357.pdf

Type

pdf

Source set

house-oversight-doj

Pages

4

Text status

Searchable text available

OCR confidence

0.9012140162524099

Original source

Extracted text

Case 1:20-cr-00330-PAE Document 357 _ Filed 10/18/21 Page1of4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ee a ee = x UNITED STATES OF AMERICA, : 20 Cr. 330 (AJN) v. . GHISLAINE MAXWELL, Defendant. =e ee ee ee ee ee ee ee ee ee en eee ee eee ee enon eee ee x DEFENDANT GHISLAINE MAXWELL'S NOTICE OF MOTIONS IN LIMINE PLEASE TAKE NOTICE that, upon the accompanying memoranda and exhibits, Defendant Ghislaine Maxwell, through counsel, hereby moves the Court in /imine to exclude certain evidence during her upcoming trial. Specifically, Ms. Maxwell hereby gives notice of her filing of the following motions: 1. Motion to Preclude the Introduction of Alleged Co-Conspirator Statements as a Sanction for Failing to Comply with This Court's September 3, 2021 Order 2. Motion 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; 3. Motion 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; 4. Motion to Exclude Evidence Related to Accuser-3; 5. Motion to Exclude Evidence of Alleged Flight; DOJ-OGR-00005256 

Case 1:20-cr-00330-PAE Document 357 _ Filed 10/18/21 Page2of4 6. Motion to Exclude Evidence of Ms. Maxwell's Alleged False Statements and to Redact Allegations Related to the Perjury Counts from the Second Superseding Indictment; 7. Motion to Exclude Government Exhibit 52, an Unauthenticated Hearsay Document from Suspect Sources; 8. Motion to Exclude Items Purportedly Seized During Search of 358 El Brillo Way on October 20, 2005; 9. Motion to Suppress Identification; 10. Motion to Preclude Law Enforcement Witnesses from Offering Expert Opinion Testimony; 11. Motion to Preclude Testimony About Any Alleged "Rape" by Jeffrey Epstein; 12. Motion to Preclude Reference to the Accusers as "Victims" or "Minor Victims"; and 13. Motion to Preclude Introduction of Government's Exhibits 251, 28…

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