mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011345.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "721",
    "date": "07/12/22",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 721 Filed 07/12/22 Page 1 of 9 Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagliuca@hmflaw.com December 14, 2021 VIA Email The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, I write under Rules of Evidence 608 and 403 to request that this Court preclude cross-examination of by the government concerning a regulatory settlement agreement involving Mr. related to , twenty years after the real estate transaction reflected in the documents he will serve as a foundational witness to admit. Mr. is a retired British Solicitor who represented Ms. Maxwell in the purchase of 44 Kinnerton Street, London SW1. The government has refused to stipulate to the admission of the 1996 Agreement for Sale for 44 Kinnerton Street and other related title documents, which show that Ms. Maxwell did not contract to purchase 44 Kinnerton Street until December 1996 (and did not complete the purchase until January 1997), long after Kate claims she engaged in a sexualized massage with Jeffrey Epstein in that residence. As a result, although the government does not contest the authenticity or relevance of these records, Ms. Maxwell DOJ-OGR-00011345",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 721 Filed 07/12/22 Page 1 of 9",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagliuca@hmflaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "December 14, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA Email The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan, I write under Rules of Evidence 608 and 403 to request that this Court preclude cross-examination of by the government concerning a regulatory settlement agreement involving Mr. related to , twenty years after the real estate transaction reflected in the documents he will serve as a foundational witness to admit. Mr. is a retired British Solicitor who represented Ms. Maxwell in the purchase of 44 Kinnerton Street, London SW1. The government has refused to stipulate to the admission of the 1996 Agreement for Sale for 44 Kinnerton Street and other related title documents, which show that Ms. Maxwell did not contract to purchase 44 Kinnerton Street until December 1996 (and did not complete the purchase until January 1997), long after Kate claims she engaged in a sexualized massage with Jeffrey Epstein in that residence. As a result, although the government does not contest the authenticity or relevance of these records, Ms. Maxwell",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011345",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jeffrey Epstein",
      "Jeffrey S. Pagliuca",
      "Kate"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York",
      "London",
      "44 Kinnerton Street"
    ],
    "dates": [
      "December 14, 2021",
      "07/12/22",
      "December 1996",
      "January 1997"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00011345",
      "1:20-cr-00330-PAE",
      "Document 721"
    ]
  },
  "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 discusses a request to preclude cross-examination of a witness and references various documents and events related to the case. Some names and details are redacted."
}