DOJ-OGR-00006420.pdf

--- Page 1 --- **Document Header** * **Case Number:** Case 1:20-cr-00330-PAE * **Document Number:** Document 439 * **Filing Date:** Filed 11/12/21 * **Page Number:** Page 3 of 69 **Page Content** * **Section III: Evidence and Argument About Prior Charging Decisions and the Course of Prior Investigations Is Admissible** + Subsection A: The NPA Is Admissible to Show the Bias and Interest of + Subsection B: Evidence and Argument About the NPA, Prior Charging Decisions, and the Death of Jeffrey Epstein Is Admissible to Challenge the Thoroughness and Good Faith of the New York Investigation + Subsection C: Evidence and Argument About the Fact that Ms. Maxwell Was Not Charged by the USAO-SDFL Is Relevant to + Subsection D: Evidence and Argument About the Scope, Timeline, and Investigative Steps of Prior Investigations Is Admissible + Subsection E: A Proffer Regarding the Basis for the Case Agents' Testimony Is Unnecessary and Unwarranted + Subsection IV: THE GOVERNMENT'S MOTION TO PRECLUDE EVIDENCE OR ARGUMENT ABOUT ITS MOTIVES FOR PROSECUTING MS. MAXWELL IS MISGUIDED AND MERITLESS + Subsection V: A PRE-TRIAL BAN ON CHALLENGES TO THE CREDIBILITY OF NON-TESTIFYING WITNESSES IS UNSUPPORTED LEGALLY OR FACTUALLY + Subsection VI: CERTAIN EVIDENCE OR ARGUMENT THAT MINOR VICTIMS CONSENTED TO SEXUAL ABUSE MAY BE ADMISSIBLE + Subsection VII: UNFOUNDED REQUEST TO PRECLUDE EVIDENCE OF MS. MAXWELL'S GOOD ACTS SHOULD BE SUMMARILY DENIED + Subsection VIII: THE GOVERNMENT'S MOTION TO LIMIT THE INTRODUCTION OF MS. MAXWELL'S STATEMENTS IS PREMATURE AND SHOULD BE DENIED AT THIS TIME + Subsection IX: MS. MAXWELL'S COUNSEL UNDERSTANDS AND WILL FOLLOW THE RULES OF EVIDENCE AND PROHIBITION AGAINST ARGUMENT FOR JURY NULLIFICATION - RENDERING THIS MOTION MOOT + Subsection X: REQUEST TO PREVIEW DEFENSE'S EVIDENCE SHOULD BE DENIED **Footer** * **Text:** DOJ-OGR-00006420