Podcasts about Exclude

Anton dives deep into the concept of building multi-store networks for high-ticket dropshipping. He shares his own journey from a single e-commerce shop to a multi-million-dollar network, and walks you through why niche-specific stores convert better, how to structure your business entity, and strategies to drive free and paid traffic across multiple sites.Key TakeawaysWhat Is a Multi-Store Network?Independent, niche-specific Shopify stores (e.g., bouncehousesplus.com, trampolinesplus.com, swingsetsplus.com)Cross-promotion flywheel: customer journeys between related nichesWhy Not One “Superstore”?Niche focus boosts conversion rate (CR) – e.g., 2.5% from targeted trafficSuperstores dilute authority, lower Return on Ad Spend (ROAS)Selecting Store NichesBrainstorm products that share a customer base (e.g., backyard play equipment)Exclude unrelated niches to preserve brand relevanceBusiness Structure & TaxesUse a single LLC (e.g., AK Stores LLC) with S-Corp tax electionSimplified accounting and exit strategy (sell the entire network)Cross-Promotion Traffic StrategiesOrder Confirmation EmailsMonthly Promotions & RemarketingScaling Your RevenueEarly strategy took Anton from ~$340K/year to ~$3.2M/yearEach store remains highly profitable on its own, but network multiplies ROINext Steps & ResourcesDrop any questions in the commentsFor in-depth niche research, store builds, and traffic modules, grab the free 2-hour webinar at dropshipwebinar.com

Discover all of the podcasts in our network, search for specific episodes, get the Optimal Living Daily workbook, and learn more at: OLDPodcast.com. Episode 3177: Jeremy Jacobson challenges the conventional wisdom of including home equity in retirement budgeting, emphasizing that doing so can create dangerous blind spots, especially during market downturns. By treating home equity separately and recognizing the benefits of imputed rent, retirees can protect their portfolios and maintain spending power without being forced into selling their homes or taking on unnecessary debt. Read along with the original article(s) here: https://www.gocurrycracker.com/mortgages-home-equity-and-retirement-spending/ Quotes to ponder: "Home equity is not included in our net worth for budgeting purposes. I plan to spend less than 4% of the remainder." "Exclude home equity from the portfolio." "Debt is leverage, which multiplies returns and losses." Episode references: Cfiresim: https://www.cfiresim.com/ Risk Parity Radio: https://www.riskparityradio.com/ Learn more about your ad choices. Visit megaphone.fm/adchoices

Discover all of the podcasts in our network, search for specific episodes, get the Optimal Living Daily workbook, and learn more at: OLDPodcast.com. Episode 3177: Jeremy Jacobson challenges the conventional wisdom of including home equity in retirement budgeting, emphasizing that doing so can create dangerous blind spots, especially during market downturns. By treating home equity separately and recognizing the benefits of imputed rent, retirees can protect their portfolios and maintain spending power without being forced into selling their homes or taking on unnecessary debt. Read along with the original article(s) here: https://www.gocurrycracker.com/mortgages-home-equity-and-retirement-spending/ Quotes to ponder: "Home equity is not included in our net worth for budgeting purposes. I plan to spend less than 4% of the remainder." "Exclude home equity from the portfolio." "Debt is leverage, which multiplies returns and losses." Episode references: Cfiresim: https://www.cfiresim.com/ Risk Parity Radio: https://www.riskparityradio.com/ Learn more about your ad choices. Visit megaphone.fm/adchoices

Discover all of the podcasts in our network, search for specific episodes, get the Optimal Living Daily workbook, and learn more at: OLDPodcast.com. Episode 3177: Jeremy Jacobson challenges the conventional wisdom of including home equity in retirement budgeting, emphasizing that doing so can create dangerous blind spots, especially during market downturns. By treating home equity separately and recognizing the benefits of imputed rent, retirees can protect their portfolios and maintain spending power without being forced into selling their homes or taking on unnecessary debt. Read along with the original article(s) here: https://www.gocurrycracker.com/mortgages-home-equity-and-retirement-spending/ Quotes to ponder: "Home equity is not included in our net worth for budgeting purposes. I plan to spend less than 4% of the remainder." "Exclude home equity from the portfolio." "Debt is leverage, which multiplies returns and losses." Episode references: Cfiresim: https://www.cfiresim.com/ Risk Parity Radio: https://www.riskparityradio.com/ Learn more about your ad choices. Visit megaphone.fm/adchoices

In a letter to Judge Subramanian, the Government opposed the defense's motion to strike exhibits GX E-331-F-R and GX E-331-H-R, which had already been admitted into evidence on June 6, 2025. The Government argued that these exhibits were properly admitted and remain central to proving the sex trafficking allegations against Sean Combs. The letter also addressed the defense's arguments, raised in their June 8th filing and discussed in court, suggesting that the Government's overarching theory of sex trafficking should be limited or curtailed.The prosecution maintained that its theory of sex trafficking, as presented to the jury, is fully supported by both the law and the evidence admitted thus far. The letter emphasized that the exhibits in question are not only relevant but critical to establishing the elements of the trafficking offense, particularly in demonstrating the coercion, pattern of conduct, and exploitation alleged. The Government urged the Court to reject the defense's attempt to narrow the scope of the case or to exclude key evidence that speaks directly to the heart of the charges.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.396.0.pdf

In this letter to Judge Subramanian, the defense opposes the government's plan to introduce certain testimony from Dawn Richard. The defense argues that the government intends to elicit inadmissible and irrelevant testimony regarding alleged statements and purported threats made by Sean Combs and Bad Boy Records President Harve Pierre. They contend that such statements, along with Ms. Richard's subjective understanding of them, fall outside the scope of permissible evidence and would unfairly prejudice the jury.The defense asserts that allowing this line of testimony would improperly introduce speculative and potentially inflammatory material that lacks proper evidentiary foundation. They request that the Court preclude the government from eliciting or offering this evidence through Ms. Richard, maintaining that it does not meet the standards for admissibility and risks distracting the jury from the core issues of the case.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.398.0.pdf

In a letter to Judge Subramanian, the Government opposed the defense's motion to strike exhibits GX E-331-F-R and GX E-331-H-R, which had already been admitted into evidence on June 6, 2025. The Government argued that these exhibits were properly admitted and remain central to proving the sex trafficking allegations against Sean Combs. The letter also addressed the defense's arguments, raised in their June 8th filing and discussed in court, suggesting that the Government's overarching theory of sex trafficking should be limited or curtailed.The prosecution maintained that its theory of sex trafficking, as presented to the jury, is fully supported by both the law and the evidence admitted thus far. The letter emphasized that the exhibits in question are not only relevant but critical to establishing the elements of the trafficking offense, particularly in demonstrating the coercion, pattern of conduct, and exploitation alleged. The Government urged the Court to reject the defense's attempt to narrow the scope of the case or to exclude key evidence that speaks directly to the heart of the charges.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.396.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

Federal prosecutors have filed a motion to exclude testimony from Dr. Elie Aoun, a forensic psychiatrist and assistant professor at Columbia University, whom Sean "Diddy" Combs' defense team intends to call as an expert witness. The defense aims to have Dr. Aoun testify regarding Combs' mental state during the period of the alleged offenses, suggesting that Combs may have had diminished mental capacity. However, the government argues that Dr. Aoun's proposed testimony is inadmissible under the Insanity Defense Reform Act of 1984 and Federal Rule of Criminal Procedure 12.2, which govern the introduction of expert testimony related to a defendant's mental condition. Prosecutors contend that Dr. Aoun's opinions lack a reliable scientific basis and appear to be speculative, rendering them unsuitable for presentation to the jury.Additionally, the government asserts that allowing Dr. Aoun's testimony would effectively permit the defense to introduce a mental health defense without adhering to the procedural requirements mandated by law. They argue that the defense has not provided sufficient notice or evidence to support such a defense, and that Dr. Aoun's testimony would serve as a substitute for calling actual witnesses, thereby circumventing the rules of evidence. The prosecution maintains that admitting this testimony could mislead the jury and prejudice the government's case, and therefore, they urge the court to preclude Dr. Aoun from testifying at trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.276.0_1.pdf

Federal prosecutors have filed a motion to exclude testimony from Conor McCourt, a former NYPD sergeant and forensic video analyst, whom Sean "Diddy" Combs' defense team intends to call as an expert witness. McCourt analyzed surveillance footage of an alleged 2016 assault involving Combs and concluded that the videos were distorted and not faithful representations of the events. The government contends that McCourt's testimony should be barred due to the defense's untimely and incomplete disclosure, which failed to meet the requirements set by Rule 16 of the Federal Rules of Criminal Procedure. Specifically, the defense did not provide a comprehensive summary of McCourt's opinions, his qualifications, or a list of prior cases where he testified as an expert, all of which were due by March 14, 2025. The government argues that this delay hindered its ability to prepare a rebuttal and prejudiced its caseBeyond procedural issues, prosecutors assert that McCourt's anticipated testimony lacks substantial probative value and could mislead the jury. They argue that his technical critiques—such as claims about video distortion and transcoding artifacts—are speculative and unlikely to assist jurors in understanding the evidence. Furthermore, the government warns that presenting McCourt as an expert may unduly influence the jury, giving his opinions more weight than warranted. They also note that McCourt's analysis includes videos not intended for presentation at trial, rendering parts of his testimony irrelevant. Consequently, the government urges the court to exclude McCourt's testimony entirely or, at the very least, limit it under Federal Rules of Evidence 403 and 702 to prevent confusion and ensure a fair trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.277.0.pdf

Federal prosecutors have filed a motion to exclude testimony from Dr. Elie Aoun, a forensic psychiatrist and assistant professor at Columbia University, whom Sean "Diddy" Combs' defense team intends to call as an expert witness. The defense aims to have Dr. Aoun testify regarding Combs' mental state during the period of the alleged offenses, suggesting that Combs may have had diminished mental capacity. However, the government argues that Dr. Aoun's proposed testimony is inadmissible under the Insanity Defense Reform Act of 1984 and Federal Rule of Criminal Procedure 12.2, which govern the introduction of expert testimony related to a defendant's mental condition. Prosecutors contend that Dr. Aoun's opinions lack a reliable scientific basis and appear to be speculative, rendering them unsuitable for presentation to the jury.Additionally, the government asserts that allowing Dr. Aoun's testimony would effectively permit the defense to introduce a mental health defense without adhering to the procedural requirements mandated by law. They argue that the defense has not provided sufficient notice or evidence to support such a defense, and that Dr. Aoun's testimony would serve as a substitute for calling actual witnesses, thereby circumventing the rules of evidence. The prosecution maintains that admitting this testimony could mislead the jury and prejudice the government's case, and therefore, they urge the court to preclude Dr. Aoun from testifying at trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.276.0_1.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

Federal prosecutors have filed a motion to exclude testimony from Conor McCourt, a former NYPD sergeant and forensic video analyst, whom Sean "Diddy" Combs' defense team intends to call as an expert witness. McCourt analyzed surveillance footage of an alleged 2016 assault involving Combs and concluded that the videos were distorted and not faithful representations of the events. The government contends that McCourt's testimony should be barred due to the defense's untimely and incomplete disclosure, which failed to meet the requirements set by Rule 16 of the Federal Rules of Criminal Procedure. Specifically, the defense did not provide a comprehensive summary of McCourt's opinions, his qualifications, or a list of prior cases where he testified as an expert, all of which were due by March 14, 2025. The government argues that this delay hindered its ability to prepare a rebuttal and prejudiced its caseBeyond procedural issues, prosecutors assert that McCourt's anticipated testimony lacks substantial probative value and could mislead the jury. They argue that his technical critiques—such as claims about video distortion and transcoding artifacts—are speculative and unlikely to assist jurors in understanding the evidence. Furthermore, the government warns that presenting McCourt as an expert may unduly influence the jury, giving his opinions more weight than warranted. They also note that McCourt's analysis includes videos not intended for presentation at trial, rendering parts of his testimony irrelevant. Consequently, the government urges the court to exclude McCourt's testimony entirely or, at the very least, limit it under Federal Rules of Evidence 403 and 702 to prevent confusion and ensure a fair trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.277.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-moscow-murders-and-more--5852883/support.

Federal prosecutors have filed a motion to exclude testimony from Conor McCourt, a former NYPD sergeant and forensic video analyst, whom Sean "Diddy" Combs' defense team intends to call as an expert witness. McCourt analyzed surveillance footage of an alleged 2016 assault involving Combs and concluded that the videos were distorted and not faithful representations of the events. The government contends that McCourt's testimony should be barred due to the defense's untimely and incomplete disclosure, which failed to meet the requirements set by Rule 16 of the Federal Rules of Criminal Procedure. Specifically, the defense did not provide a comprehensive summary of McCourt's opinions, his qualifications, or a list of prior cases where he testified as an expert, all of which were due by March 14, 2025. The government argues that this delay hindered its ability to prepare a rebuttal and prejudiced its caseBeyond procedural issues, prosecutors assert that McCourt's anticipated testimony lacks substantial probative value and could mislead the jury. They argue that his technical critiques—such as claims about video distortion and transcoding artifacts—are speculative and unlikely to assist jurors in understanding the evidence. Furthermore, the government warns that presenting McCourt as an expert may unduly influence the jury, giving his opinions more weight than warranted. They also note that McCourt's analysis includes videos not intended for presentation at trial, rendering parts of his testimony irrelevant. Consequently, the government urges the court to exclude McCourt's testimony entirely or, at the very least, limit it under Federal Rules of Evidence 403 and 702 to prevent confusion and ensure a fair trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.277.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

– Should I invest in an ETF that excludes banks and miners? – Is value investing dead? – Can insider ownership be bad? – Do I have enough Super? – Lay off Australia!See omnystudio.com/listener for privacy information.

​Bryan Kohberger, charged with the 2022 murders of four University of Idaho students, has been diagnosed with autism spectrum disorder (ASD), according to his defense attorney, Anne Taylor. Taylor argues that this diagnosis should exempt him from the death penalty, contending that ASD diminishes his culpability and that his behaviors, such as avoiding eye contact and repetitive movements, might be misinterpreted by jurors as signs of guilt or lack of remorse. She also highlights that Kohberger's ASD-related communication challenges hinder his ability to participate effectively in his defense.Legal experts, however, are skeptical of this argument's success. They note that while ASD can be considered a mitigating factor during sentencing, it does not typically preclude the application of the death penalty. In Idaho, the death penalty is applicable unless the defendant is intellectually disabled, a criterion distinct from ASD. Therefore, despite the defense's efforts, it is unlikely that Kohberger's ASD diagnosis will prevent prosecutors from seeking capital punishment in this case.to contact  me:bobbycapucci@protonmail.comsource:Kohberger's team: Autism should negate Idaho death penalty. Experts say it's a stretchBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-moscow-murders-and-more--5852883/support.

Welcome to episode 162 of Growers Daily! We cover: if woodchips can be contaminated (like compost can), pests that refuse to be kept out, and buying the right broadfork. We are a Non-Profit! 

This document is a motion in limine filed by Sean Combs' legal team in his federal criminal case (Case No. 24-cr-542) in the Southern District of New York, seeking to exclude the testimony of Dr. Dawn Hughes, a psychological expert the prosecution intends to call. Dr. Hughes is expected to testify about general behavioral patterns of victims and perpetrators of sexual and domestic abuse, which the defense argues would unfairly bolster the credibility of the government's witnesses — including alleged victims — without having evaluated any facts specific to this case. The defense asserts that Dr. Hughes's testimony is not based on a reliable scientific application to the actual circumstances surrounding Combs and instead consists of broad generalizations that risk misleading the jury by presenting “typical” abuse behavior as evidence of guilt.Combs' attorneys argue that Hughes's proposed testimony violates the standards set by Federal Rules of Evidence 702 and 403, which regulate expert witness admissibility. They claim her statements offer no specialized knowledge beyond what jurors already understand — such as abusers exploiting power or victims remaining in abusive relationships — and that she conflates clinical definitions of coercion with legal ones, potentially confusing the jury. The motion asserts that Hughes's testimony is “advocacy masquerading as expertise” and warns it would improperly bolster the credibility of government witnesses under the guise of psychology. The defense urges the court to block her from testifying, citing that her opinions are methodologically unsound and prejudicial rather than probative.to contact  me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.206.0.pdf

This document is a motion in limine filed by Sean Combs' legal team in his federal criminal case (Case No. 24-cr-542) in the Southern District of New York, seeking to exclude the testimony of Dr. Dawn Hughes, a psychological expert the prosecution intends to call. Dr. Hughes is expected to testify about general behavioral patterns of victims and perpetrators of sexual and domestic abuse, which the defense argues would unfairly bolster the credibility of the government's witnesses — including alleged victims — without having evaluated any facts specific to this case. The defense asserts that Dr. Hughes's testimony is not based on a reliable scientific application to the actual circumstances surrounding Combs and instead consists of broad generalizations that risk misleading the jury by presenting “typical” abuse behavior as evidence of guilt.Combs' attorneys argue that Hughes's proposed testimony violates the standards set by Federal Rules of Evidence 702 and 403, which regulate expert witness admissibility. They claim her statements offer no specialized knowledge beyond what jurors already understand — such as abusers exploiting power or victims remaining in abusive relationships — and that she conflates clinical definitions of coercion with legal ones, potentially confusing the jury. The motion asserts that Hughes's testimony is “advocacy masquerading as expertise” and warns it would improperly bolster the credibility of government witnesses under the guise of psychology. The defense urges the court to block her from testifying, citing that her opinions are methodologically unsound and prejudicial rather than probative.to contact  me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.206.0.pdf

In this filing, the defense team for Sean “Diddy” Combs renews its motion to exclude certain summary charts the government intends to introduce as evidence under Federal Rule of Evidence 1006. The defense argues that these charts are not neutral summaries of voluminous records—as Rule 1006 requires—but rather argumentative presentations designed to convey the government's interpretation of the evidence. They point to a prior concession by the government acknowledging that the charts are not intended to prove specific facts, but to help “present the government's theory,” which the defense contends renders them inherently prejudicial and inadmissible. The defense notes that while the court previously reserved judgment pending a review of the government's draft charts, the newly submitted versions confirm their earlier concerns.The defense further emphasizes that these charts violate the spirit and letter of Rule 1006, which was designed to allow juries to more easily digest large volumes of data—not to serve as vehicles for a party's argument. By framing the charts as interpretive rather than objective, the defense argues that the government is improperly using visual aids to bolster its narrative in a way that is likely to mislead the jury and unfairly prejudice Mr. Combs. They assert that this tactic runs counter to guidance from the Rules Advisory Committee, which warns against using summary evidence to argue a party's case rather than present underlying facts. On these grounds, the defense requests that the court preclude the government from introducing the proposed summary exhibits at trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.357.0.pdf

This document is a motion in limine filed by Sean Combs' legal team in his federal criminal case (Case No. 24-cr-542) in the Southern District of New York, seeking to exclude the testimony of Dr. Dawn Hughes, a psychological expert the prosecution intends to call. Dr. Hughes is expected to testify about general behavioral patterns of victims and perpetrators of sexual and domestic abuse, which the defense argues would unfairly bolster the credibility of the government's witnesses — including alleged victims — without having evaluated any facts specific to this case. The defense asserts that Dr. Hughes's testimony is not based on a reliable scientific application to the actual circumstances surrounding Combs and instead consists of broad generalizations that risk misleading the jury by presenting “typical” abuse behavior as evidence of guilt.Combs' attorneys argue that Hughes's proposed testimony violates the standards set by Federal Rules of Evidence 702 and 403, which regulate expert witness admissibility. They claim her statements offer no specialized knowledge beyond what jurors already understand — such as abusers exploiting power or victims remaining in abusive relationships — and that she conflates clinical definitions of coercion with legal ones, potentially confusing the jury. The motion asserts that Hughes's testimony is “advocacy masquerading as expertise” and warns it would improperly bolster the credibility of government witnesses under the guise of psychology. The defense urges the court to block her from testifying, citing that her opinions are methodologically unsound and prejudicial rather than probative.to contact  me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.206.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-moscow-murders-and-more--5852883/support.

This document is a motion in limine filed by Sean Combs' legal team in his federal criminal case (Case No. 24-cr-542) in the Southern District of New York, seeking to exclude the testimony of Dr. Dawn Hughes, a psychological expert the prosecution intends to call. Dr. Hughes is expected to testify about general behavioral patterns of victims and perpetrators of sexual and domestic abuse, which the defense argues would unfairly bolster the credibility of the government's witnesses — including alleged victims — without having evaluated any facts specific to this case. The defense asserts that Dr. Hughes's testimony is not based on a reliable scientific application to the actual circumstances surrounding Combs and instead consists of broad generalizations that risk misleading the jury by presenting “typical” abuse behavior as evidence of guilt.Combs' attorneys argue that Hughes's proposed testimony violates the standards set by Federal Rules of Evidence 702 and 403, which regulate expert witness admissibility. They claim her statements offer no specialized knowledge beyond what jurors already understand — such as abusers exploiting power or victims remaining in abusive relationships — and that she conflates clinical definitions of coercion with legal ones, potentially confusing the jury. The motion asserts that Hughes's testimony is “advocacy masquerading as expertise” and warns it would improperly bolster the credibility of government witnesses under the guise of psychology. The defense urges the court to block her from testifying, citing that her opinions are methodologically unsound and prejudicial rather than probative.to contact  me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.206.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-moscow-murders-and-more--5852883/support.

In this filing, the defense team for Sean “Diddy” Combs renews its motion to exclude certain summary charts the government intends to introduce as evidence under Federal Rule of Evidence 1006. The defense argues that these charts are not neutral summaries of voluminous records—as Rule 1006 requires—but rather argumentative presentations designed to convey the government's interpretation of the evidence. They point to a prior concession by the government acknowledging that the charts are not intended to prove specific facts, but to help “present the government's theory,” which the defense contends renders them inherently prejudicial and inadmissible. The defense notes that while the court previously reserved judgment pending a review of the government's draft charts, the newly submitted versions confirm their earlier concerns.The defense further emphasizes that these charts violate the spirit and letter of Rule 1006, which was designed to allow juries to more easily digest large volumes of data—not to serve as vehicles for a party's argument. By framing the charts as interpretive rather than objective, the defense argues that the government is improperly using visual aids to bolster its narrative in a way that is likely to mislead the jury and unfairly prejudice Mr. Combs. They assert that this tactic runs counter to guidance from the Rules Advisory Committee, which warns against using summary evidence to argue a party's case rather than present underlying facts. On these grounds, the defense requests that the court preclude the government from introducing the proposed summary exhibits at trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.357.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

This document is a motion in limine filed by Sean Combs' legal team in his federal criminal case (Case No. 24-cr-542) in the Southern District of New York, seeking to exclude the testimony of Dr. Dawn Hughes, a psychological expert the prosecution intends to call. Dr. Hughes is expected to testify about general behavioral patterns of victims and perpetrators of sexual and domestic abuse, which the defense argues would unfairly bolster the credibility of the government's witnesses — including alleged victims — without having evaluated any facts specific to this case. The defense asserts that Dr. Hughes's testimony is not based on a reliable scientific application to the actual circumstances surrounding Combs and instead consists of broad generalizations that risk misleading the jury by presenting “typical” abuse behavior as evidence of guilt.Combs' attorneys argue that Hughes's proposed testimony violates the standards set by Federal Rules of Evidence 702 and 403, which regulate expert witness admissibility. They claim her statements offer no specialized knowledge beyond what jurors already understand — such as abusers exploiting power or victims remaining in abusive relationships — and that she conflates clinical definitions of coercion with legal ones, potentially confusing the jury. The motion asserts that Hughes's testimony is “advocacy masquerading as expertise” and warns it would improperly bolster the credibility of government witnesses under the guise of psychology. The defense urges the court to block her from testifying, citing that her opinions are methodologically unsound and prejudicial rather than probative.to contact  me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.206.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

This document is a motion in limine filed by Sean Combs' legal team in his federal criminal case (Case No. 24-cr-542) in the Southern District of New York, seeking to exclude the testimony of Dr. Dawn Hughes, a psychological expert the prosecution intends to call. Dr. Hughes is expected to testify about general behavioral patterns of victims and perpetrators of sexual and domestic abuse, which the defense argues would unfairly bolster the credibility of the government's witnesses — including alleged victims — without having evaluated any facts specific to this case. The defense asserts that Dr. Hughes's testimony is not based on a reliable scientific application to the actual circumstances surrounding Combs and instead consists of broad generalizations that risk misleading the jury by presenting “typical” abuse behavior as evidence of guilt.Combs' attorneys argue that Hughes's proposed testimony violates the standards set by Federal Rules of Evidence 702 and 403, which regulate expert witness admissibility. They claim her statements offer no specialized knowledge beyond what jurors already understand — such as abusers exploiting power or victims remaining in abusive relationships — and that she conflates clinical definitions of coercion with legal ones, potentially confusing the jury. The motion asserts that Hughes's testimony is “advocacy masquerading as expertise” and warns it would improperly bolster the credibility of government witnesses under the guise of psychology. The defense urges the court to block her from testifying, citing that her opinions are methodologically unsound and prejudicial rather than probative.to contact  me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.206.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

In this filing, the defense team for Sean “Diddy” Combs renews its motion to exclude certain summary charts the government intends to introduce as evidence under Federal Rule of Evidence 1006. The defense argues that these charts are not neutral summaries of voluminous records—as Rule 1006 requires—but rather argumentative presentations designed to convey the government's interpretation of the evidence. They point to a prior concession by the government acknowledging that the charts are not intended to prove specific facts, but to help “present the government's theory,” which the defense contends renders them inherently prejudicial and inadmissible. The defense notes that while the court previously reserved judgment pending a review of the government's draft charts, the newly submitted versions confirm their earlier concerns.The defense further emphasizes that these charts violate the spirit and letter of Rule 1006, which was designed to allow juries to more easily digest large volumes of data—not to serve as vehicles for a party's argument. By framing the charts as interpretive rather than objective, the defense argues that the government is improperly using visual aids to bolster its narrative in a way that is likely to mislead the jury and unfairly prejudice Mr. Combs. They assert that this tactic runs counter to guidance from the Rules Advisory Committee, which warns against using summary evidence to argue a party's case rather than present underlying facts. On these grounds, the defense requests that the court preclude the government from introducing the proposed summary exhibits at trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.357.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-moscow-murders-and-more--5852883/support.

Federal prosecutors have filed a motion to exclude testimony from Dr. Elie Aoun, a forensic psychiatrist and assistant professor at Columbia University, whom Sean "Diddy" Combs' defense team intends to call as an expert witness. The defense aims to have Dr. Aoun testify regarding Combs' mental state during the period of the alleged offenses, suggesting that Combs may have had diminished mental capacity. However, the government argues that Dr. Aoun's proposed testimony is inadmissible under the Insanity Defense Reform Act of 1984 and Federal Rule of Criminal Procedure 12.2, which govern the introduction of expert testimony related to a defendant's mental condition. Prosecutors contend that Dr. Aoun's opinions lack a reliable scientific basis and appear to be speculative, rendering them unsuitable for presentation to the jury.Additionally, the government asserts that allowing Dr. Aoun's testimony would effectively permit the defense to introduce a mental health defense without adhering to the procedural requirements mandated by law. They argue that the defense has not provided sufficient notice or evidence to support such a defense, and that Dr. Aoun's testimony would serve as a substitute for calling actual witnesses, thereby circumventing the rules of evidence. The prosecution maintains that admitting this testimony could mislead the jury and prejudice the government's case, and therefore, they urge the court to preclude Dr. Aoun from testifying at trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.276.0_1.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

Federal prosecutors have filed a motion to exclude testimony from Dr. Elie Aoun, a forensic psychiatrist and assistant professor at Columbia University, whom Sean "Diddy" Combs' defense team intends to call as an expert witness. The defense aims to have Dr. Aoun testify regarding Combs' mental state during the period of the alleged offenses, suggesting that Combs may have had diminished mental capacity. However, the government argues that Dr. Aoun's proposed testimony is inadmissible under the Insanity Defense Reform Act of 1984 and Federal Rule of Criminal Procedure 12.2, which govern the introduction of expert testimony related to a defendant's mental condition. Prosecutors contend that Dr. Aoun's opinions lack a reliable scientific basis and appear to be speculative, rendering them unsuitable for presentation to the jury.Additionally, the government asserts that allowing Dr. Aoun's testimony would effectively permit the defense to introduce a mental health defense without adhering to the procedural requirements mandated by law. They argue that the defense has not provided sufficient notice or evidence to support such a defense, and that Dr. Aoun's testimony would serve as a substitute for calling actual witnesses, thereby circumventing the rules of evidence. The prosecution maintains that admitting this testimony could mislead the jury and prejudice the government's case, and therefore, they urge the court to preclude Dr. Aoun from testifying at trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.276.0_1.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

Federal prosecutors have filed a motion to exclude testimony from Dr. Elie Aoun, a forensic psychiatrist and assistant professor at Columbia University, whom Sean "Diddy" Combs' defense team intends to call as an expert witness. The defense aims to have Dr. Aoun testify regarding Combs' mental state during the period of the alleged offenses, suggesting that Combs may have had diminished mental capacity. However, the government argues that Dr. Aoun's proposed testimony is inadmissible under the Insanity Defense Reform Act of 1984 and Federal Rule of Criminal Procedure 12.2, which govern the introduction of expert testimony related to a defendant's mental condition. Prosecutors contend that Dr. Aoun's opinions lack a reliable scientific basis and appear to be speculative, rendering them unsuitable for presentation to the jury.Additionally, the government asserts that allowing Dr. Aoun's testimony would effectively permit the defense to introduce a mental health defense without adhering to the procedural requirements mandated by law. They argue that the defense has not provided sufficient notice or evidence to support such a defense, and that Dr. Aoun's testimony would serve as a substitute for calling actual witnesses, thereby circumventing the rules of evidence. The prosecution maintains that admitting this testimony could mislead the jury and prejudice the government's case, and therefore, they urge the court to preclude Dr. Aoun from testifying at trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.276.0_1.pdf

Federal prosecutors have filed a motion to exclude testimony from Dr. Elie Aoun, a forensic psychiatrist and assistant professor at Columbia University, whom Sean "Diddy" Combs' defense team intends to call as an expert witness. The defense aims to have Dr. Aoun testify regarding Combs' mental state during the period of the alleged offenses, suggesting that Combs may have had diminished mental capacity. However, the government argues that Dr. Aoun's proposed testimony is inadmissible under the Insanity Defense Reform Act of 1984 and Federal Rule of Criminal Procedure 12.2, which govern the introduction of expert testimony related to a defendant's mental condition. Prosecutors contend that Dr. Aoun's opinions lack a reliable scientific basis and appear to be speculative, rendering them unsuitable for presentation to the jury.Additionally, the government asserts that allowing Dr. Aoun's testimony would effectively permit the defense to introduce a mental health defense without adhering to the procedural requirements mandated by law. They argue that the defense has not provided sufficient notice or evidence to support such a defense, and that Dr. Aoun's testimony would serve as a substitute for calling actual witnesses, thereby circumventing the rules of evidence. The prosecution maintains that admitting this testimony could mislead the jury and prejudice the government's case, and therefore, they urge the court to preclude Dr. Aoun from testifying at trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.276.0_1.pdf

Federal prosecutors have filed a motion to exclude testimony from Dr. Elie Aoun, a forensic psychiatrist and assistant professor at Columbia University, whom Sean "Diddy" Combs' defense team intends to call as an expert witness. The defense aims to have Dr. Aoun testify regarding Combs' mental state during the period of the alleged offenses, suggesting that Combs may have had diminished mental capacity. However, the government argues that Dr. Aoun's proposed testimony is inadmissible under the Insanity Defense Reform Act of 1984 and Federal Rule of Criminal Procedure 12.2, which govern the introduction of expert testimony related to a defendant's mental condition. Prosecutors contend that Dr. Aoun's opinions lack a reliable scientific basis and appear to be speculative, rendering them unsuitable for presentation to the jury.Additionally, the government asserts that allowing Dr. Aoun's testimony would effectively permit the defense to introduce a mental health defense without adhering to the procedural requirements mandated by law. They argue that the defense has not provided sufficient notice or evidence to support such a defense, and that Dr. Aoun's testimony would serve as a substitute for calling actual witnesses, thereby circumventing the rules of evidence. The prosecution maintains that admitting this testimony could mislead the jury and prejudice the government's case, and therefore, they urge the court to preclude Dr. Aoun from testifying at trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.276.0_1.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-moscow-murders-and-more--5852883/support.

Federal prosecutors have filed a motion to exclude testimony from Dr. Elie Aoun, a forensic psychiatrist and assistant professor at Columbia University, whom Sean "Diddy" Combs' defense team intends to call as an expert witness. The defense aims to have Dr. Aoun testify regarding Combs' mental state during the period of the alleged offenses, suggesting that Combs may have had diminished mental capacity. However, the government argues that Dr. Aoun's proposed testimony is inadmissible under the Insanity Defense Reform Act of 1984 and Federal Rule of Criminal Procedure 12.2, which govern the introduction of expert testimony related to a defendant's mental condition. Prosecutors contend that Dr. Aoun's opinions lack a reliable scientific basis and appear to be speculative, rendering them unsuitable for presentation to the jury.Additionally, the government asserts that allowing Dr. Aoun's testimony would effectively permit the defense to introduce a mental health defense without adhering to the procedural requirements mandated by law. They argue that the defense has not provided sufficient notice or evidence to support such a defense, and that Dr. Aoun's testimony would serve as a substitute for calling actual witnesses, thereby circumventing the rules of evidence. The prosecution maintains that admitting this testimony could mislead the jury and prejudice the government's case, and therefore, they urge the court to preclude Dr. Aoun from testifying at trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.276.0_1.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-moscow-murders-and-more--5852883/support.

​In the case of United States v. Sean Combs (S2 24 Cr. 542), the government opposes the defendant's motion to exclude evidence of prior sexual assaults under Federal Rules of Evidence 413 and 404(b). The prosecution asserts that Combs engaged in a pattern of sexual, physical, and psychological abuse against multiple victims, including those named in the indictment and others not specified therein. This evidence is presented as direct proof of the racketeering conspiracy charge and, alternatively, as admissible under Rules 413 and 404(b) to demonstrate Combs's propensity for sexual assault and to establish motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.The government argues that the probative value of this evidence outweighs any potential prejudicial effect, emphasizing its relevance in illustrating the nature and scope of the alleged criminal enterprise. They contend that such evidence provides critical context for the jury to understand the full extent of Combs's conduct and its impact on the victims. The prosecution also maintains that a preliminary hearing to assess the admissibility of this evidence is unnecessary and inappropriate, asserting that the court can make determinations based on the existing record and legal arguments presented.to contact me:bobbycapucci@protonmail.comBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

In this 39-page motion filed on April 7, 2025, Sean Combs' legal team asks the court to exclude any reference to alleged prior sexual assaults under Federal Rules of Evidence 413 and 404(b). They argue that Rule 413 only applies when a defendant is formally charged with a sexual assault offense, which Combs is not—his current charges involve racketeering, sex trafficking, and related crimes, but not specific counts of sexual assault. Therefore, they assert the government's attempt to admit uncharged sexual assault allegations under Rule 413 is legally improper and violates the plain text and legislative intent of the rule.Additionally, the motion challenges the admissibility of this evidence under Rule 404(b), which governs the use of prior bad acts to show motive, opportunity, or intent. Combs' attorneys argue that the government's notice is procedurally deficient and that the proposed evidence relies heavily on impermissible character inferences—essentially suggesting that because Combs allegedly committed bad acts before, he is more likely to have committed the crimes he's charged with now. They also invoke Rule 403, saying the evidence has low probative value, is highly inflammatory, and would result in mini-trials over unrelated allegations, confusing the jury and unfairly prejudicing Combs. At minimum, the defense requests a preliminary hearing to assess the reliability of the evidence before it's presented at trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.213.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

In this 39-page motion filed on April 7, 2025, Sean Combs' legal team asks the court to exclude any reference to alleged prior sexual assaults under Federal Rules of Evidence 413 and 404(b). They argue that Rule 413 only applies when a defendant is formally charged with a sexual assault offense, which Combs is not—his current charges involve racketeering, sex trafficking, and related crimes, but not specific counts of sexual assault. Therefore, they assert the government's attempt to admit uncharged sexual assault allegations under Rule 413 is legally improper and violates the plain text and legislative intent of the rule.Additionally, the motion challenges the admissibility of this evidence under Rule 404(b), which governs the use of prior bad acts to show motive, opportunity, or intent. Combs' attorneys argue that the government's notice is procedurally deficient and that the proposed evidence relies heavily on impermissible character inferences—essentially suggesting that because Combs allegedly committed bad acts before, he is more likely to have committed the crimes he's charged with now. They also invoke Rule 403, saying the evidence has low probative value, is highly inflammatory, and would result in mini-trials over unrelated allegations, confusing the jury and unfairly prejudicing Combs. At minimum, the defense requests a preliminary hearing to assess the reliability of the evidence before it's presented at trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.213.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

​In the case of United States v. Sean Combs (Case No. 1:24-cr-00542-AS), the defense has filed a reply memorandum supporting their motion to suppress evidence obtained through search warrants executed at Combs' residences in Los Angeles and Miami, as well as his electronic accounts and devices. The defense argues that the government obtained these warrants by making false statements and omitting critical exculpatory evidence, thereby presenting a misleading portrayal of the facts to justify the searches. They contend that certain evidence, which suggested that participation in the alleged "Freak-Off" parties was voluntary and consensual, was intentionally excluded from the warrant applications. The defense asserts that this misconduct led to the issuance of overly broad warrants, allowing the seizure of extensive personal and digital records unrelated to the alleged offenses.Alternatively, the defense requests a Franks hearing to challenge the validity of the search warrants. A Franks hearing is warranted when a defendant makes a substantial preliminary showing that a false statement was knowingly and intentionally, or with reckless disregard for the truth, included in a warrant affidavit, and that the allegedly false statement is necessary to the finding of probable cause. The defense maintains that the government's alleged omissions and misrepresentations meet this standard, necessitating such a hearing. They emphasize that without the purportedly misleading information, the warrants would lack probable cause, rendering the seized evidence inadmissible.to contact me:bobbycapucci@protonmail.comsource:  gov.uscourts.nysd.628425.187.0.pdf

​In the case of United States v. Sean Combs (Case No. 1:24-cr-00542-AS), the defense has filed a reply memorandum supporting their motion to suppress evidence obtained through search warrants executed at Combs' residences in Los Angeles and Miami, as well as his electronic accounts and devices. The defense argues that the government obtained these warrants by making false statements and omitting critical exculpatory evidence, thereby presenting a misleading portrayal of the facts to justify the searches. They contend that certain evidence, which suggested that participation in the alleged "Freak-Off" parties was voluntary and consensual, was intentionally excluded from the warrant applications. The defense asserts that this misconduct led to the issuance of overly broad warrants, allowing the seizure of extensive personal and digital records unrelated to the alleged offenses.Alternatively, the defense requests a Franks hearing to challenge the validity of the search warrants. A Franks hearing is warranted when a defendant makes a substantial preliminary showing that a false statement was knowingly and intentionally, or with reckless disregard for the truth, included in a warrant affidavit, and that the allegedly false statement is necessary to the finding of probable cause. The defense maintains that the government's alleged omissions and misrepresentations meet this standard, necessitating such a hearing. They emphasize that without the purportedly misleading information, the warrants would lack probable cause, rendering the seized evidence inadmissible.to contact me:bobbycapucci@protonmail.comsource:  gov.uscourts.nysd.628425.187.0.pdfshow lessBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

​In the case of United States v. Sean Combs (S2 24 Cr. 542), the government opposes the defendant's motion to exclude evidence of prior sexual assaults under Federal Rules of Evidence 413 and 404(b). The prosecution asserts that Combs engaged in a pattern of sexual, physical, and psychological abuse against multiple victims, including those named in the indictment and others not specified therein. This evidence is presented as direct proof of the racketeering conspiracy charge and, alternatively, as admissible under Rules 413 and 404(b) to demonstrate Combs's propensity for sexual assault and to establish motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.The government argues that the probative value of this evidence outweighs any potential prejudicial effect, emphasizing its relevance in illustrating the nature and scope of the alleged criminal enterprise. They contend that such evidence provides critical context for the jury to understand the full extent of Combs's conduct and its impact on the victims. The prosecution also maintains that a preliminary hearing to assess the admissibility of this evidence is unnecessary and inappropriate, asserting that the court can make determinations based on the existing record and legal arguments presented.to contact me:bobbycapucci@protonmail.com

​In the case of United States v. Sean Combs (S2 24 Cr. 542), the government opposes the defendant's motion to exclude evidence of prior sexual assaults under Federal Rules of Evidence 413 and 404(b). The prosecution asserts that Combs engaged in a pattern of sexual, physical, and psychological abuse against multiple victims, including those named in the indictment and others not specified therein. This evidence is presented as direct proof of the racketeering conspiracy charge and, alternatively, as admissible under Rules 413 and 404(b) to demonstrate Combs's propensity for sexual assault and to establish motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.The government argues that the probative value of this evidence outweighs any potential prejudicial effect, emphasizing its relevance in illustrating the nature and scope of the alleged criminal enterprise. They contend that such evidence provides critical context for the jury to understand the full extent of Combs's conduct and its impact on the victims. The prosecution also maintains that a preliminary hearing to assess the admissibility of this evidence is unnecessary and inappropriate, asserting that the court can make determinations based on the existing record and legal arguments presented.to contact me:bobbycapucci@protonmail.com

​In the case of United States v. Sean Combs (S2 24 Cr. 542), the government opposes the defendant's motion to exclude evidence of prior sexual assaults under Federal Rules of Evidence 413 and 404(b). The prosecution asserts that Combs engaged in a pattern of sexual, physical, and psychological abuse against multiple victims, including those named in the indictment and others not specified therein. This evidence is presented as direct proof of the racketeering conspiracy charge and, alternatively, as admissible under Rules 413 and 404(b) to demonstrate Combs's propensity for sexual assault and to establish motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.The government argues that the probative value of this evidence outweighs any potential prejudicial effect, emphasizing its relevance in illustrating the nature and scope of the alleged criminal enterprise. They contend that such evidence provides critical context for the jury to understand the full extent of Combs's conduct and its impact on the victims. The prosecution also maintains that a preliminary hearing to assess the admissibility of this evidence is unnecessary and inappropriate, asserting that the court can make determinations based on the existing record and legal arguments presented.to contact me:bobbycapucci@protonmail.com

​In the case of United States v. Sean Combs (S2 24 Cr. 542), the government opposes the defendant's motion to exclude evidence of prior sexual assaults under Federal Rules of Evidence 413 and 404(b). The prosecution asserts that Combs engaged in a pattern of sexual, physical, and psychological abuse against multiple victims, including those named in the indictment and others not specified therein. This evidence is presented as direct proof of the racketeering conspiracy charge and, alternatively, as admissible under Rules 413 and 404(b) to demonstrate Combs's propensity for sexual assault and to establish motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.The government argues that the probative value of this evidence outweighs any potential prejudicial effect, emphasizing its relevance in illustrating the nature and scope of the alleged criminal enterprise. They contend that such evidence provides critical context for the jury to understand the full extent of Combs's conduct and its impact on the victims. The prosecution also maintains that a preliminary hearing to assess the admissibility of this evidence is unnecessary and inappropriate, asserting that the court can make determinations based on the existing record and legal arguments presented.to contact me:bobbycapucci@protonmail.comBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

​In the case of United States v. Sean Combs (S2 24 Cr. 542), the government opposes the defendant's motion to exclude evidence of prior sexual assaults under Federal Rules of Evidence 413 and 404(b). The prosecution asserts that Combs engaged in a pattern of sexual, physical, and psychological abuse against multiple victims, including those named in the indictment and others not specified therein. This evidence is presented as direct proof of the racketeering conspiracy charge and, alternatively, as admissible under Rules 413 and 404(b) to demonstrate Combs's propensity for sexual assault and to establish motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.The government argues that the probative value of this evidence outweighs any potential prejudicial effect, emphasizing its relevance in illustrating the nature and scope of the alleged criminal enterprise. They contend that such evidence provides critical context for the jury to understand the full extent of Combs's conduct and its impact on the victims. The prosecution also maintains that a preliminary hearing to assess the admissibility of this evidence is unnecessary and inappropriate, asserting that the court can make determinations based on the existing record and legal arguments presented.to contact me:bobbycapucci@protonmail.comBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

​In the case of United States v. Sean Combs (S2 24 Cr. 542), the government opposes the defendant's motion to exclude evidence of prior sexual assaults under Federal Rules of Evidence 413 and 404(b). The prosecution asserts that Combs engaged in a pattern of sexual, physical, and psychological abuse against multiple victims, including those named in the indictment and others not specified therein. This evidence is presented as direct proof of the racketeering conspiracy charge and, alternatively, as admissible under Rules 413 and 404(b) to demonstrate Combs's propensity for sexual assault and to establish motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.The government argues that the probative value of this evidence outweighs any potential prejudicial effect, emphasizing its relevance in illustrating the nature and scope of the alleged criminal enterprise. They contend that such evidence provides critical context for the jury to understand the full extent of Combs's conduct and its impact on the victims. The prosecution also maintains that a preliminary hearing to assess the admissibility of this evidence is unnecessary and inappropriate, asserting that the court can make determinations based on the existing record and legal arguments presented.to contact me:bobbycapucci@protonmail.comBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

In this 39-page motion filed on April 7, 2025, Sean Combs' legal team asks the court to exclude any reference to alleged prior sexual assaults under Federal Rules of Evidence 413 and 404(b). They argue that Rule 413 only applies when a defendant is formally charged with a sexual assault offense, which Combs is not—his current charges involve racketeering, sex trafficking, and related crimes, but not specific counts of sexual assault. Therefore, they assert the government's attempt to admit uncharged sexual assault allegations under Rule 413 is legally improper and violates the plain text and legislative intent of the rule.Additionally, the motion challenges the admissibility of this evidence under Rule 404(b), which governs the use of prior bad acts to show motive, opportunity, or intent. Combs' attorneys argue that the government's notice is procedurally deficient and that the proposed evidence relies heavily on impermissible character inferences—essentially suggesting that because Combs allegedly committed bad acts before, he is more likely to have committed the crimes he's charged with now. They also invoke Rule 403, saying the evidence has low probative value, is highly inflammatory, and would result in mini-trials over unrelated allegations, confusing the jury and unfairly prejudicing Combs. At minimum, the defense requests a preliminary hearing to assess the reliability of the evidence before it's presented at trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.213.0.pdf

In this 39-page motion filed on April 7, 2025, Sean Combs' legal team asks the court to exclude any reference to alleged prior sexual assaults under Federal Rules of Evidence 413 and 404(b). They argue that Rule 413 only applies when a defendant is formally charged with a sexual assault offense, which Combs is not—his current charges involve racketeering, sex trafficking, and related crimes, but not specific counts of sexual assault. Therefore, they assert the government's attempt to admit uncharged sexual assault allegations under Rule 413 is legally improper and violates the plain text and legislative intent of the rule.Additionally, the motion challenges the admissibility of this evidence under Rule 404(b), which governs the use of prior bad acts to show motive, opportunity, or intent. Combs' attorneys argue that the government's notice is procedurally deficient and that the proposed evidence relies heavily on impermissible character inferences—essentially suggesting that because Combs allegedly committed bad acts before, he is more likely to have committed the crimes he's charged with now. They also invoke Rule 403, saying the evidence has low probative value, is highly inflammatory, and would result in mini-trials over unrelated allegations, confusing the jury and unfairly prejudicing Combs. At minimum, the defense requests a preliminary hearing to assess the reliability of the evidence before it's presented at trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.213.0.pdf

In this 39-page motion filed on April 7, 2025, Sean Combs' legal team asks the court to exclude any reference to alleged prior sexual assaults under Federal Rules of Evidence 413 and 404(b). They argue that Rule 413 only applies when a defendant is formally charged with a sexual assault offense, which Combs is not—his current charges involve racketeering, sex trafficking, and related crimes, but not specific counts of sexual assault. Therefore, they assert the government's attempt to admit uncharged sexual assault allegations under Rule 413 is legally improper and violates the plain text and legislative intent of the rule.Additionally, the motion challenges the admissibility of this evidence under Rule 404(b), which governs the use of prior bad acts to show motive, opportunity, or intent. Combs' attorneys argue that the government's notice is procedurally deficient and that the proposed evidence relies heavily on impermissible character inferences—essentially suggesting that because Combs allegedly committed bad acts before, he is more likely to have committed the crimes he's charged with now. They also invoke Rule 403, saying the evidence has low probative value, is highly inflammatory, and would result in mini-trials over unrelated allegations, confusing the jury and unfairly prejudicing Combs. At minimum, the defense requests a preliminary hearing to assess the reliability of the evidence before it's presented at trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.213.0.pdf

In this 39-page motion filed on April 7, 2025, Sean Combs' legal team asks the court to exclude any reference to alleged prior sexual assaults under Federal Rules of Evidence 413 and 404(b). They argue that Rule 413 only applies when a defendant is formally charged with a sexual assault offense, which Combs is not—his current charges involve racketeering, sex trafficking, and related crimes, but not specific counts of sexual assault. Therefore, they assert the government's attempt to admit uncharged sexual assault allegations under Rule 413 is legally improper and violates the plain text and legislative intent of the rule.Additionally, the motion challenges the admissibility of this evidence under Rule 404(b), which governs the use of prior bad acts to show motive, opportunity, or intent. Combs' attorneys argue that the government's notice is procedurally deficient and that the proposed evidence relies heavily on impermissible character inferences—essentially suggesting that because Combs allegedly committed bad acts before, he is more likely to have committed the crimes he's charged with now. They also invoke Rule 403, saying the evidence has low probative value, is highly inflammatory, and would result in mini-trials over unrelated allegations, confusing the jury and unfairly prejudicing Combs. At minimum, the defense requests a preliminary hearing to assess the reliability of the evidence before it's presented at trial.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.213.0.pdf

This document is a motion in limine filed by Sean Combs' legal team in his federal criminal case (Case No. 24-cr-542) in the Southern District of New York, seeking to exclude the testimony of Dr. Dawn Hughes, a psychological expert the prosecution intends to call. Dr. Hughes is expected to testify about general behavioral patterns of victims and perpetrators of sexual and domestic abuse, which the defense argues would unfairly bolster the credibility of the government's witnesses — including alleged victims — without having evaluated any facts specific to this case. The defense asserts that Dr. Hughes's testimony is not based on a reliable scientific application to the actual circumstances surrounding Combs and instead consists of broad generalizations that risk misleading the jury by presenting “typical” abuse behavior as evidence of guilt.Combs' attorneys argue that Hughes's proposed testimony violates the standards set by Federal Rules of Evidence 702 and 403, which regulate expert witness admissibility. They claim her statements offer no specialized knowledge beyond what jurors already understand — such as abusers exploiting power or victims remaining in abusive relationships — and that she conflates clinical definitions of coercion with legal ones, potentially confusing the jury. The motion asserts that Hughes's testimony is “advocacy masquerading as expertise” and warns it would improperly bolster the credibility of government witnesses under the guise of psychology. The defense urges the court to block her from testifying, citing that her opinions are methodologically unsound and prejudicial rather than probative.to contact  me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.206.0.pdf

This document is a motion in limine filed by Sean Combs' legal team in his federal criminal case (Case No. 24-cr-542) in the Southern District of New York, seeking to exclude the testimony of Dr. Dawn Hughes, a psychological expert the prosecution intends to call. Dr. Hughes is expected to testify about general behavioral patterns of victims and perpetrators of sexual and domestic abuse, which the defense argues would unfairly bolster the credibility of the government's witnesses — including alleged victims — without having evaluated any facts specific to this case. The defense asserts that Dr. Hughes's testimony is not based on a reliable scientific application to the actual circumstances surrounding Combs and instead consists of broad generalizations that risk misleading the jury by presenting “typical” abuse behavior as evidence of guilt.Combs' attorneys argue that Hughes's proposed testimony violates the standards set by Federal Rules of Evidence 702 and 403, which regulate expert witness admissibility. They claim her statements offer no specialized knowledge beyond what jurors already understand — such as abusers exploiting power or victims remaining in abusive relationships — and that she conflates clinical definitions of coercion with legal ones, potentially confusing the jury. The motion asserts that Hughes's testimony is “advocacy masquerading as expertise” and warns it would improperly bolster the credibility of government witnesses under the guise of psychology. The defense urges the court to block her from testifying, citing that her opinions are methodologically unsound and prejudicial rather than probative.to contact  me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628425.206.0.pdf