📧 Communication

This document is a legal letter dated December 5, 2021, from defense attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The defense objects to the government's attempt to introduce the '900 series' of photographs of Jeffrey Epstein's New York apartment taken in 2019, arguing they have not been authenticated as accurately representing the apartment during the relevant timeframe of 1994-1996. The letter urges the court to reaffirm its previous ruling from December 3 excluding the photos based on Rules 401 and 403.