EFTA00023413.pdf
30.5 KB
Extraction Summary
3
People
3
Organizations
1
Locations
0
Events
1
Relationships
2
Quotes
Document Information
Type:
Email
File Size:
30.5 KB
Summary
An email dated November 14, 2021, from an Assistant United States Attorney (SDNY) to a colleague regarding a draft Q&A for Paul Kane (likely a witness, such as an FBI agent). The email discusses legal strategy for admitting records not created by 'PCS' but maintained by them as business records, citing the case United States v. Kuthuru. This correspondence appears to be part of the preparation for the Ghislaine Maxwell trial.
People (3)
| Name | Role | Context |
|---|---|---|
| Paul Kane | Subject of Q&A / Likely Witness |
Subject of a draft Q&A document attached to the email, likely regarding testimony about records.
|
| Redacted Sender | Assistant United States Attorney |
Sender of the email, works at SDNY.
|
| Redacted Recipient | Unknown (Likely Colleague/Prosecutor) |
Recipient of the email discussing legal strategy.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Southern District of New York (SDNY) |
Sender's employer, office of the Assistant United States Attorney.
|
|
| PCS |
Entity mentioned in relation to record creation ('since PCS didn't create this record'). Likely refers to a telecommu...
|
|
| Second Circuit |
Court of Appeals referenced for case law.
|
Locations (1)
| Location | Context |
|---|---|
|
Address of the Assistant United States Attorney (SDNY).
|
Relationships (1)
Sender (AUSA)
→
Colleagues / Legal Team
→
Recipient
Informal tone ('Hey', 'Let's chat'), sharing draft legal documents for a case.
Key Quotes (2)
"Attached is a draft Paul Kane Q&A."Source
EFTA00023413.pdf
Quote #1
"basically, since PCS didn't create this record, the questions are aimed at a line of Second Circuit cases holding that "Records maintained but not created by a company may be admissible as business records of that company if witnesses testify that the records are integrated into [the] company's records and relied upon in its day-to-day operations.""Source
EFTA00023413.pdf
Quote #2
Full Extracted Text
Complete text extracted from the document (894 characters)
From: [REDACTED] <[REDACTED]>
To: [REDACTED] <[REDACTED]>
Subject: Paul Kane Q&A
Date: Sun, 14 Nov 2021 06:30:33 +0000
Attachments: Kane_Q&A.docx
To: [REDACTED] <[REDACTED]>
Subject: Paul Kane Q&A
Date: Sun, 14 Nov 2021 06:30:33 +0000
Attachments: Kane_Q&A.docx
Hey [REDACTED]
Attached is a draft Paul Kane Q&A. There are a couple questions that may seem weird — basically, since PCS didn't create this record, the questions are aimed at a line of Second Circuit cases holding that "Records maintained but not created by a company may be admissible as business records of that company if witnesses testify that the records are integrated into [the] company's records and relied upon in its day-to-day operations." United States v. Kuthuru, 665 F. App'x 34, 39 (2d Cir. 2016).
Let's chat about the other hearsay issue when you have a minute?
Thanks!
[REDACTED]
[REDACTED]
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
[REDACTED]
EFTA00023413
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