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d-7993Court UnsealedLegal Filing

Court Filing: 706

Date
Unknown
Source
Court Unsealed
Reference
File: 706
Pages
12
Persons
9

Summary

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.

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Court UnsealedCorrespondenceUnknown

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.

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Court UnsealedLegal FilingUnknown

Court Filing: 704

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 UnsealedLegal FilingUnknown

Court Filing: 523

The document is a letter from the U.S. Department of Justice to Judge Alison J. Nathan, arguing for the admission of certain photographs from Jeffrey Epstein's New York house as evidence. These photographs are claimed to corroborate the testimony of a witness known as 'Jane' regarding her experiences in Epstein's house, particularly in the massage room where she alleges she was sexually abused. The government asserts that the photographs are relevant and should be admitted as they support Jane's testimony about the details of the massage room and Epstein's house.

9p
Court UnsealedLegal FilingUnknown

Court Filing: 525

The defense responds to the government's letter arguing that the '900 series photos' of Jeffrey Epstein's apartment are inadmissible due to lack of authentication and relevance, as they were taken in 2019, long after the alleged events. The defense argues that without testimony confirming the photos accurately depict the apartment during the relevant time period, they are irrelevant and potentially misleading. The court had previously sustained the defense's objection to the photos' admission.

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Court UnsealedLegal FilingUnknown

Court Filing: 528

The document is a letter from the US Department of Justice to Judge Alison J. Nathan arguing that the defense's motion to call Jane's attorney, Robert Glassman, to testify should be denied due to attorney-client privilege and lack of probative value under Rule 403. The government asserts that Glassman's conversations with Jane are privileged and that the defense's theories for why the privilege does not apply are without merit.

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Court UnsealedLegal FilingUnknown

Court Filing: 555

The defense responds to the government's motion to preclude certain testimony by Alexander Hamilton, arguing that the testimony regarding Kate's statements to Hamilton is admissible to show Kate's bias and motive. The defense also requests permission for Hamilton to testify remotely via WebEx due to COVID-19.

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