mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00008425.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "553",
    "date": "December 16, 2021",
    "document_type": "Letter",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 553 Filed 12/17/21 Page 1 of 3\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 16, 2021\nVIA Email\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 this Court's order.\nAs to the first question, federal law is clear. \"No longer, when a lawyer asks a witness whether he made a certain statement, written or not, is the lawyer required (as he was at common law, see Note of Advisory Committee to Fed.R.Evid. 613(a)) to show the statement or disclose its contents to the witness, though he must upon request show it to opposing counsel.\" United States v. Marks, 816 F.2d 1207, 1210 (7th Cir. 1986) (Posner, J.).\nAs to the second question a statement provable by extrinsic evidence even though the witness affirms that the 3500 material contains the inconsistent statement and also expresses disagreement with the substance. By disagreeing with the substance, the witness has logically and necessarily denied making the statement (or failed to remember making the statement).\nThus, under Rule 613, the statement is inconsistent because it has \"under any rational theory it might lead to any relevant conclusion different from any other relevant conclusion resulting from anything the witness said.\" United States v. Barile, 286 F.3d 749, 755 (4th Cir. 2002)\nDOJ-OGR-00008425",
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      "content": "Case 1:20-cr-00330-PAE Document 553 Filed 12/17/21 Page 1 of 3",
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    {
      "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"
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    {
      "type": "printed",
      "content": "December 16, 2021\nVIA Email\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"
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    {
      "type": "printed",
      "content": "I write in response to this Court's order.\nAs to the first question, federal law is clear. \"No longer, when a lawyer asks a witness whether he made a certain statement, written or not, is the lawyer required (as he was at common law, see Note of Advisory Committee to Fed.R.Evid. 613(a)) to show the statement or disclose its contents to the witness, though he must upon request show it to opposing counsel.\" United States v. Marks, 816 F.2d 1207, 1210 (7th Cir. 1986) (Posner, J.).\nAs to the second question a statement provable by extrinsic evidence even though the witness affirms that the 3500 material contains the inconsistent statement and also expresses disagreement with the substance. By disagreeing with the substance, the witness has logically and necessarily denied making the statement (or failed to remember making the statement).\nThus, under Rule 613, the statement is inconsistent because it has \"under any rational theory it might lead to any relevant conclusion different from any other relevant conclusion resulting from anything the witness said.\" United States v. Barile, 286 F.3d 749, 755 (4th Cir. 2002)",
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  "entities": {
    "people": [
      "Jeffrey S. Pagliuca",
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Posner, J."
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "December 16, 2021",
      "12/17/21"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 553",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00008425"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from a law firm to a judge, discussing legal matters related to a court case. The text is well-formatted and clear, with no visible redactions or damage."
}