SALT LAKE CITY -- Federal prosecutors responded Tuesday to defense motions seeking to limit the evidence that can be presented at next week's Olympic bribery trial.

The government wants to use an ethics report that laid out the scandal for the board of the Salt Lake Organizing Committee and served as a template for the federal prosecution.

The defense wants to strike that evidence as hearsay, along with any mention of immigration fraud leveled against John Kim, the son of a powerful International Olympic Committee member and the beneficiary of a job arranged by the Salt Lake bid committee.

The 1½-inch ethics report was based partly on interviews with bid chief Tom Welch and deputy Dave Johnson, who tried to explain some of the payments made to IOC delegates.

In court papers, prosecutors said they wanted to question Welch about payments made to Jean Claude Ganga, an IOC member from the Republic of Congo who was expelled for taking $320,000 from Salt Lake City.

Welch was quoted in the ethics report saying $50,000 of the money was intended for amateur athletes in the Congo, and that he didn't know those checks were deposited to Ganga's personal account. The government contends evidence shows otherwise and that it should be allowed to explore this avenue by citing the ethics report.

The ethics report was prepared by a five-member panel, including Utah's former chief justice, and released in February 1999. Defense lawyers call it prejudicial and based on secondhand accounts, not direct evidence.

Kim, of South Korea, was accused of using a no-show job set up by Welch with a Salt Lake telecommunications company to obtain a green card to stay in this country.

The Kim case is a "bizarre subconspiracy" with little relevance to the main government case against bid Welch and Johnson and adds "an entirely separate and highly inflammatory dimension" that could distract a jury, the bid leaders' lawyers contend.

But to prosecutors, the Kim job was just another favor conferred on IOC delegates or their relatives by the Salt Lake bid campaign.

"The overall purpose of the conspiracy alleged in the indictment was to make payoffs to IOC members in whatever form most effective, in an effort to garner votes for Salt Lake City," Justice Department trial attorneys Richard Wiedis and John Scott said in their rebuttal.

"The indictment plainly alleges that defendants assisted John Kim in unlawfully obtaining a green card in order to influence his father, IOC member Un Yong Kim, to vote for Salt Lake City," they said.

John Kim and his father, the IOC's vice president, have maintained the younger Kim did honest consulting work in 1991 and 1992 for Salt Lake businessman David Simmons trying to arrange cable television deals with the heads of South Korea's major television networks.

Kim failed to generate any business for Simmons, who got the bid committee to reimburse him $78,000 for Kim's salary. Simmons pleaded guilty to tax fraud for claiming the salary as a business expense on his tax returns.

"Just like the college tuition provided to the children of IOC members Essomba from Cameroon, Sibandze from Swaziland and Keita from Mali, or the job and relocation assistance provided to the daughter of IOC member Arroyo from Ecuador, the provision of a job and documentation to support the green card application of John Kim was simply another embodiment of the defendants' efforts to sway the votes of IOC members by fulfilling the needs of their children," they wrote.

U.S. District Court Judge David Sam will rule on the motions before the trial, which starts Tuesday with jury selection and could last six weeks.