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Case 1:20-cr-00330-AJN Document 124 Filed 01/25/21 Page 5of8 In many cases the bar for sufficiency of an indictment is low. It is also true that courts find, in certain cases, that the discovery provided in connection with the matter may cure various pleading deficiencies. See, e.g., United States v. Jain, No. 19-CR-59 (PKC), 2019 WL 6888635, at *2 (S.D.N.Y. Dec. 18, 2019) (“When supplemented by discovery material, no additional information is necessary for trial preparation or to prevent surprise.”). However, “while an indictment parroting the language of a federal criminal statute is often sufficient, there are crimes that must be charged with greater specificity.” United States v. Resendiz-Ponce, 549 U.S. 102 at 109. These are those crimes. Here, neither the Indictment nor the discovery inform Ms. Maxwell about critical information necessary to prepare her defense. The Indictment contains multiple open-ended time periods: e “from at least in or about 1994, up to and including at least in or about 1997” 44 1,9, 13, 15; and e “beginning in at least 1994” ¥ 4. These phrases make the time frame alleged limitless and meaningless for application of the statute of limitations or any defense. In addition to not identifying the individuals accusing Ms. Maxwell of a crime, the Indictment, through the use of inconsistent and vague phrases, makes it impossible to know who may, or may not, be someone that the Government claims is a “victim.” e “minor girls” ¥ 1; e “victims” § 1; e “victims were as young as 14” § 1; e “certain girls were in fact under the age of 18” § 1; DOJ-OGR-00002315