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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 194 of 239 404(b)(2); (ii) is relevant to the crime for which the defendant is on trial; (111) has probative value that is not substantially outweighed by any unfair prejudicial effect; and (iv) is admitted with a limiting instruction to the jury, if requested. See Huddleston v. United States, 485 U.S. 681, 691- 92 (1988); United States v. LaFlam, 369 F.3d 153, 156 (2d Cir. 2004). Here, evidence regarding the defendant’s interactions with Minor Victim-3 is admissible to prove the defendant’s knowledge, intent, and modus operandi, all of which are permissible purposes under Rule 404(b). Testimony regarding the defendant’s efforts to recruit and encourage Minor Victim-3 to engage in sex acts with Epstein in the context of massages establishes that the defendant knew of Epstein’s attraction to minor girls and knew that Epstein used massage to initiate sexual contact with minor girls. Similarly, testimony regarding the defendant’s interactions with Minor Victim-3, including how the defendant befriended Minor Victim-3 and then encouraged her to engage in sex acts with Epstein, establishes that the defendant intended for minor girls to engage in sex acts with Epstein when she befriended them, invited them to travel, and arranged for their travel. Finally, the details of how the defendant interacted with Minor Victim-3 demonstrates that the defendant had a specific modus operandi when grooming minor girls to engage in sexual activity with Epstein. As with Minor Victim-1 and Minor Victim-2, the defendant asked minor girls details about their lives, normalized sexual topics and activity, and used her presence as an adult woman to convince minor girls that the sexual activity Epstein initiated was normal and acceptable. “The similarity sufficient to admit evidence of past acts to establish a recurring modus operandi need not be complete; it is enough that the characteristics relied upon are sufficiently idiosyncratic to permit a fair inference ofa pattern’s existence.” United °° Such evidence is particularly probative when it seems apparent from defense filings that the defendant plans to argue that even if she were somehow involved in transporting or traveling with minors, she had no knowledge or intent that they engage in sexual conduct with Epstein. 167 DOJ-OGR-00003128