DOJ-OGR-00008267.jpg
655 KB
Extraction Summary
4
People
1
Organizations
0
Locations
2
Events
2
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
655 KB
Summary
This legal document is a filing on behalf of Ms. Maxwell arguing against the government's attempt to use her April 2016 deposition testimony. The core argument is that "Deposition Exhibit 13" is an unauthenticated photocopy and is fundamentally different from "Exhibit 52." This claim is supported by testimony from Mr. Alessi, who noted a significant physical discrepancy between Exhibit 52 and books he saw while employed by Mr. Epstein.
People (4)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable |
Addressed at the top of the letter.
|
| Ms. Maxwell | Party in a legal case |
The document is written on her behalf, referencing her April 2016 deposition and arguments.
|
| Mr. Alessi | Witness |
Provided testimony that the Court deemed inadequate to authenticate an exhibit, comparing Exhibit 52 to books he saw ...
|
| Mr. Epstein | Employer |
Mr. Alessi was employed by him.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| Court | Government agency |
Mentioned as having previously rejected the government's arguments and having heard testimony from Mr. Alessi.
|
Timeline (2 events)
2016-04
Ms. Maxwell's deposition where she gave testimony concerning Deposition Exhibit 13.
Mr. Alessi provided testimony explaining that Exhibit 52 was not the same as books he saw during his employment with Mr. Epstein.
Court
Relationships (2)
The document states Mr. Alessi saw certain books "during his employment with Mr. Epstein."
The document outlines Ms. Maxwell's legal arguments against the government's position in a court case.
Full Extracted Text
Complete text extracted from the document (1,882 characters)
Case 1:20-cr-00330-PAE Document 532 Filed 12/09/21 Page 3 of 8
The Honorable Alison J. Nathan
December 8, 2021
Page 3
December 8, 2021
Page 3
(D) all these conditions are shown by the testimony of the custodian or another
qualified witness, or by a certification that complies with Rule 902(11) or (12) or
with a statute permitting certification; and
qualified witness, or by a certification that complies with Rule 902(11) or (12) or
with a statute permitting certification; and
(E) the opponent does not show that the source of information or the method or
circumstances of preparation indicate a lack of trustworthiness.
circumstances of preparation indicate a lack of trustworthiness.
Fed. R. Evid. 803(6).
Pages 3 to 6 of the government’s letter rehash arguments the government has already
made and this Court has already rejected. Ms. Maxwell will not repeat here why these arguments
fail. (Ms. Maxwell incorporates those arguments by reference.)
made and this Court has already rejected. Ms. Maxwell will not repeat here why these arguments
fail. (Ms. Maxwell incorporates those arguments by reference.)
What’s new is the government’s attempt to rely on Ms. Maxwell’s April 2016 deposition
testimony and in particular the questions she was asked and the answers she gave concerning
Deposition Exhibit 13. The government’s reliance is not persuasive.
testimony and in particular the questions she was asked and the answers she gave concerning
Deposition Exhibit 13. The government’s reliance is not persuasive.
First, Deposition Exhibit 13 is not the same thing as Exhibit 52. Deposition Exhibit 13 is
a photocopy of some pages of some document. There is no explanation from where the
photocopy came, when it was made, who made it, what it purports to be a copy of, whether it is a
complete copy, or whether it is an accurate copy. Whatever it is, it is not a copy of Exhibit 52. (It
has, for example, several handwritten pages that aren’t contained in the government’s trial
exhibit.) Quite simply, Ms. Maxwell was not asked and did not testify about Exhibit 52 or its
authenticity.
a photocopy of some pages of some document. There is no explanation from where the
photocopy came, when it was made, who made it, what it purports to be a copy of, whether it is a
complete copy, or whether it is an accurate copy. Whatever it is, it is not a copy of Exhibit 52. (It
has, for example, several handwritten pages that aren’t contained in the government’s trial
exhibit.) Quite simply, Ms. Maxwell was not asked and did not testify about Exhibit 52 or its
authenticity.
This is no trivial matter. As Mr. Alessi explained in testimony this Court deemed
inadequate to authenticate the exhibit, Exhibit 52 is not the same as the books he saw during his
employment with Mr. Epstein. The books in use when he was an employee were two inches
thick. Exhibit 52 is 1/4 inch thick.
inadequate to authenticate the exhibit, Exhibit 52 is not the same as the books he saw during his
employment with Mr. Epstein. The books in use when he was an employee were two inches
thick. Exhibit 52 is 1/4 inch thick.
DOJ-OGR-00008267
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