DOJ-OGR-00005396.jpg
715 KB
Extraction Summary
5
People
3
Organizations
0
Locations
2
Events
2
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
715 KB
Summary
This legal document is a preliminary statement from the Government, filed on October 29, 2021, in case 1:20-cr-00330-PAE. The Government submits nine motions in limine to the Court, seeking to set the rules for an upcoming trial. The motions aim to protect victims' privacy, admit certain statements, and preclude the defense from introducing what the Government considers irrelevant, confusing, or improper evidence and arguments, such as questioning law enforcement decisions or attempting to garner sympathy for the defendant.
People (5)
| Name | Role | Context |
|---|---|---|
| victims | Victim |
Mentioned as individuals whose dignity and privacy the Government seeks to protect, and as minor victims whose prior ...
|
| witnesses | Witness |
The Government requests that certain witnesses be permitted to testify under pseudonyms or first names. Also mentione...
|
| law enforcement agents | Law Enforcement Agent |
The Government seeks to preclude the defense from presenting testimony and argument related to their investigative de...
|
| prosecutors | Prosecutor |
The Government seeks to preclude the defense from presenting testimony and argument related to their prosecutive deci...
|
| defendant | Defendant |
The subject of the prosecution. The Government's motions aim to limit the evidence and arguments the defense can pres...
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Government | government agency |
The prosecuting party submitting motions in limine to the Court.
|
| The Court | government agency |
The judicial body being asked to rule on the Government's motions.
|
| Federal Bureau of Investigation (“FBI”) | government agency |
The Government moves to preclude the defense from calling FBI agents to testify.
|
Timeline (2 events)
The Government submitted nine motions in limine in preparation for trial.
The document discusses preparations and rules for an upcoming trial.
Relationships (2)
The document consists of the Government filing motions to preclude and limit the arguments and evidence that the defense can present at trial.
Full Extracted Text
Complete text extracted from the document (2,070 characters)
Case 1:20-cr-00330-PAE Document 380 Filed 10/29/21 Page 3 of 54
PRELIMINARY STATEMENT
The Government respectfully submits the following motions in limine. First, the
Government respectfully requests that the Court protect the dignity and privacy of victims by
permitting certain witnesses to testify under pseudonyms or using only their first names, and
permitting the filing of related trial exhibits under seal. Second, the Government moves to admit
prior consistent statements made by the minor victims in this case. Third, the Government
moves to preclude the defense from distracting the jury with irrelevant and confusing testimony
and argument relating to the investigative and prosecutive decisions of law enforcement agents
and prosecutors. In particular, the Government moves to preclude the defense from calling
agents from the Federal Bureau of Investigation (“FBI”), in an improper effort to put the
Government on trial. Fourth, and relatedly, the Government respectfully requests that the Court
preclude the defense from offering argument or evidence at trial in support of the defense’s
unfounded theory that the Government is prosecuting the defendant for nefarious reasons. Fifth,
the Government moves to preclude the defense from attempting to impeach the credibility of
individuals who will not be witnesses at trial. Sixth, consent is not a legal defense in this case,
and the defense should be precluded from suggesting to the jury that the victims consented to
their abuse. Seventh, the Government requests that the Court require the defendant to explain the
relevance of any evidence she seeks to offer showing that she did not commit crimes with which
she is not charged, before she offers that evidence or makes argument based on that evidence.
Eighth, the Government requests that the Court preclude the defense from offering out-of-court
statements by the defendant, which are hearsay. Ninth, the Government moves to preclude the
defense from offering irrelevant evidence to garner sympathy for the defendant. [REDACTED]
Government respectfully requests that the Court protect the dignity and privacy of victims by
permitting certain witnesses to testify under pseudonyms or using only their first names, and
permitting the filing of related trial exhibits under seal. Second, the Government moves to admit
prior consistent statements made by the minor victims in this case. Third, the Government
moves to preclude the defense from distracting the jury with irrelevant and confusing testimony
and argument relating to the investigative and prosecutive decisions of law enforcement agents
and prosecutors. In particular, the Government moves to preclude the defense from calling
agents from the Federal Bureau of Investigation (“FBI”), in an improper effort to put the
Government on trial. Fourth, and relatedly, the Government respectfully requests that the Court
preclude the defense from offering argument or evidence at trial in support of the defense’s
unfounded theory that the Government is prosecuting the defendant for nefarious reasons. Fifth,
the Government moves to preclude the defense from attempting to impeach the credibility of
individuals who will not be witnesses at trial. Sixth, consent is not a legal defense in this case,
and the defense should be precluded from suggesting to the jury that the victims consented to
their abuse. Seventh, the Government requests that the Court require the defendant to explain the
relevance of any evidence she seeks to offer showing that she did not commit crimes with which
she is not charged, before she offers that evidence or makes argument based on that evidence.
Eighth, the Government requests that the Court preclude the defense from offering out-of-court
statements by the defendant, which are hearsay. Ninth, the Government moves to preclude the
defense from offering irrelevant evidence to garner sympathy for the defendant. [REDACTED]
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DOJ-OGR-00005396
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