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be N Ww ws Oo OY ~] oO WO Ww a OY 20 21 22 23 24 25 Case 1:20-cr-00330-PAE Document 549-1 Filed 12/17/21 Page 10 of 24 22 LB1ITMAX1 ubstantially confuse and delay the trial. The evidence (0) utlined in the defense's papers, including who was interviewed e) and when, what documents were subpoenaed and other details of investigations in two different states and different time periods would substantially expand the scope of the trial. Exactly what steps investigators took is not a simple question, of course. The government would likely present a contrary account of events, leading to trials within trials on what law enforcement did over the course of years. This prejudice would substantially outweigh any minimum probative value that might be gained from such a far-flung endeavor. Third, as to prejudice, th vidence would be cumulative, demonstrating that an investigation was "hasty" and not thorough is at best repetitive of the defense's arguments that the government collected insufficient evidence of guilt. That point is made most clearly and directly by focusing on the evidence or lack of evidence and credibility or lack of credibility of the witnesses presented at trial. The second piece of guidance I can provide now is that the Court will exclude much of the evidence outlined in the defense's papers of the government's alleged motives for investigating and charging Ms. Maxwell. This evidence includes but is not limited to the Miami Herald article, statements from Attorney General William Barr and the like. Th vidence presented by the government in this trial SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00008404