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Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 44 of 54 defendant has emphasized these witness statements, and claimed that they are exculpatory. (See, e.g., Mem. of Law, Dkt. 138 at 7-11; Letter, Dkt. 64 at 1; Mot., Dkt. No. 346 at 2 n.1). As explained above, as a general matter, “evidence of good conduct that does not refute evidence of the offense charged” is inadmissible. United States v. Rivera, No. 13 Cr. 149 (KAM), 2015 WL 1725991, at *2 (E.D.N.Y. Apr. 15, 2015). The Government will not contend at trial that the defendant personally participated in the abuse of all of Epstein’s victims, and it is not a defense to claim that the defendant is not guilty of crimes with which she is not charged. This Court has already said as much. In the defendant’s pretrial motions, she alleged pre- indictment delay on the grounds that the lead detective from the Palm Beach Police Department investigating Epstein “revealed that not one of the alleged Epstein victims ever mentioned Ms. Maxwell’s name and she was never considered a suspect.” (Mem. of Law, Dkt. 138 at 10-11). The Court rejected this argument, explaining that the testimony the defendant suggested that the detective might have offered “is propensity evidence that does nothing to establish her innocence of the charged offenses.” (Opinion & Order, Dkt. 207 at 18); see United States v. Raniere, 384 F. Supp. 3d 282, 325 (E.D.N.Y. 2019) (rejecting a motion for discovery because “statements by individuals who were not allegedly directed to have sex with [the defendant] or were not threatened with the release of collateral in exchange for acts of care are not Brady material because they have no bearing on whether the alleged victims were so directed or threatened”). Moreover, the Government notes that evidence of these encounters is only admissible through the victims themselves. Any other method of eliciting that evidence, such as through 43 DOJ-OGR-00005437