533.pdf
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- pdf
- Source set
- house-oversight-doj
- Pages
- 8
- Text status
- Searchable text available
- OCR confidence
- 0.9358672071221164
Original source
Extracted text
Case 1:20-cr-00330-PAE Document533 _ Filed 12/09/21 Page1of8 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew’s Plaza New York, New York 10007 December 8, 2021 REQUEST TO BE FILED UNDER SEAL BY EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter renewing its application for the admission of Government Exhibit 52, the contact book. At trial on December 2, the Court reserved its decision on whether to admit the book during the testimony of Juan Alessi. 12/02/21 Tr. at 876. At the time, the Government anticipated calling Employee-1, who was expected to provide additional authentication testimony. The Government no longer intends to call Employee-1 to testify at trial, but additional corroboration of Government Exhibit 52’s authenticity has been received in evidence. The Government therefore submits that the issue is ripe for resolution, and that the exhibit should be admitted. The lone issue before the Court is whether the Government has established the authenticity 1 DOJ-OGR-00008273
Case 1:20-cr-00330-PAE Document533 Filed 12/09/21 Page2of8 of Government Exhibit 52, under Rule 902. For the reasons set forth below, the record at trial establishes that Government Exhibit 52 is authentic. Accordingly, excerpts of Government Exhibit 52 should be admitted. 1. Applicable Law The Second Circuit has “often commented that the bar for authentication of evidence is not particularly high.” United States v. Al-Moyad, 545 F.3d 139, 172 (2d Cir. 2008) (alteration and internal quotation marks omitted). The “proponent of the evidence is not required to rule out all possibilities inconsistent with authenticity, or to prove beyond a reasonable doubt that the evidence is wha…
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