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Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 7 of 23 the defense can adequately prepare for trial”)). For the very same reasons, the Jencks Act and 404(b) evidence should be produced to the defense no later than March 12, 2021. For the reasons set forth below, the Court should grant Ms. Maxwell’s request for a bill of particulars and her other requests for pretrial disclosures. I. Motion for a Bill of Particulars Ms. Maxwell requests that the Court direct the government to file a Bill of Particulars, pursuant to Rule 7(f) of the Federal Rules of Criminal Procedure, because the Superseding Indictment does not sufficiently inform her of the nature of the charges against her. Counts One through Four of the indictment make vague and unspecified allegations that Ms. Maxwell purportedly enticed and caused unidentified individuals to travel to engage in illegal sex acts over a four-year period. But they provide no specifics about when these events supposedly took place or what constituted the alleged illegal sex acts. Indeed, it is now almost seven months since Ms. Maxwell was arrested and the government s/i// has not even disclosed the identities of the three accusers that form the core of the government’s case against her in Counts One through Four. Nor has the government alleged why Ms. Maxwell’s supposedly perjurious responses to the deposition questions set forth in Counts Five and Six were material to the defamation proceeding in which they arose. Ms. Maxwell cannot hope to investigate these allegations and adequately prepare for trial with such limited information. A bill of particulars is therefore warranted. Rule 7(f) permits a defendant to seek a bill of particulars “in order to identify with sufficient particularity the nature of the charge pending against him, thereby enabling defendant to prepare for trial, to prevent surprise, and to interpose a plea of double jeopardy should he be prosecuted a second time for the same offense.” United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987). The decision of whether to grant a bill of particulars is within the discretion of 3 DOJ-OGR-00002700