EFTA00021944.pdf

Type: pdf
Source set: data-set-8
Extracted text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
x 
: 
20 Cr. 330 (MN) 
UNITED STATES OF AMERICA, 
v. 
GHISLAINE MAXWELL, 
Defendant. 
x 
GHISLAINE MAXWELL'S MOTION TO PRECLUDE INTRODUCTION OF 
GOVERNMENT EXHIBITS 251, 288, 294, 313 AND 606 
Jeffrey S. Pagliuca 
Laura A. Menninger 
HADDON, MORGAN & FOREMAN P.C. 
150 East 10th Avenue 
Denver, CO 80203 
Phone: 303-831-7364 
Christian R. Everdell 
COHEN & GRESSER LLP 
800 Third Avenue 
New York, NY 10022 
Phone: 212-957-7600 
Bobbi C. Sternheim 
Law Offices of Bobbi C. Sternheim 
225 Broadway, Suite 715 
New York, NY 10007 
Phone: 212-243-1100 
Attorneys for Chislaine Maxwell 
EFTA00021944


TABLE OF CONTENTS 
I. 
The Exhibits 
 1 
II. The Items are Not Relevant 
2 
III. The Evidence Should Be Excluded as Unfairly Prejudicial 
2 
CONCLUSION 
4 
EFTA00021945


TABLES OF AUTHORITIES 
Cases 
Old Chief v. United States, 519 U.S. 172, 178 (1997) 
2, 3 
United States v. Salim, 189 F. Supp. 2d 93, 98 (S.D.N.Y. 2002) 
3 
Rules 
Fed. R. Evid. 401  
1, 2 
Fed. R. Evid. 403 
1, 3 
Fed. R. Evid. 404 
1 
ii 
EFTA00021946


The Government has proffered a number of exhibits that it apparently intends to 
introduce at trial. It is difficult to assess the admissibility of some of the exhibits pretrial. Others, 
however, such as the ones described below, are not relevant in the context of this case, have no 
probative value, and are extremely prejudicial. Accordingly, Ms. Maxwell objects to the 
following exhibits pursuant to Federal Rules of Evidence 401, 403 and 404(b): 
I. The Exhibits 
Government Exhibit 251 and 288 are framed photograph 
The photographs have no nexus to Ms. Maxwell 
The photographs have no probative value to any allegation in this 
case and appear to be offered to demonstrate some character flaw in Mr. Epstein and, by 
association, Ms. Maxwell. 
Government Exhibit 294 is a box containing an item described as "Twin Torpedos." This 
box was apparently seized during the execution of a search warrant at 358…
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