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703 KB
Extraction Summary
4
People
1
Organizations
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Locations
2
Events
1
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
703 KB
Summary
This legal document is a filing arguing against the government's attempt to admit 'Exhibit 52' as evidence in a trial involving Ms. Maxwell. The author contends that the government has failed to authenticate the exhibit, has abandoned its original premise that it was Ms. Maxwell's book, and that admitting it at this late stage would be unfair. The argument is bolstered by the government's decision not to call a key witness, 'Employee-1', who was supposed to link the exhibit to Ms. Maxwell.
People (4)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable |
Addressed at the top of the document.
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| Ms. Maxwell |
A central figure in the legal proceedings, likely the defendant, against whom the government is trying to admit Exhib...
|
|
| Employee-1 | Witness |
A potential witness the government decided not to call to testify about Exhibit 52.
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| Mr. Alessi |
A person who has finished testifying in the case.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| Court | Judicial body |
Mentioned as "this Court" which recognized that Mr. Alessi is done testifying.
|
Timeline (2 events)
2021-12-08
A legal argument is being made regarding the admissibility of Exhibit 52 in a trial.
Ms. Maxwell gave deposition testimony where she denied ownership of or responsibility for Deposition Exhibit 13.
Relationships (1)
The document outlines the government's attempt to introduce evidence (Exhibit 52) against Ms. Maxwell and the defense's arguments refuting the government's claims and methods.
Key Quotes (1)
"Ms. Maxwell unequivocally denied being the owner of or responsible for Deposition Exhibit 13."Source
— Ms. Maxwell
(Cited in a footnote from her deposition testimony as evidence that the government has abandoned its argument that Exhibit 52 was her book.)
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Quote #1
Full Extracted Text
Complete text extracted from the document (2,029 characters)
Case 1:20-cr-00330-PAE Document 532 Filed 12/09/21 Page 6 of 8
The Honorable Alison J. Nathan
December 8, 2021
Page 6
December 8, 2021
Page 6
Id. at 331. The government’s attempt to authenticate Exhibit 52 through Ms. Maxwell’s testimony about something else entirely fails.
The flaws in the government’s argument don’t end with these two problems, though each problem itself is dispositive of the government’s request. The government’s letter focuses exclusively on the authentication question. The government does not address the business records exception or even attempt to justify the admission of Exhibit 52 despite it being hearsay.
The government also conveniently ignores all it said before about why Exhibit 52 was relevant and how it would be admitted and used as evidence. The government first said Exhibit 52 was Ms. Maxwell’s book. That was the entire premise of the government’s November 12 letter and its opposition to Ms. Maxwell’s motion in limine. But no witness has testified that it was Ms. Maxwell’s book, and the government has abandoned that argument.¹
The government next said it would call Employee-1 as a witness to authenticate the exhibit and lay the foundation for its admission and, in turn, to testify that Exhibit 52 belonged to Ms. Maxwell. But no more. The government’s decision not to call Employee-1 confirms what Ms. Maxwell has been saying all along: Exhibit 52 did not belong to her, and Employee-1 was never going to testify that it did.
Finally, it would be exceedingly unfair were the government to admit Exhibit 52 at this late stage in its case, having now abandoned its earlier arguments for admissibility and relevance. As this Court recognized earlier today, Mr. Alessi is done testifying, and Ms. Maxwell cannot be
¹ We know the government has abandoned this argument because it relies on Ms. Maxwell’s deposition testimony as the basis for admitting Exhibit 52. But in that testimony, Ms. Maxwell unequivocally denied being the owner of or responsible for Deposition Exhibit 13.
DOJ-OGR-00008270
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