DOJ Letter: Southern D.New, November 21, 2021, United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN (EFTA00105576)

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building New York, New York 10007 November 21, 2021 BY E-MAIL The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 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 in reply to the defendant's motion to exclude Government Exhibit 52. (See Dkt. No. 476). The Court ordered the Government to respond in particular to the defendant's argument that "Employee-1 cannot authenticate Government Exhibit 52 because - a former employee, purportedly removed the document from the property before Employee-1 began working for Mr. Epstein." (Id.) 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) (alterati