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Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page7of9 This trial will turn on the credibility of the individuals accusing Ms. Maxwell of these crimes. The Court should allow broad cross-examination during the trial on general issues of bias and motive for fabrication to protect Ms. Maxwell’s rights under the Confrontation Clause of the United States Constitution. A criminal defendant “states a violation of the Confrontation Clause by showing that [s]he was prohibited from engaging in otherwise appropriate cross-examination designed to show a prototypical form of bias on the part of the witness, and thereby ‘to expose to the jury the facts from which jurors could appropriately draw inferences relating to the reliability of the witness.’” Delaware v. Van Arsdall, 475 U.S. 673 (1986) (quoting Davis v. Alaska, 415 U.S. 308, 318, (1974)). “[T]he exposure of a witness’ motivation in testifying is a proper and important function of the constitutionally protected right of cross-examination.’” Olden v. Kentucky, 488 U.S. 227, 231 (1988) (quoting Davis, 415 U.S. at 316-17). The possibility of an economic reward is classic impeachment material. United States v. Bagley, 473 U.S. 667, 684, (1985). Full and complete cross-examination of the Accusers is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Ms. Maxwell, as well as others. Cf Moore v. Marr, 254 F.3d 1235, 1244 (10th Cir. 2001) (noting that witnesses’ “application for victim compensation payments and application for and receipt of emergency victim compensation payments may well have been ‘favorable’ within the meaning of Brady,” requiring government disclosure of exculpatory evidence to criminal defendants); payments and promises made to cooperating witnesses. See also, United States v. DeLeon, 428 F. Supp. 3d 675, 697 (D.N.M. 2019); and United States v. Sedaghaty, 728 F.3d 885, 898 (9th Cir. 2013), “Impeachment evidence is especially likely to be material when it impugns the testimony” of witnesses “critical to the prosecution's case.” DOJ-OGR- 00007364