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Case 1:20-cr-00330-PAE Document 392 Filed 10/29/21 Page4of8 Defendant Ghislaine Maxwell, through counsel, moves to prohibit the Government from offering testimony from Accuser 4 a identifying Ms. Maxwell as a perpetrator of any crime. Any in-court identification is tainted by unduly suggestive photo array procedures employed by the Government that violate Ms. Maxwell’s right to due process under the United States Constitution for the following reasons: BACKGROUND Accuser 4, i was first contacted by the FBI in 2007. xg was interviewed on August 7, 2007 by Agents i and asked about any abuse by Jeffrey Epstein. x SSCS HE id not identify Ms. Maxwell as someone who recruited her, groomed her, or otherwise interacted with her in Palm Beach, Florida, or any other location. She identified yyy WM 2s someone she interacted with and who took nude photographs of her at Mr. Epstein’s circ. lls After her FBI interview, J tepresented by counsel, filed gg lawsuits against Jeffrey Epstein i BE. Neither of those lawsuits mentions Ms. Maxwell. yg eS ee ee During her deposition in connection with the lawsuit, eC ES She cid not identify Ms. Maxwell as having had any role in any alleged sexual abuse or trafficking. DOJ-OGR-00005741