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572 KB
Extraction Summary
5
People
3
Organizations
3
Locations
3
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal correspondence / defense filing
File Size:
572 KB
Summary
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.
People (5)
| Name | Role | Context |
|---|---|---|
| Jeffrey S. Pagliuca | Attorney |
Author of the letter, representing the defense (Haddon, Morgan and Foreman, P.C).
|
| Alison J. Nathan | Judge |
Recipient of the letter; presiding judge over United States v. Ghislaine Maxwell.
|
| Ghislaine Maxwell | Defendant |
Named in the case title 'United States v. Ghislaine Maxwell'.
|
| Jeffrey Epstein | Deceased / Associate |
Referenced as 'Mr. Epstein'; discussion concerns photos of his New York apartment.
|
| Jane | Alleged Victim / Witness |
Mentioned at the very end of the page in relation to the timeline 1994-1996.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Haddon, Morgan and Foreman, P.C |
Law firm representing the defense.
|
|
| United States District Court, Southern District of New York |
The court where the case is being heard.
|
|
| The Government |
Referring to the Prosecution/Department of Justice.
|
Timeline (3 events)
1994-1996
Time period relevant to the testimony involving 'Jane' and the state of the apartment.
Epstein's New York apartment
2019
Time period when the '900 series of photos' of Epstein's apartment were taken.
Epstein's New York apartment
December 3, 2021
Court ruling that the defense asks to be reaffirmed.
Southern District of New York
Judge Alison J. Nathan
Locations (3)
| Location | Context |
|---|---|
|
Address of Haddon, Morgan and Foreman, P.C.
|
|
|
Address of the United States District Court.
|
|
|
The location depicted in the disputed '900 series of photos'.
|
Relationships (2)
Pagliuca is writing on behalf of the defense in United States v. Ghislaine Maxwell.
Text links 'Jane' to the timeframe 1994-1996 inside Epstein's apartment.
Key Quotes (5)
"I write in response to the government's December 4, 2021 letter—the latest example of the government's inability to take no for an answer."Source
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Quote #1
"This is the government's modus operandi."Source
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Quote #2
"The government has, so far, failed to authenticate the 900 series photos, and unless it does, the photos are irrelevant under Rule 401 and misleading and prejudicial under Rule 403."Source
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Quote #3
"The 900 series of photos depict the exterior and portions of the interior of Mr. Epstein's New York apartment as it existed in 2019."Source
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Quote #4
"But the government has admitted no testimony that the 2019 photographs accurately depict the interior of Mr. Epstein's apartment as it existed in 1994 or 1995 or 1996"Source
DOJ-OGR-00008225.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (1,583 characters)
Case 1:20-cr-00330-PAE Document 525 Filed 12/05/21 Page 1 of 9
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
Jeffrey S. Pagliuca
HADDON
MORGAN
FOREMAN
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmflaw.com
jpagliuca@hmflaw.com
MORGAN
FOREMAN
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmflaw.com
jpagliuca@hmflaw.com
December 5, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
I write in response to the government's December 4, 2021 letter—the latest example of
the government's inability to take no for an answer. This is the government's modus operandi. It
disagrees with the Court's ruling and seeks to relitigate the issue under the guise of uncertainty
(either the government claims not to understand, or the Court wasn't clear enough) or confusion
(the Court didn't understand the government's argument). But there isn't any uncertainty or
confusion here. The government has, so far, failed to authenticate the 900 series photos, and
unless it does, the photos are irrelevant under Rule 401 and misleading and prejudicial under
Rule 403. This Court should reaffirm its ruling from December 3.
the government's inability to take no for an answer. This is the government's modus operandi. It
disagrees with the Court's ruling and seeks to relitigate the issue under the guise of uncertainty
(either the government claims not to understand, or the Court wasn't clear enough) or confusion
(the Court didn't understand the government's argument). But there isn't any uncertainty or
confusion here. The government has, so far, failed to authenticate the 900 series photos, and
unless it does, the photos are irrelevant under Rule 401 and misleading and prejudicial under
Rule 403. This Court should reaffirm its ruling from December 3.
BACKGROUND
The 900 series of photos depict the exterior and portions of the interior of Mr. Epstein's
New York apartment as it existed in 2019. That much the government can show.
New York apartment as it existed in 2019. That much the government can show.
But the government has admitted no testimony that the 2019 photographs accurately
depict the interior of Mr. Epstein's apartment as it existed in 1994 or 1995 or 1996 (when Jane
depict the interior of Mr. Epstein's apartment as it existed in 1994 or 1995 or 1996 (when Jane
DOJ-OGR-00008225
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