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Case 1:20-cr-00330-PAE Document 444 _ Filed 11/12/21 Page 20of21 CONCLUSION For the foregoing reasons, the Court should exclude evidence related to Accuser-3 because it is not probative of the charged conspiracies and inadmissible under Rule 404(b) and Rule 403 of the Federal Rules of Evidence. In the alternative, Ms. Maxwell respectfully requests that the Court (1) preclude the government and Accuser-3 from referring to Accuser-3 as a “minor” or asserting that she was a “minor” at the time of the alleged sex acts, (2) preclude the government and Accuser-3 from representing that she was “sexually abused” by Jeffrey Epstein, and (3) give the jury an appropriate limiting instruction concerning Accuser-3’s testimony that includes the points discussed above. Dated: October 18, 2021 New York, New York Respectfully submitted, /s/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 225 Broadway, Suite 715 New York, NY 10007 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell 16 DOJ-OGR-00006646