Case 1:20-cr-00330-PAE Document 723 Filed 07/12/22 Pagel1of13
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
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Denver, Colorado 80203
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HADDON
MORGAN
FOREMAN
December 16, 2021
VIA Email
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re: — United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
I write in response to the government’s motion to preclude testimony from Eva Dubin,
Michelle Healy, and Kelly Bovino.' The government claims that testimony from Eva, Michelle,
and Kelly is inadmissible because: (1) it does not contradict Jane’s testimony; and (2) it is
improper impeachment on a collateral matter. The government is wrong.
BACKGROUND
On the stand, Jane alleged that several other women were involved in sexual conduct and
group sexualized massages with her, Mr. Epstein, and Ms. Maxwell. These women included Eva,
Michelle, and Kelly. TR. at 523-30. Although Jane has not always been consistent with the
government about the involvement of these women, she testified that all these women were
involved in or could “confirm” what happened in the group sexualized massages that are the
' The government also moved to preclude certain testimony from John Lopez. That part
of the motion is moot because Ms. Maxwell will not call Mr. Lopez as a witness.
DOJ-OGR-00011363