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643 KB
Extraction Summary
5
People
1
Organizations
1
Locations
3
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
643 KB
Summary
This legal document argues that certain proffered documents cannot be authenticated as required by Federal Rules of Evidence. The filing suggests the documents, which surfaced in 2009, were likely manipulated or manufactured by Mr. Rodriguez, a former employee of Mr. Epstein, in an attempt to secure a $50,000 payment. The document asserts there is no evidence linking the creation or maintenance of these documents to Ms. Maxwell or any other credible source.
People (5)
| Name | Role | Context |
|---|---|---|
| Mr. Rodriguez |
Subject of a bribery and obstruction scheme, alleged to have manipulated or manufactured documents for a payday. Form...
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| Mr. Epstein |
Former employer of Mr. Rodriguez. Documents were allegedly taken from his home.
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| Ms. Maxwell |
Mentioned as someone for whom there is no evidence of creating or maintaining the documents in question.
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| Dhinsa | Defendant |
Mentioned in the case citation 'United States v. Dhinsa, 243 F.3d 635, 658 (2d Cir. 2001)'.
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| Ruggiero | Defendant |
Mentioned in the case citation 'United States v. Ruggiero, 928 F.2d 1289, 1303 (2d Cir. 1991)'.
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Organizations (1)
| Name | Type | Context |
|---|---|---|
| United States | government agency |
Party in several cited legal cases: United States v. Dhinsa, United States v. Ruggiero, and United States v. Rodriguez.
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Timeline (3 events)
United States v. Rodriguez, Case No. 9:09-mj-08308-LRJ
Mr. Rodriguez's bribery and obstruction scheme.
Locations (1)
| Location | Context |
|---|---|
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Location from which Mr. Rodriguez stated he did not take any documents, lists, books, or journals.
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Relationships (1)
The document states that Mr. Rodriguez was no longer working for Mr. Epstein, indicating a former employer-employee relationship.
Key Quotes (4)
"evidence sufficient to support a finding that the matter in question is what its proponent claims."Source
— Fed. R. Evid. 901(a)
(Quoted to explain the requirement of authentication for evidence.)
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Quote #1
"is satisfied ‘if sufficient proof has been introduced so that a reasonable juror could find in favor of authenticity or identification.’"Source
— Rule 901
(Quoted from United States v. Dhinsa to further explain the standard for authentication.)
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Quote #2
"P.B., 2004-2005"Source
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Quote #3
"explained that he had compiled lists of additional victims in the case and their contact information"Source
— Mr. Rodriguez
(A statement from Mr. Rodriguez in the case United States v. Rodriguez.)
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Quote #4
Full Extracted Text
Complete text extracted from the document (1,791 characters)
Case 1:20-cr-00330-PAE Document 390 Filed 10/29/21 Page 7 of 11
I. The Document Cannot be Authenticated
In order to satisfy the requirement of authentication, a party must provide “evidence sufficient to support a finding that the matter in question is what its proponent claims.” Fed. R. Evid. 901(a). Rule 901 “is satisfied ‘if sufficient proof has been introduced so that a reasonable juror could find in favor of authenticity or identification.’” United States v. Dhinsa, 243 F.3d 635, 658 (2d Cir. 2001) (quoting United States v. Ruggiero, 928 F.2d 1289, 1303 (2d Cir. 1991)). Here, the putatively proffered documents were at the heart of Mr. Rodriguez’s bribery and obstruction scheme. The documents apparently did not surface until 2009, decades after the claims here, years after the alleged conspiracy, and five years after Mr. Rodriguez was no longer working for Mr. Epstein. The documents contain an unexplained notation, “P.B., 2004-2005” the only potential (hearsay) date referenced in the documents. There is no evidence to suggest that these documents were created or maintained by Ms. Maxwell. Indeed, there is no evidence to suggest that these documents were created or maintained by anyone. It is entirely probable that whatever the documents are they were manipulated or manufactured by Mr. Rodriguez in an effort to get a $50,000 payday. United States v. Rodriguez, Case No. 9:09-mj-08308-LRJ, ECF No. 3, ¶6 (Mr. Rodriguez “explained that he had compiled lists of additional victims in the case and their contact information”).
Mr. Rodriguez’s statement, albeit inadmissible, on this issue is that he did not possess any document, list, books, journals or anything else taken from Mr. Epstein’s home. [REDACTED]
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DOJ-OGR-00005719
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