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Case 1:20-cr-00330-AJN Document 146 Filed 02/04/21 Page 12 of 16 (quoting Grunewald v. United States, 353 U.S. 391, 397 (1957)). Thus, whether Ms. Maxwell’s alleged conduct with respect to Minor Victim-3 constituted an overt act in furtherance of the alleged conspiracy depends on the scope of the alleged conspiracy. In United States v. Hsia, 24 F. Supp. 2d 14 (D.D.C. 1998), for example, the defendant was charged with conspiracy, and causing false statements to be made to the Federal Election Commission, in connection with an alleged scheme to obtain illegal campaign contributions from foreign donors. The defendant moved to strike references in the indictment to acts of concealment of the alleged conspiracy. The court expressed concern that “the allegations provide little detail about the acts” and that “references to the alleged acts of concealment and cover-up suggest the inclusion of offenses that are not part of the conspiracy charged in the indictment.” /d. at 25. Although the court denied the defendant’s motion to strike, it ordered a bill of particulars “as to the scope of the alleged conspiratorial agreement and in particular whether and how the acts of concealment alleged in the indictment were within the scope of the conspiracy charged.” /d. at 33. The court added that if the bill of particulars confirmed the defendant’s assertion that the alleged acts of concealment and cover-up were not within the alleged scope of the conspiratorial agreement, her motion to strike would be granted. /d. at 26. Here, the object of the alleged conspiracies—necessarily, under the Mann Act—was not to cause any individual to engage in unlawful sex acts with Epstein, but to cause individuals to travel to do so. The allegations regarding Accuser-3, even if proven, could not have furthered such alleged conspiracies. There is no basis for any reasonable inference that Epstein and Ms. Maxwell’s interactions with Accuser-3 in England furthered a conspiracy to cause Accuser-1, Accuser-2, or anyone else to travel. There is no allegation that Accuser-3 even knew Accuser-1 DOJ-OGR-00002687