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Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 9 of 23 government, but have not been able to agree on a disclosure schedule and therefore renew this request as part of this motion for a bill of particulars. Ms. Maxwell’s efforts to prepare for trial have also been significantly impaired by the lack of specificity in the indictment. In Bortnovsky, the Second Circuit reversed the defendants’ convictions for failure to grant a bill of particulars, primarily because the indictment failed to identify relevant dates. Bortnovsky, 820 F.2d at 574-75. The Circuit concluded that the defendants, accused of submitting false burglary claims for insurance purposes, “were hindered in preparing their defense by the district court’s failure to compel the Government to reveal crucial information: the dates of the fake burglaries and the identity of the three fraudulent documents.” /d. at 574. As aresult, Bortnovsky held, “[t]he relevance of key events was shrouded in mystery at the commencement of and throughout the trial.” Jd. at 575. Ms. Maxwell is similarly hindered. The indictment charges Ms. Maxwell with enticing or arranging travel for an unidentified individual, Accuser-1,* from Florida to New York at some point during a four-year period. Yet the government has not alleged the dates of Ms. Maxwell’s alleged interactions with Accuser-1, the dates when Accuser-1 allegedly traveled across state lines for the purpose of engaging in sexual encounters with Jeffrey Epstein, the dates on which Ms. Maxwell allegedly enticed the complainant to do so, and the actions Ms. Maxwell allegedly took to entice Accuser-1 to travel. Ms. Maxwell has requested precisely such particulars from the government, and the government has declined to provide them. This information also has not been provided in discovery. Notwithstanding the government’s representation that accuser testimony is corroborated by “flight records, diary entries, business records, and other evidence,” (Dkt. 4 at 5), the government has not produced any such records from which it could be ascertained when or how Ms. Maxwell is alleged to ‘ The indictment identifies the three accusers as Minor Victims 1-3. We will refer to them as Accusers 1-3. 5 DOJ-OGR- 00002702