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Case 1:20-cr-00330-PAE Document 213 _ Filed 04/16/21 Page2of8 The government continues to stonewall Ms. Maxwell’s requests for clarity about what it claims she did to justify her continued incarceration and prosecution. Although the government has dumped thousands of pages of irrelevant discovery from inapplicable time periods on Ms. Maxwell and her counsel, it refuses to provide the most basic information about the allegations in Counts One through Four: who, what, when, and how. Because Counts One through Four of the superseding indictment (“Indictment”) lack the basic factual information necessary for Ms. Maxwell to prepare her defense, and the government refuses to provide any meaningful discovery, the Court should either dismiss these counts or direct the government to answer Ms. Maxwell’s requests for particularity. I. The Indictment Lacks the Necessary Specificity The government attempts to justify some of the Indictment’s deficiencies, e.g., lack of names and dates, through citation to obviously inapplicable cases. “First,” the government offers United States v. Stringer, 730 F.3d 120, 124 (2d Cir. 2013), for the proposition that “the use of pseudonyms to refer to minor victims of the charged conduct does not warrant dismissal of the indictment.” Resp. at 153. The government fails to point out, however, that Stringer was a fraud case in which the conduct was alleged to have occurred over a 7-month period. The indictment was brought within a few years, not decades, of the alleged crime, and the identity of the two people whose names were used in connection with the fraud “had been revealed in the documents disclosed by the government a year” before trial. Td. at 123. United States v. Kidd, 386 F. Supp. 3d 364, 367 (S.D.N.Y. 2019), is equally unpersuasive. Kidd was indicted in 2018 for crimes alleged to have occurred as late as 2018. The case involved two alleged victims and the government produced sufficient discovery to obviate the need for a bill of particulars. /d. at 368, 370. DOJ-OGR- 00003834