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Case 1:20-cr-00330-PAE Document 706 Filed 07/12/22 Page1of12
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
December 15, 2021
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this motion to preclude certain testimony of certain
defense witnesses. After reviewing the defendant’s witness list and related material, it appears
that certain witnesses are expected to testify about matters that are irrelevant, prejudicial, or
improper impeachment.
Specifically, the Government moves to preclude the following:
e Testimony from Eva Dubin, Michelle Healy, or Kelly Bovino about whether they
participated in a sexualized massage with Jane;
e Testimony from Alexander Hamilton as contained in the affidavit attached as Exhibit
AS
e Testimony from Dr. Loftus about suggestive activities that did not occur in this case;
DOJ-OGR-00011253