{
  "document_metadata": {
    "page_number": "9",
    "document_number": "382",
    "date": "10/29/21",
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  "full_text": "Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 9 of 69\n\nGhislaine Maxwell herby submits her response to the Government's Omnibus Motions in Limine.\n\nPRELIMINARY STATEMENT\n\nThe government's self-described \"Motions in Limine\" are an ill-founded attempt to:\n\n(1) improperly obtain advisory rulings from the Court on an undeveloped factual record;\n\n(2) prematurely, and unconstitutionally, force Ms. Maxwell to reveal defense theories, strategies, and cross-examination; (3) improperly limit Ms. Maxwell's defenses; and (4) inappropriately enlist the Court in vouching for the credibility of the accusers by the use of pseudonyms and other artifices.\n\nFor the most part, the issues raised by the government cannot, and should not, be addressed pretrial because the Court lacks the necessary facts to make intelligent rulings. The issues raised under headings II-XI should be denied on this basis alone. The arguments related to the use of pseudonyms and other artifices fails because the limitations suggested by the government will: (1) unconstitutionally restrict Ms. Maxwell's confrontation rights; (2) run afoul of both her right to a public trial and the First Amendment right to public access, and (3) are simply unworkable as a practical matter inviting a mistrial.\n\nA. The True Purpose of a Motion in Limine\n\nThe purpose of a motion in limine is to allow the trial court to rule in advance of trial on the admissibility of certain forecasted evidence. See Luce v. United States, 469 U.S. 38, 40 n. 2 (1984) (explaining that the motion in limine is used to \"to exclude anticipated prejudicial evidence before the evidence is actually offered\"); see also Palmieri v. Defaria et al., 88 F.3d 136, 141 (2d Cir. 1996) (\"The purpose of an in limine motion is to aid the trial process by enabling the Court to rule in advance of trial on the relevance of certain forecasted evidence, as\n\n1\n\nDOJ-OGR-00005464",
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      "content": "Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 9 of 69",
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    {
      "type": "printed",
      "content": "Ghislaine Maxwell herby submits her response to the Government's Omnibus Motions in Limine.",
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    {
      "type": "printed",
      "content": "PRELIMINARY STATEMENT",
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      "content": "The government's self-described \"Motions in Limine\" are an ill-founded attempt to:\n\n(1) improperly obtain advisory rulings from the Court on an undeveloped factual record;\n\n(2) prematurely, and unconstitutionally, force Ms. Maxwell to reveal defense theories, strategies, and cross-examination; (3) improperly limit Ms. Maxwell's defenses; and (4) inappropriately enlist the Court in vouching for the credibility of the accusers by the use of pseudonyms and other artifices.",
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    {
      "type": "printed",
      "content": "For the most part, the issues raised by the government cannot, and should not, be addressed pretrial because the Court lacks the necessary facts to make intelligent rulings. The issues raised under headings II-XI should be denied on this basis alone. The arguments related to the use of pseudonyms and other artifices fails because the limitations suggested by the government will: (1) unconstitutionally restrict Ms. Maxwell's confrontation rights; (2) run afoul of both her right to a public trial and the First Amendment right to public access, and (3) are simply unworkable as a practical matter inviting a mistrial.",
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    {
      "type": "printed",
      "content": "A. The True Purpose of a Motion in Limine",
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    {
      "type": "printed",
      "content": "The purpose of a motion in limine is to allow the trial court to rule in advance of trial on the admissibility of certain forecasted evidence. See Luce v. United States, 469 U.S. 38, 40 n. 2 (1984) (explaining that the motion in limine is used to \"to exclude anticipated prejudicial evidence before the evidence is actually offered\"); see also Palmieri v. Defaria et al., 88 F.3d 136, 141 (2d Cir. 1996) (\"The purpose of an in limine motion is to aid the trial process by enabling the Court to rule in advance of trial on the relevance of certain forecasted evidence, as",
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      "content": "DOJ-OGR-00005464",
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  "entities": {
    "people": [
      "Ghislaine Maxwell",
      "Luce",
      "Palmieri",
      "Defaria"
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    "organizations": [
      "Government",
      "Court"
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    "locations": [],
    "dates": [
      "10/29/21",
      "1984",
      "1996"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 382",
      "DOJ-OGR-00005464"
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}