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Case 1:20-cr-00330-PAE Document 213 _ Filed 04/16/21 Page5of8 Thus, the court found: the indictment “contains dates ranges for each count, stretching from approximately four days to four months. These date ranges are well within the boundaries permitted by the Second Circuit and other federal courts, and have been supplemented with additional details provided by the Government. Id., at *4 (emphasis added). To date, the only time the government has “supplemented” any information about the accusations is when it is attempting to excuse some failure. Here, the accusers have given statements to the government. Accuser-1 gave a statement to the government in 2006. All three accusers have made claims against the Epstein Estate. Presumably, the Accusers had to tell the Estate when and where any alleged abuse by Epstein occurred. Accordingly, this is not a situation where children do not remember things. This is a situation where the government has refused to provide basic necessary information in an attempt to prejudice Ms. Maxwell’s defense. “Third,” the indictment is not “clear” (Resp. at 155); it was purposely drafted to maximize charges and minimize clarity. For example, the photograph of Ms. Maxwell in the indictment is not from the time-period alleged. The pictures of the various properties were not included for specificity, they were included to maximize pretrial prejudice. The indictment is full of “weasel words” which are words the meaning of which are “malleable to a point where they mean what the user wants them to mean in any given situation; they have no meaning of their own.” Absirax, Inc. v. Hewlett-Packard Co., No, 2:14-CV-158-JRG, 2014 WL 5677834, at *2 (E.D. Tex. Nov. 4, 2014). For example: “up to and including at least in or about,” 99: ¢¢ “contributed,” “among other things,” “for example in some instances,” “certain victims,” and “groomed and/or abused at multiple locations including the following.” Ms. Maxwell is at a loss to understand what she is charged with and when it is alleged to have happened. She can guess at DOJ-OGR-00003837