555.pdf
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- pdf
- Source set
- house-oversight-doj
- Pages
- 5
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- OCR confidence
- 0.9303918854441242
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Extracted text
Case 1:20-cr-00330-PAE Document555 Filed 12/18/21 Pagelof5 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.hmflaw.com [email protected] HADDON MORGAN FOREMAN December 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, I write in response to the government’s motion to preclude certain testimony by Alexander Hamilton. Based on a defense Rule 26.2 disclosure, the government’s motion identifies four categories of testimony it asks this Court to preclude: (1) Testimony about Kate" a (2) Testimony describing Kate as (3) Testimony about Kate’s statements to Mr. Hamilton. (4) Testimony about Mr. Hamilton’s J of Kate’s account of her alleged abuse. Gov. Letter, pp 8-10. Ms. Maxwell provided Mr. Hamilton’s declaration to the government under Rule 26.2 because that is what the Rule requires. But just as the government does not intend to admit evidence about every disclosure it makes, so too here. DOJ-OGR- 00008431
Case 1:20-cr-00330-PAE Document555 - Filed 12/18/21 Page2of5 The Honorable Alison J. Nathan December 15, 2021 Page 2 The government did not confer with defense counsel before filing its motion. Had it done so, the government would have learned that of these four categories, Ms. Maxwell intends only to elicit testimony about the third. As to that category of testimony, the government’s argument borders on the frivolous. While talking with Mr. Hamilton about Mr. Epstein in 2019 or 2020, Kate made two statements laying bare her motive and bias. [las a a ES The 12 is clear that Ms. Maxwell can ask Mr. Hamilton about these statements. “The law is well settled in this Circuit, as in others, that bias of a witness is not a collateral issue and extrinsic evidence is admissible to prove that a witness has a motive to …
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