mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011283.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "709",
    "date": "November 15, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 709 Filed 07/12/22 Page 1 of 5\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\n\nNovember 15, 2021\n\nVIA EMAIL\n\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\n\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\n\nDear Judge Nathan,\n\nPursuant to the Court's November 1, 2021, Order we write in response to the government's letter of November 12, 2021 to note our good faith objections to categories of alleged co-conspirator hearsay statements and representative examples1:\n\nCategory 2, \"Statements made by Jeffrey Epstein to his employees\" appears to relate primarily to statements that post-date any alleged conspiracy. The last overt act alleged in the S-2\n\n1 In its November 12, 2021 letter to the Court, the government apparently misunderstands, and overstates, its understanding of the Defendant's position regarding the proffered statements. To be clear, Ms. Maxwell is not agreeing to the admission of any statements proffered by the government under Fed. R. Evid. 801(d)(2)(E) for many reasons including the fact that she was not a member of any conspiracy as alleged in the indictment. Ms. Maxwell understood that, in her conferral letter to the government, she was identifying her good faith objections given established Second Circuit procedures governing the admissibility of the proffered statements. Ms. Maxwell will object, at trial, to any proffered statement when appropriate.\n\nDOJ-OGR-00011283",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 709 Filed 07/12/22 Page 1 of 5",
      "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": "November 15, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA EMAIL",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan,",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Pursuant to the Court's November 1, 2021, Order we write in response to the government's letter of November 12, 2021 to note our good faith objections to categories of alleged co-conspirator hearsay statements and representative examples1:\n\nCategory 2, \"Statements made by Jeffrey Epstein to his employees\" appears to relate primarily to statements that post-date any alleged conspiracy. The last overt act alleged in the S-2",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 In its November 12, 2021 letter to the Court, the government apparently misunderstands, and overstates, its understanding of the Defendant's position regarding the proffered statements. To be clear, Ms. Maxwell is not agreeing to the admission of any statements proffered by the government under Fed. R. Evid. 801(d)(2)(E) for many reasons including the fact that she was not a member of any conspiracy as alleged in the indictment. Ms. Maxwell understood that, in her conferral letter to the government, she was identifying her good faith objections given established Second Circuit procedures governing the admissibility of the proffered statements. Ms. Maxwell will object, at trial, to any proffered statement when appropriate.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011283",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey S. Pagliuca",
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jeffrey Epstein"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "November 15, 2021",
      "November 1, 2021",
      "November 12, 2021",
      "07/12/22"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00011283"
    ]
  },
  "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 November 15, 2021, and is in response to a government letter dated November 12, 2021. The document is well-formatted and legible."
}