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Case 1:20-cr-00330-PAE Document 390 _ Filed 10/29/21 Page7of11 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. yyy DOJ-OGR-00005719