Case 1:20-cr-00330-PAE Document 490 Filed 11/22/21 Page1of3
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
My 150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmilaw.com
[email protected]
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