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Case 1:20-cr-00330-PAE Document 235 Filed 04/22/21 Page3of10 Page 3 beyond the Mann Act counts. But the defense did. And notwithstanding that understanding, the defense at no point suggested that it would seek to adjourn the trial date if the Court denied its severance motion. Given the defense’s expansive view of the amount of evidence and time that would be required to complete a trial of the perjury counts, their removal from the equation should largely make up for the additional trial time required to address the new charges and allegations regarding Minor Victim-4 in the S2 Indictment. Similarly, now that the defense no longer has to prepare immediately for what it predicted would be a “collateral trial on whether Virginia Roberts Giuffre’s statements about an alleged conspiracy from 1999-2002 were in fact lies” (Dkt. No. 120 at 9-10), defense counsel can prepare for a trial that includes the allegations regarding Minor Victim-4. Moreover, as noted in its April 9, 2021 letter, the Government fully intends to focus its presentation of evidence at trial primarily on the experiences of the four victims referenced in the S2 Indictment. As the Government has previewed in its conferrals with defense counsel, the Government anticipates introducing evidence regarding a small number of additional victims either as direct evidence of the charged conspiracies or pursuant to Federal Rule of Evidence 404(b). The Government does not expect that this additional evidence will significantly lengthen the trial, particularly because much of this evidence will come from witnesses and exhibits that will already be introduced in connection with the four victims referenced in the S2 Indictment. This streamlined approach will ensure both that the length of trial is not significantly expanded and that the defense will be able to focus its trial preparation on addressing the allegations DOJ-OGR-00003945