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Case 1:20-cr-00330-PAE Document508 _ Filed 11/24/21 Page/7of25 cy are not unfairly prejudicial or otherwise inadmissible. And because the government’s other arguments are undeveloped or unsuited for resolution pretrial—the government is always free to raise specific evidentiary objections in context—this Court should reject the government’s request to preclude Dr. Hall from testifying. A. Factual background. Accuser-4, iE is the named victim in several of the counts against Ms. Maxwell, including conspiracy. The government claims she was abused by Mr. Epstein from 2001 to 2004. RS Mo! x. B. Dr. Hall reviewed EE ¢cords, and interviewed yy over the course of 6 % hours. /d. at 1, 2. Dr. Hall produced a 108-page report (which the government produced to Ms. Maxwell, recognizing its relevance and exculpatory value). As is relevant to the government’s motion to preclude Dr. Hall from testifying, the report addresses two areas that are essential to Ms. Maxwell’s defense in this case: fF DOJ-OGR- 00008092