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Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 22 of 26 The S2 Indictment identifies Minor Victim-4 as a victim of the conspiracy charged in Count Five and the trafficking offense contained in Count Six. See, e.g., S2 Indictment 4 9(d), 25, 27. Further, the S2 Indictment provides extensive detail regarding how the sex trafficking scheme operated. See, e.g., id. J 6-7. In particular, the S2 Indictment explains that the defendant or another of Epstein’s employees would: call a minor victim to schedule an appointment to massage Epstein; greet the minor victim at Epstein’s Palm Beach residence and escort her into a massage room, where Epstein would then engage in sex acts with the victim; and pay the minor victim hundreds of dollars in cash after the massage. See id. 7. The S2 Indictment specifies the types of sex acts involved in this conduct, see id. { 7(b), and further identifies the particular role that the defendant played in facilitating the trafficking of Minor Victim-4, see id. § 9(d). Among other things, the S2 Indictment describes conversations the defendant had with Minor Victim-4 and further explains that the defendant called Minor Victim-4 to schedule massage appointments, paid Minor Victim-4 after completing massages, sent Minor Victim-4 gifts from New York to Florida, and encouraged Minor Victim-4 to bring other young females to massage Epstein. See id. Given all of these details, the S2 Indictment alone provides a sufficient basis to deny the defendant’s motion in its entirety. See, e.g., United States v. Bonventre, 646 F. App’x 73, 79 (2d Cir. 2016) (“‘[E]videntiary detail is not the function of the bill of particulars.’ Particulars are necessary only where indictment charges are ‘so general that they do not advise the defendant of 399 the specific acts of which he is accused.’” (internal citation omitted) (quoting Torres, 901 F.2d at 234; United States v. Chen, 378 F.3d 151, 163 (2d Cir. 2004))); United States v. Wedd, No. 15 Cr. 616 (KBF), 2016 WL 1055737, at *3 (S.D.N.Y. Mar. 10, 2016) (denying motion for bill of particulars where “the Indictment is a ‘speaking’ Indictment that provides a significant amount of 18 DOJ-OGR-00004729