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Case 1:20-cr-00330-PAE Document 723 Filed 07/12/22 Page1of13 Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca oO 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jeagliuca@hmflaw.com 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