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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page177 of 239 VII. The Indictment Contains the Elements of Each Offense and Provides the Defendant More Than Adequate Notice of the Charges Against Her The defendant also moves to dismiss Counts One through Four on the grounds that the Indictment lacks specificity because it does not name minor victims, does not include specific dates, and uses language that the defendant claims not to understand. (Def. Mot. 12). The motion is meritless and should be denied. The plain language of the Indictment clearly and sufficiently sets forth every element of each crime charged, and the extensive details contained in the Indictment as further amplified through the voluminous discovery and the Government’s various pre-trial filing describing the case and its anticipated proof at trial provide the defendant with more than sufficient notice of the charges against her. A. Applicable Law It is well-established that “[a]n indictment is sufficient if it contains the elements of the offense(s) charged and fairly informs a defendant of the charge(s) against which he must defend.” United States v. Rahimi, No. 16 Cr. 760 (RMB), 2017 WL 2984169, at *1 (S.D.N.Y. June 22, 2017) (citing United States v. Chalmers, 474 F. Supp. 2d 555, 559 (S.D.N.Y. 2007); Hamling v. United States, 418 U.S. 87, 117 (1974)). As a result, “‘an indictment need do little more than to track the language of the statute charged and state the time and place (in approximate terms) of the alleged crime’” in order to be sufficient. United States v. Stavroulakis, 952 F.2d 686, 693 (2d Cir. 1992) (quoting United States v. Tramunti, 513 F.2d 1087, 1113 (2d Cir. 1975)). As such, “[a] defendant faces a high standard in seeking to dismiss an indictment.” United States v. Nejad, No. 18 Cr. 224 (AJN), 2019 WL 6702361, at *3 (S.D.N.Y. Dec. 9, 2019) (internal quotation marks omitted) (quoting United States v. Post, 950 F. Supp. 2d 519, 527 (S.D.N.Y. 2013)). Additionally, “when deciding a motion to dismiss, a court must accept all factual allegations in the indictment as true.” Chalmers, 474 F. Supp. 2d at 559. “A court should not look beyond the face 150 DOJ-OGR-00003111