706.pdf
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- pdf
- Source set
- house-oversight-doj
- Pages
- 12
- Text status
- Searchable text available
- OCR confidence
- 0.9356693049224667
Original source
Extracted text
Case 1:20-cr-00330-PAE Document 706 Filed 07/12/22 Page1of12 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew’s Plaza New York, New York 10007 December 15, 2021 The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 82 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this motion to preclude certain testimony of certain defense witnesses. After reviewing the defendant’s witness list and related material, it appears that certain witnesses are expected to testify about matters that are irrelevant, prejudicial, or improper impeachment. Specifically, the Government moves to preclude the following: e Testimony from Eva Dubin, Michelle Healy, or Kelly Bovino about whether they participated in a sexualized massage with Jane; e Testimony from Alexander Hamilton as contained in the affidavit attached as Exhibit A; e Testimony from Dr. Loftus about suggestive activities that did not occur in this case; DOJ-OGR-00011253
Case 1:20-cr-00330-PAE Document 706 Filed 07/12/22 Page 2of12 and e Testimony from John Lopez about undisclosed exhibits. 1. Applicable Law Federal Rule of Evidence 402 provides that “[i]rrelevant evidence is not admissible.” Accordingly, any evidence that does not bear on the defendant’s guilt or innocence of the charges in the indictment should be excluded as irrelevant. Rule 403 further states that the Court may “exclude relevant evidence if its probative value is substantially outweighed by a danger of one or more of the following: unfair prejudice, confusing the issues, misleading the jury, undue delay, wasting time, or needlessly presenting cumulative evidence.” As a general matter, “extrinsic evidence is not admissible to prove specific instances of a witness’s conduct in order to attack or support the witness’s ch…
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