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Case 1:05-cr-00394-RBW     Document 274-1     Filed 02/08/2007     Page 1 of 4

RESPONSE OF DEFENDANT I. LEWIS LIBBY TO GOVERNMENT'S MOTIONS IN
LIMINE CONCERNING IMPEACHMENT OF PROSECUTION WITNESSES

    The government has filed two motions seeking to insulate its witnesses from attacks on their credibility: a general motion in limine, which recites a series of abstract and largely undisputed principles that govern impeachment evidence, ¹ and a motion to exclude the testimony of Jill Abramson, who will impeach government witness Judith Miller on a critical point. ² The Court should deny both motions and address evidentiary issues as they arise during the testimony.

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Case 1:05-cr-00394-RBW     Document 274-1     Filed 02/08/2007     Page 2 of 4

Case 1:05-cr-00394-RBW     Document 274-1     Filed 02/08/2007     Page 3 of 4

Case 1:05-cr-00394-RBW     Document 274-1     Filed 02/08/2007     Page 4 of 4

CONCLUSION

    For the foregoing reasons, the Court should deny the government's motions in limine and address objections as they arise during the testimony of the defense impeachment witnesses. Date: February 8, 2007

posted by cboldt  # 2/08/2007 09:42:00 AM