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675 KB
Extraction Summary
4
People
1
Organizations
0
Locations
3
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
675 KB
Summary
This legal document is the Government's response to a defense motion to exclude 'Government Exhibit 52,' a physical contact book. The Government clarifies that it will offer the physical book itself, not a scan from the 'Guiffre v. Maxwell' civil case, and argues that the book's controversial acquisition history affects its weight, not its admissibility. The Government also contends the book is not hearsay because it is being used to prove the defendant kept contact information for victims, not to prove the accuracy of that information.
People (4)
| Name | Role | Context |
|---|---|---|
| Guiffre | Plaintiff |
Mentioned as a party in the civil litigation 'Guiffre v. Maxwell'.
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| Maxwell | Defendant |
Mentioned as a party in the civil litigation 'Guiffre v. Maxwell'.
|
| Jeffrey Epstein |
A former employee of his attempted to sell Government Exhibit 52 to a civil lawyer suing him.
|
|
| Al Farekh |
Mentioned in a legal citation: 'See Al Farekh, 810 F. App’x at 24-25.'
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Organizations (1)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
The prosecuting party in the case, which obtained and seeks to use Government Exhibit 52 as evidence.
|
Timeline (3 events)
The defendant moves to exclude Government Exhibit 52.
defendant
Government
The Government acquired Government Exhibit 52 after a former employee of Jeffrey Epstein attempted to sell it.
Relationships (2)
They are opposing parties in the 'Guiffre v. Maxwell civil litigation'.
The document states that a 'former employee of Jeffrey Epstein' attempted to sell the exhibit.
Key Quotes (2)
"as part of discovery in Guiffre v. Maxwell civil litigation . . . with no explanation about its origin."Source
— defendant
(Quoted from the defendant's motion (Def. Mot. 7 at 1) describing how they believe the Government obtained Exhibit 52.)
DOJ-OGR-00005857.jpg
Quote #1
"particularly troubling"Source
— defense
(The defense's description of the history of the Government's acquisition of Government Exhibit 52 (Def. Mot. 7 at 2).)
DOJ-OGR-00005857.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (1,990 characters)
Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 74 of 84
First, the defendant moves to exclude Government Exhibit 52, which it says was obtained
by the Government “as part of discovery in Guiffre v. Maxwell civil litigation . . . with no
explanation about its origin.” (Def. Mot. 7 at 1). The defendant misidentifies the exhibit.
Government Exhibit 52 is a physical contact book belonging to the defendant. The records
attached by the defense as Exhibit 1 appear to be a scan of Government Exhibit 52 that was
produced in discovery in Guiffre v. Maxwell. But the Government will not offer that scan at trial.
It will offer the physical book itself, along with scans taken by the Government of the physical
book. A witness with personal knowledge of the physical book is expected to testify to its
authenticity.
by the Government “as part of discovery in Guiffre v. Maxwell civil litigation . . . with no
explanation about its origin.” (Def. Mot. 7 at 1). The defendant misidentifies the exhibit.
Government Exhibit 52 is a physical contact book belonging to the defendant. The records
attached by the defense as Exhibit 1 appear to be a scan of Government Exhibit 52 that was
produced in discovery in Guiffre v. Maxwell. But the Government will not offer that scan at trial.
It will offer the physical book itself, along with scans taken by the Government of the physical
book. A witness with personal knowledge of the physical book is expected to testify to its
authenticity.
The defendant takes issue with the history of the Government’s acquisition of Government
Exhibit 52. The defendant is correct that the Government came into custody of this exhibit after a
former employee of Jeffrey Epstein attempted to sell it to a civil lawyer suing Epstein. (Id.). The
defense calls this “particularly troubling” (Def. Mot. 7 at 2), but that argument is misplaced. How
the Government acquired the exhibit goes, if anything, to its weight and not its admissibility. If a
witness can identify the exhibit based on its contents, that is sufficient to pass the relatively low
bar for authentication of evidence.” See Al Farekh, 810 F. App’x at 24-25.
Exhibit 52. The defendant is correct that the Government came into custody of this exhibit after a
former employee of Jeffrey Epstein attempted to sell it to a civil lawyer suing Epstein. (Id.). The
defense calls this “particularly troubling” (Def. Mot. 7 at 2), but that argument is misplaced. How
the Government acquired the exhibit goes, if anything, to its weight and not its admissibility. If a
witness can identify the exhibit based on its contents, that is sufficient to pass the relatively low
bar for authentication of evidence.” See Al Farekh, 810 F. App’x at 24-25.
Finally, the defendant argues that the contents of Government Exhibit 52 are hearsay
because they are not a business record. (Def. Mot. 7 at 4-6). The exhibit is separately admissible
not for the truth of the matter asserted therein (such as the accuracy of the contact information for
victims), but to establish that the defendant kept contact information for relevant individuals at
trial, including victims. The exhibit has evidentiary value in showing that the defendant
because they are not a business record. (Def. Mot. 7 at 4-6). The exhibit is separately admissible
not for the truth of the matter asserted therein (such as the accuracy of the contact information for
victims), but to establish that the defendant kept contact information for relevant individuals at
trial, including victims. The exhibit has evidentiary value in showing that the defendant
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DOJ-OGR-00005857
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