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Case 1:20-cr-00330-PAE Document 445 Filed 11/12/21 Page5of11 Defendant Ghislaine Maxwell (“Ms. Maxwell”) files this Motion in Limine to Exclude Government Exhibit 52, an unauthenticated hearsay document from suspect sources, and states as follows: INTRODUCTION The Government has identified, as Exhibit 52, A-F, pages of an often photocopied and altered exhibit that has no identified author, date of creation, or custodian. These pages are from a 97-page exhibit provide to the Government from lawyers who represent multiple Epstein accusers. The document, as produced to the Government, is attached as Exhibit 1. As produced, the document appears to be a compilation of material that was copied from more than one source, arranged, and paginated after the fact. There are unexplained faded marks that may have, at one time, been staples or evidence of staple holes. The top of page one of Exhibit | to this motion has six faded dots that look like a photocopy of a page that had three staples removed. Page four has shadows that resemble a page that was photocopied with staples in the page. It is impossible to tell whether pages have been added, omitted, cut or pasted. There are several examples of what appear to be photocopies of tabs, which suggest that pages have been added, omitted or altered because of the inconsistency from page to page. For example, tab-like shadows appear at page 20, but not on page 21-23; reappear on page 24; and disappear; and reappear within the remainder of the exhibit. At certain points -- pages 78 and 79, for example -- the tab-like shadows appear to be covered by something. The Government’s compilation has been cleaned up from what was produced from the civil litigation. However, no one can clean up the unsavory story of this purported exhibit. The document was not produced pursuant to any subpoena from a legitimate third-party custodian. Rather, the document appeared as part of discovery in the Giuffre v. Maxwell civil litigation case with no explanation about its origin. DOJ-OGR-00006654