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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 185 of 239 conspiracy is timely. Second, the description of Minor Victim-3’s experiences in the Indictment is no more inflammatory or prejudicial than those regarding Minor Victim-1 and Minor Victim-2. Finally, even if evidence regarding Minor Victim-3 were not admissible as direct evidence of the charged conspiracies—which it is—that evidence will be admissible under Federal Rule of Evidence 404(b) to prove the defendant’s knowledge, intent, and modus operandi. Accordingly, the motion to strike references to Minor Victim-3 as surplusage should be denied. A. Relevant Facts As alleged in the Indictment, Minor Victim-3 was one of the minor girls whom the defendant groomed to engage in sexual activity with Jeffrey Epstein. Minor Victim-3 was born in . At trial, the Government expects that Minor Victim-3 will testify,°° in substance and in part, that when she was a. she met the defendant. After meeting Minor Victim- 3, the defendant befriended Minor Victim-3 by, among other things, discussing Minor Victim-3’s life and family with Minor Victim-3. As a result, the defendant came to know Minor Victim-3’s age. °6 While the Government is proffering these facts for purposes of this Motion, the underlying information, which is contained in the FBI 302 reports of interviews with Minor Victim-3, will be produced to the defense as 3500 material in advance of trial. 158 DOJ-OGR-00003119