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Case 1:20-cr-00330-PAE Document 295 _ Filed 05/25/21 Page 21 of 26 VI. A Bill of Particulars Is Not Warranted The defendant again seeks a bill of particulars, this time related to Counts Five and Six of the S2 Indictment. Because the Government has provided the defendant with more than sufficient information—through both the S2 Indictment and discovery—to understand the charges against her, to prepare a defense, and to protect against double jeopardy, this motion should be denied. The instant motion seeks essentially the same type of details that the defendant sought with regards to Counts One through Four in her prior motions. For the same reasons that the Court denied that prior motion, this motion should also be denied. (See Apr. Op. at 19). The proper purpose of a bill of particulars under Federal Rule of Criminal Procedure 7(f) is “to provide defendant with information about the details of the charge against him if this is necessary to the preparation of his defense, and to avoid prejudicial surprise at trial.” United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 628 F.3d 36, 41 (2d Cir. 2010) (emphasis added) (internal quotation marks omitted). Accordingly, “[a] bill of particulars is required ‘only where the charges of the indictment are so general that they do not advise the defendant of the specific acts of which he is accused.’” United States v. Walsh, 194 F.3d 37, 47 (2d Cir. 1999) (quoting Torres, 901 F.2d at 234); see United States v. Mahabub, No. 13 Cr. 908 (AJN), 2014 WL 4243657, at *2 (S.D.N.Y. Aug. 26, 2014). As was the case with the charges contained in the prior indictment, the charges contained in Counts Five and Six of the S2 Indictment are clear from the face of the charging instrument, which provides significant detail. As is apparent from the 23-page speaking S2 Indictment, Counts Five and Six concern the defendant’s participation in a conspiracy to commit sex trafficking of minors with Epstein and her participation in, and aiding and abetting of, the sex trafficking of a particular minor identified as Minor Victim-4 with Epstein from approximately 2001 through 2004. 17 DOJ-OGR-00004728