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Case 22-1426, Document 58_02/28/2023, 3475901, Page17/0 of 221 A-370 Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 13 of 45 Further, in both counts, the witnesses testified that they received financial gifts and payments as a means by which the Defendant and Epstein acquired their victims’ trust and extended the period of sexual abuse. .g., id. at 302 (Jane testified that she was given money “[allmost every visit” and that Epstein paid for things like voice lessons and clothes). The Government emphasized such financial gifts as one step in the Defendant’s playbook of grooming. F.g., id. at 2851 (“Then came the next step in the playbook: Making these girls feel special, giving them gifts, making friends, giving them money, promising to help with their futures, promises like sending Annie on a trip to Thailand or helping to pay for Jane’s voice lessons and tuition.”), 2890 (“[Jane] told you that Epstein gave her money and gifts and paid for school. That money wasn’t free.... That is inducement, that is enticement, that is coercion.”’). The financial quid pro quo may have become more explicit beginning in 2001, but that shift in approach is not nearly so dramatic as to suggest that the Defendant and Epstein at that time entered “a wholly new agreement” with a new “conspiratorial objective.” Haji v. Miller, 584 F. Supp. 2d 498, 519 (E.D.N.Y. 2008). The similarity-of-operations factor therefore favors the Defendant. Overlap of geographic scope. There is some, albeit incomplete, geographic overlap between the two counts. Count Three focused on travel to New York because the ultimate objective of the conspiracy was to transport minors to New York to engage in criminal sexual activity in violation of New York law. Count Five, by contrast, focused on Epstein’s residence in Florida, where Carolyn and Virginia Roberts were paid to give Epstein sexualized massages. Nevertheless, some geographic overlap between the two counts remained. All four witnesses testified about sexual conduct by the Defendant or Epstein in locations other than New York, whether Florida, New Mexico, or London. The Court admitted such testimony concerning 13 DOJ-OGR- 00020996