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Case 1:20-cr-00330-PAE Document 358 _ Filed 10/18/21 Page2of4 The Honorable Alison J. Nathan October 18, 2021 Page 2 to Exclude Government Exhibit 52, an Unauthenticated Hearsay Document from Suspect Sources; to Exclude Items Purportedly Seized During Search of 358 El Brillo Way on October 20, 2005; to Suppress Identification; to Preclude Law Enforcement Witnesses from Offering Expert Opinion Testimony; to Preclude Testimony About Any Alleged "Rape" by Jeffrey Epstein; to Preclude Reference to the Accusers as "Victims" or "Minor Victims"; and to Preclude Introduction of Government's Exhibits 251, 288, 294, 313 and 606. Temporary Sealing Some of the memoranda and exhibits in support of the motions in /imine contain Confidential Information produced in discovery that is governed by paragraph 15 of the Protective Order (Dkt. 36). Accordingly, pursuant to our prior practice, we will not file the memoranda and exhibits on the public docket until we are instructed to do so by the Court. Instead, we will submit the memoranda and exhibits by email to the Court and the government under seal—pursuant to Rule 2(B) of the Court’s individual rules of criminal practice—to give both parties the opportunity to propose and justify any redactions it deems necessary. The government has agreed to do the same for its motions in /imine. We will, however, file the Notice of Motion and this cover letter on the public docket because they do not contain Confidential Information. Reservation of Rights to File Additional Motions in Limine As directed by the Court, we endeavored to comply with today’s filing deadline, but as previously raised with the government and the Court, additional time is required to determine DOJ-OGR-00005261