📧 Communication

This document is a Preliminary Statement from a Government memorandum filed on October 29, 2021, in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). The Government argues against thirteen motions in limine filed by the defense, asserting the admissibility of expert testimony, evidence regarding Minor Victim-3 and Minor Victim-4, co-conspirator statements, and the use of the terms 'victim' and 'rape' during trial. The Government also notes it will not introduce evidence of the defendant's flight or false statements in its case-in-chief unless the defense opens the door.