Court Filing: 704
Summary
The government opposes Ghislaine Maxwell's request to allow three defense witnesses to testify using pseudonyms or first names, arguing that it is unprecedented and not necessary to protect the defendant's constitutional rights. The government contends that the witnesses do not fit into established categories of witnesses who are permitted to testify anonymously, such as victims of sex abuse or undercover law enforcement officers.
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Court Filing: 706
The government moves to preclude testimony from certain defense witnesses, including Eva Dubin, Michelle Healy, and Kelly Bovino, regarding their alleged participation in sexualized massages with Jane, arguing that it is irrelevant and improper impeachment. The government also seeks to preclude testimony from other witnesses, including Alexander Hamilton and Dr. Loftus, on various grounds.
Court Filing - Letter to Judge: 722
The letter, filed by Jeffrey S. Pagliuca on behalf of Ghislaine Maxwell, notifies the court and the government of the defendant's intention to present extrinsic evidence of prior inconsistent statements made by witnesses Jane and Carolyn during their testimonies. The letter details specific inconsistencies between the witnesses' trial testimonies and their prior statements as recorded in 3500 materials.
Court Filing - Letter to Judge: 547
The defense attorney, Bobbi C. Sternheim, writes to Judge Alison J. Nathan arguing against the government's attempt to limit Dr. Loftus's expert testimony on the science of memory and suggestive questioning. The letter cites examples from witness testimony and government interviews, asserting that the government's actions are an effort to restrict relevant testimony and undermine the defendant's right to a defense.
Court Filing - Letter to Judge: 723
The defense attorney for Ghislaine Maxwell argues that the testimony of Eva Dubin, Michelle Healy, and Kelly Bovino is relevant, material, and exculpatory, contradicting Jane's testimony about group sexualized massages involving Maxwell and Jeffrey Epstein. The defense asserts that excluding this testimony would violate Maxwell's right to present a defense and confront her accusers.
Court Filing: 107
The defense team for Ghislaine Maxwell requests a two-week extension to file pretrial motions and modify the briefing schedule due to COVID-19 restrictions and the large volume of discovery. The government consents to the requested extension. The proposed new deadlines are January 25, 2021, for the defendant's motions, February 26, 2021, for the government's response, and March 5, 2021, for the defendant's reply.
Court Order: 127
The court has received twelve pre-trial motions from the defendant, some of which have been filed under temporary seal due to sensitive information. The government is given two days to respond to the proposed redactions. The order is issued by Judge Alison J. Nathan.
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