Preemptively argue that the doctrine of chances requires genuinely independent allegations, and challenge independence by showing media exposure and complainant communications prior to reporting.
Address the continued relationship through expert testimony on trauma responses and acquaintance assault dynamics rather than as affirmative evidence of consent.
Choose one theory: either focus on specific inconsistencies in individual complainants' accounts, or argue social influence, but do not deploy both simultaneously as the contradiction weakens overall credibility.
Reframe the entire motion under the Ventimiglia framework, addressing each of the recognized exceptions (motive, intent, absence of mistake, common scheme, identity) and arguing none apply.
Pre-screen each email exhibit and address ambiguous language proactively, providing the defense's interpretation before prosecution can frame them unfavorably.