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Case 1:20-cr-00330-AJN Document 124 Filed 01/25/21 Page 6 of 8 e “some of the minor girls” § 2; e “multiple minor girls” { 4; e “Epstein’s minor victims” ¥ 4a; e “a minor victim” ¥ 4b; e “Among the victims ... were minor victims identified herein as Minor Victim-1, Minor Victim-2, and Minor Victim-3.” § 7; and e “engaged in the following acts, among others, with respect to minor victims. ...” q 7. The inconsistent and interchangeable use of seemingly defined alleged victims, i.e., 39 66 Minor Victim-1, with generic undefined “victims,” “minor victims”, and “girls,” prevents Ms. Maxwell from knowing what alleged conduct with what alleged person formed the basis of this Indictment and allows for multiple variances of proof at any trial. Random acts are disbursed throughout the indictment, some tied to generic alleged “victims” other to a defined alleged “Minor Victim:” e “befriend” { 4a; e “being present” § 7a; e “groomed” 97a; e “undressing” §J7a; and e “took Minor Victim -2 to a movie” § 7b. The discovery provides to Ms. Maxwell provides no information about when and where the alleged instances of sexual abuse took place. Because there are no dates provided, other than a three-year period beginning (perhaps) 27 years in the past, Ms. Maxwell cannot properly investigate where she and other witnesses were when the alleged crime supposedly occurred. And because the crimes alleged in Counts One through Four are based largely on vaguely stated, DOJ-OGR-00002316