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be NO Ww ws Oo OY ~] oO Ke) a oO he be No (ee) = Hs Oo _ OY a ~] a oO a Ke} 20 21 22 23 24 25 Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 92 of 127 92 LB1TMAX3 came going suspe wasn't around in 2004. from or how it was created. The government says that it has a witness that is CO S ay that that was Ms. Maxwell's book. I'm highly ct of that to begin with. And secondarily, that witness this purported foundation, both of whom were And so we have now two witnesses for not employed during the relevant timeframe of the conspiracy. So I'm at a loss, authe document. then they will say as a business record we'll] The government says well, admi frankly, to understand how anyone could either nticate that document or admit it as some non-hearsay even if it's not admissible, that is. t it for some other purpose, which I And if they're admitting it for another purpose, the government says don't know what don't understand the relevance of this, given the inability to establish a foundation and to tie it with any alleged conduct that is part of the indictment in this case. 5 o I don't think we can just leave have a discussion about this in the middle o Seems the g to m overn this here and then f trial. And it e that in this type of hearing, a pretrial hearing, ment should say here's the witness authe that ntica 1s wh that we th that is going to te it, here's how they're going to authenticate it, at we're authenticating it for, here are the pages ink are relevant and here's why. e don't have anything of that information. We are SOUTHERN DISTRICT REPORTERS, (212) 805-0300 PG ew DOJ-OGR-00007143