House Oversight — DOJ production
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- 358.pdf
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- House Oversight (DOJ)
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- 4
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Case 1:20-cr-00330-PAE Document 358 Filed 10/18/21 Page1of4 Uy Haddon, Morgan and Foreman, P.c Jeffrey Pagliuca HA. D DON eh ISS es 150 East 10th Avenue FOREMAN Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpaglisca@hmfilaw.com October 18, 2021 VIA ECF 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: Today, counsel for Ghislaine Maxwell filed 13 motions in /imine and accompanying exhibits seeking the following relief: to Preclude the Introduction of Alleged Co-Conspirator Statements as a Sanction for Failing to Comply with This Court's September 3, 2021 Order; to Exclude Any Evidence Offered by the Government Pursuant to Fed. R. Evid. 404(b) for Failure to Comply with the Rule's Notice Requirement; to Exclude Under Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993) and Request for Daubert Hearing; to Exclude Evidence Related to Accuser-3; to Exclude Evidence of Alleged Flight; to Exclude Evidence of Ms. Maxwell's Alleged False Statements and to Redact Allegations Related to the Perjury Counts from the Second Superseding Indictment; DOJ-OGR-00005260 Case 1:20-cr-00330-PAE Document 358 _ Filed 10/18/21 Page2of4 The Honorable Alison J. Nathan October 18, 2021 Page 2 to Exclude Government Exhibit 52, an Unauthenticated Hearsay Document from Suspect Sources; to Exclude Items Purportedly Seized During Search of 358 El Brillo Way on October 20, 2005; to Suppress Identification; to Preclude Law Enforcement Witnesses from Offering Expert Opinion Testimony; to Preclude Testimony About Any Alleged "Rape" by Jeffrey Epstein; to Preclude Reference to the Accusers as "Victims" or "Minor Victims"; and to Preclude Introduction of Government's Exhibits 251, 288, 294, 313 and 606. Temporary Sealing Some of the memoranda and exhibits in support of the motions […]