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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 207 of 239 Particulars are necessary only where indictment charges are ‘so general that they do not advise the 999 defendant of the specific acts of which he is accused.’” (internal citation omitted) (quoting Torres, 901 F.2d at 234; United States v. Chen, 378 F.3d 151, 163 (2d Cir. 2004))); United States v. Wedd, No. 15 Cr. 616 (KBF), 2016 WL 1055737, at *3 (S.D.N.Y. Mar. 10, 2016) (denying motion for bill of particulars where “the Indictment is a ‘speaking’ Indictment that provides a significant amount of detail as to the Government’s theory of the case and the nature of the proof that will underlie the charges at trial’’). Additional particularity relating to the details of the counts in the Indictment might be helpful for the defendant, but that is both true in every case and not the appropriate standard. Instead, the inquiry is properly focused on whether the information already available to her is so general that a bill of particulars is necessary to the preparation of her defense. Plainly it is not. In addition to the speaking Indictment, the defendant has received over 2.7 million pages of discovery in this case. Although that is a high volume of discovery, it is clear from the defense’s own motion that the defense has apparently already reviewed that material (at least in significant part), identified relevant materials therein, and is aware of their relevance to the allegations in the Indictment. (See, e.g., Def. Mot. 10 at 6). Indeed, much of the discovery is text searchable, and the time period that each document relates to is readily ascertainable. 6! Records of commercial flights were unavailable by the time the Government opened its investigation in this case. Accordingly, the Government has no records of commercial flights that the defendant, Epstein, or any victims may have taken during the relevant period. 180 DOJ-OGR-00003141