. And it explained that the directories in fact belong to the defendant and Epstein: a copy of their directories \"must be placed to the right of each telephone (except for the Guestrooms).\" GX 606 at 7.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Third, the contents of Government Exhibit 52 have been confirmed by other evidence to accurately reflect relationships between the defendant and other individuals. See United States v. Prevezon Holdings, Ltd., 319 F.R.D. 459, 463 (S.D.N.Y. 2017) (permitting authentication under",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 Defense counsel also pointed to the additional markings that may have been added by Rodriguez or the FBI. Tr. at 872-73, 875. These markings are non-substantive on any page which the Government is offering, as explained in a prior brief. (Dkt. No. 491 at 4-5).",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008276",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Sarah Kellen",
      "Alessi",
      "Epstein",
      "Maxwell",
      "Rodriguez"
    ],
    "organizations": [
      "FBI"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "12/09/21",
      "2005"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 533",
      "GX 606",
      "Dkt. No. 491",
      "DOJ-OGR-00008276"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving Epstein and Maxwell. The text discusses the authentication of Government Exhibit 52 and the testimony of Alessi. The document is well-formatted and free of significant damage or redactions."
}