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Case 1:20-cr-00330-PAE Document 490 Filed 11/22/21 Page1of3 Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca oO 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www. hmilaw.com joagliuca@hmflaw.com HADDON MORGAN FOREMAN November 15, 2021 VIA EMAIL The Honorable Alison J. Nathan 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, There are two fundamental flaws with the government’s evidentiary proffer regarding proposed Exhibit 52. First, as a matter of fact, Government Exhibit 52 was not something that the cooperating government witness reviewed, used, or saw during her brief employment with Jeffrey Epstein. Records produced in discovery reflect that witness began working for Epstein in HE At that point, the suspect source of Government Exhibit 52, Alfredo Rodriguez, was not employed by Epstein because he had been fired in 2004. According to Mr. Rodriguez, when he left the Epstein home he took an address book, which he claimed was Epstein’s book, and had it in his possession until 2009 when he tried to sell it to Brad Edwards for $50,000.' The book was clearly altered by Mr. Rodriguez. The single ' Mr. Rodriguez knew the target of his intended sale which makes the likelihood of alteration all the more probable. Mr. Edwards was a lawyer with of the Fort Lauderdale law firm of Rothstein Rosenfelt Adler. The firm was under investigation by the U.S. Attorney for the DOJ-OGR-00007409