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Case 1:20-cr-00330-PAE Document 287 Filed 05/20/21 Page4of16 Ghislaine Maxwell respectfully submits this Reply Memorandum in Support of her Motion for a Bill of Particulars and Pretrial Disclosures (“Motion”). Ms. Maxwell’s opening brief sets forth compelling reasons justifying the need for a bill of particulars, and for accelerated disclosure of the identities of the government’s witnesses, Jencks Act material, Brady/Giglio material, Rule 404(b) evidence, and any co-conspirator statements that the government will seek to introduce at trial. The government’s opposition (“Opp.”) does not address these justifications, or attempts to deflect them, and does nothing to undercut Ms. Maxwell’s arguments in support of the requested relief. Indeed, the new revelations in the government’s opposition highlight the need for the relief she seeks. In response to Ms. Maxwell’s Motion to Strike Surplusage from the Indictment, the government’s opposition discloses for the first time that Accuser-3' will testify that she gy rs ES 1:3: 2tcz:ci00s, which meaningfully expand the scope of the charges against Ms. Maxwell, are not mentioned anywhere in the Superseding Indictment (“Indictment”), nor are they alluded to in the over 2.7 million pages of discovery. Ms. Maxwell cannot possibly investigate the allegations to prepare her defense if she does not know fundamental information about when and where the alleged incidents of sexual abuse took place. Nor can she make appropriate motions to preclude the government’s use of this evidence, as it falls outside of the scope of the charged conspiracies. Moreover, the government continues to refuse to provide Ms. Maxwell the most basic piece of information she needs to prepare for trial — the names of the three individuals who have accused " Accuser-3 is identified in the Superseding Indictment as “Minor Victim-3.” Similarly, the individuals identified in the Superseding Indictment as “Minor Victim-1” and “Minor Victim-2” are referred to herein as Accuser-1 and Accuser-2, respectively. DOJ-OGR- 00004231