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Case 1:20-cr-00330-PAE Document 358 Filed 10/18/21 Page 2 of 4
The Honorable Alison J. Nathan
October 18, 2021
Page 2

to Exclude Government Exhibit 52, an Unauthenticated Hearsay Document from
Suspect Sources;

to Exclude Items Purportedly Seized During Search of 358 El Brillo Way on October
20, 2005;

to Suppress Identification;

to Preclude Law Enforcement Witnesses from Offering Expert Opinion Testimony;

to Preclude Testimony About Any Alleged "Rape" by Jeffrey Epstein;

to Preclude Reference to the Accusers as "Victims" or "Minor Victims"; and

to Preclude Introduction of Government's Exhibits 251, 288, 294, 313 and 606.

Temporary Sealing

Some of the memoranda and exhibits in support of the motions in limine contain
Confidential Information produced in discovery that is governed by paragraph 15 of the
Protective Order (Dkt. 36). Accordingly, pursuant to our prior practice, we will not file the
memoranda and exhibits on the public docket until we are instructed to do so by the Court.
Instead, we will submit the memoranda and exhibits by email to the Court and the government
under seal—pursuant to Rule 2(B) of the Court’s individual rules of criminal practice—to give
both parties the opportunity to propose and justify any redactions it deems necessary. The
government has agreed to do the same for its motions in limine. We will, however, file the
Notice of Motion and this cover letter on the public docket because they do not contain
Confidential Information.

Reservation of Rights to File Additional Motions in Limine

As directed by the Court, we endeavored to comply with today’s filing deadline, but as
previously raised with the government and the Court, additional time is required to determine

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