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Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 38 of 52 activity for which the defendant could be charged with specific New Jersey, Pennsylvania, New York, and Canadian criminal offenses” (emphasis added)). Accordingly, the Court should give the jury the defense’s requested limiting instruction.® V. THE GOVERNMENT CONCEDES THAT IT WILL NOT OFFER EVIDENCE OF MS. MAXWELL’S ALLEGED “FLIGHT” The government has conceded that it will not elicit any evidence or argue to the jury that Ms. Maxwell “was hiding from, evading, or fleeing from law enforcement between Epstein’s arrest and her own.” Resp. at 81-82. VI. THE GOVERNMENT CONCEDES THAT IT WILL NOT OFFER EVIDENCE OF MS. MAXWELL’S ALLEGED FALSE STATEMENTS AND AGREES TO MS. MAXWELL’S PROPOSED REDACTIONS The government has also conceded that it will not elicit any evidence concerning Ms. Maxwell’s alleged false statements in her 2016 depositions and agrees to the defense’s request to redact the perjury counts and related allegations from the S2 Indictment. Resp. at 82. VII. THE COURT SHOULD HOLD A PRE-TRIAL EVIDENTIARY HEARING ON MS. MAXWELL’S MOTION TO SUPPRESS IDENTIFICATION. From approximate! [ll SS a * The defense also agrees with the government that the Court should instruct the jury that it cannot convict Ms. Maxwell of the charged conspiracies based solely on evidence. See Resp. at 50 n.12. ae DOJ-OGR-00006918