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Extracted Text (OCR)
Case 1:20-cr-00330-PAE Document 723 Filed 07/12/22 Page12o0f13
The Honorable Alison J. Nathan
December 16, 2021
Page 12
evidence. Gov. Letter, pp 3, 8. Even if that is what those cases hold (which Ms. Maxwell
disputes), the cases have no applicability here, because the details of the sexualized massages are
not collateral issues. They are the central issues in this case.
At best, the government’s arguments go to weight, not admissibility. If the government
wants to argue that Eva Dubin, Michelle Healy, and Kelly Bovino are not the Eva, Michelle, and
Kelly who Jane was referring to, the government is free to make that argument. In fact, the
government has already made precisely that argument as to J . responding to the
flight logs’ use of the name [J But that argument is no basis for denying Ms. Maxwell her
constitutional right to present a defense. U.S. Const. amends. V, VI.
CONCLUSION
This Court should deny the government’s motion.
DOJ-OGR-00011374
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Document Details
| Filename | DOJ-OGR-00011374.jpg |
| File Size | 406.9 KB |
| OCR Confidence | 93.7% |
| Has Readable Text | Yes |
| Text Length | 969 characters |
| Indexed | 2026-02-03 18:07:28.589674 |