Court Filing - Letter to Judge: 723
Summary
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 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: 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.
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.
Court Filing - Letter to Judge: 521
The letter, filed by Ghislaine Maxwell's attorneys, argues that Maxwell has a constitutional right to call Jane's attorney, Robert Glassman, as a witness to testify about his advice to Jane regarding cooperating with the government and testifying against Maxwell. The attorneys contend that the attorney-client privilege does not apply or has been waived, and that Glassman's testimony is relevant to Jane's credibility and Maxwell's defense.
Court Filing - Letter to Judge: 709
The letter is a response to the government's November 12, 2021, letter to the court, objecting to certain categories of alleged co-conspirator hearsay statements and representative examples proffered by the government. The defense argues that these statements are not in furtherance of any conspiracy and are therefore inadmissible. The letter also requests that the court exclude certain statements under Fed. R. Evid. 403 due to their prejudicial impact.
Court Filing - Letter to Judge: 717
The defense team for Ghislaine Maxwell requests that three witnesses be allowed to testify using pseudonyms or their first names only, citing substantial professional and personal privacy interests, and arguing that this is necessary to protect their constitutional rights to present a defense and effective assistance of counsel.
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