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be N Ww ws Oo OY ~] oO WO a oO = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 1:20-cr-00330-PAE Document 549-1 LB1TMAX1 to the jury's decision of Ms. Maxwell's guilt now, which is wheth Filed 12/17/21 Page 15 of 24 27 r there is evidenc t beyond a reasonable government will put it Now there is prior statements by the confron decisions. ts case to the jury. betw a differ ne n for impeachment purposes, doubt as the admitting a witness' which is protected tation clause, United States v. Borrero, and admitting In a case analogous to this one on another district cour prior charging this issue, t judge held that a defendant could permissibly cross-examine a witness about their prior statement to law ent di accused a fferent individual of de fendant That case admit the ended in a nolle, tended ex fact witness's statement. ual disputes, As appear to be true her Fi indicated may not come in, cross-examination of the government's witnesses. to impeach the credibility of fth piece ot was later charged. docket is 13 CR 58. 2013 WL 6 Bu charging decision that because it would cont fF guidance: and was, the Court will the crime at best, In contrast 020773 fuse jurors, (Ss. D.. Nw. forcement in which they for which the 2013). t the court there did not the early investigation had require cumulative of to what permit De the I have explained, the same would t relevant fense seeks some witnesses by admitting those witnesses' did not implicate Ms. to impeach a witness th prior statem M ents axwell. This use of to the government that p urportedly cross—-examination at has allegedly changed her story to SOUTHERN D STR CT REPORT ERS, Ps (212) 805-0300 DOJ-OGR-00008409