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Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 64 of 69 examples were given, the Court finds that this is too vague a category to grant the relief requested."). The government has not explained why they believe that counsel does not understand these rules or what evidence (beyond "charitable works" or "evidence of her family history") that they expect to be offered at trial. If the topic of "charitable works" comes up in the government's case, then topics of Ms. Maxwell's "charitable works" may become relevant. If the topic of Ms. Maxwell's family history is elicited or argued by the government, then topics of Ms. Maxwell's family history may become relevant. One wonders if the government is suggesting these topics because it intends to try to elicit some testimony on these topics and then preclude Ms. Maxwell from responding. If that were the case, then the government should have said so in their Motion. Regardless, there is no reason for the Court to enter any orders on this topic. Ms. Maxwell will tender evidence on cross examination and in her defense case that is relevant. The government is free to make any objections it deems appropriate at that time, with reference to any evidence the government has already elicited from the witnesses and in opening statements. X. REQUEST TO PREVIEW DEFENSE'S EVIDENCE SHOULD BE DENIED The government would like nothing better than for the Court to require defense counsel to have their hands tied behind their back and their mouths duct-taped while the accusers, and related witnesses, testify under anonymity, [ll Re. 'f the government wants to preclude the interposing of defenses, it should dismiss the case. The government is not and should not be privy to the defenses Ms. Maxwell may interpose at trial, despite the claim that the government’s “years-long investigation has not developed any evidence that the defendant was victimized in any way by Jeffrey Epstein” and defense counsel made not factual assertions regarding victimization. (Mot. at 49). Perhaps the 56 DOJ-OGR-00006481