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Case 1:20-cr-00330-PAE Document 438 Filed 11/12/21 Page3of54 PRELIMINARY STATEMENT The Government respectfully submits the following motions in /imine. First, the Government respectfully requests that the Court protect the dignity and privacy of victims by permitting certain witnesses to testify under pseudonyms or using only their first names, and permitting the filing of related trial exhibits under seal. Second, the Government moves to admit prior consistent statements made by the minor victims in this case. Third, the Government moves to preclude the defense from distracting the jury with irrelevant and confusing testimony and argument relating to the investigative and prosecutive decisions of law enforcement agents and prosecutors. In particular, the Government moves to preclude the defense from calling agents from the Federal Bureau of Investigation (“FBI”), in an improper effort to put the Government on trial. Fourth, and relatedly, the Government respectfully requests that the Court preclude the defense from offering argument or evidence at trial in support of the defense’s unfounded theory that the Government is prosecuting the defendant for nefarious reasons. Fifth, the Government moves to preclude the defense from attempting to impeach the credibility of individuals who will not be witnesses at trial. Sixth, consent is not a legal defense in this case, and the defense should be precluded from suggesting to the jury that the victims consented to their abuse. Seventh, the Government requests that the Court require the defendant to explain the relevance of any evidence she seeks to offer showing that she did not commit crimes with which she is not charged, before she offers that evidence or makes argument based on that evidence. Eighth, the Government requests that the Court preclude the defense from offering out-of-court statements by the defendant, which are hearsay. Ninth, the Government moves to preclude the defense from offering irrelevant evidence to garner sympathy for the defendant. | Z DOJ-OGR-00006363