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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, 82 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