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Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 43 of 84 befriended Minor Victim-3 in London, England between approximately 1994 and 1995, including during a period of time in which [the defendant] knew that Minor Victim-3 was under the age of 18.” (Indictment ¥ 9(c)). The defendant “introduced Minor Victim-3 to Epstein and arranged for multiple interactions between Minor Victim-3 and Epstein,” during which the defendant “encouraged Minor Victim-3 to massage Epstein, knowing that Epstein would engage in sex acts with Minor Victim-3 during those massages.” (/d.) Minor Victim-3 provided those massages, during which Epstein sexually abused Minor Victim-3. (/d.) Two overt acts in those Indictments concemed the defendant and Epstein’s sexual abuse of Minor Victim-3 in London. (/d. JJ 13(d), 19(d)). The defendant moved to strike the portions of the S1 Indictment involving Minor Victim- 3, arguing that the events involving Minor Victim-3 were unrelated to the conspiracies charged in Count One and Count Three. (See generally Mem. of Law, Dkt. No. 146). In response, the Government explained that the defendant and Epstein’s “interactions with Minor Victim-3 were part of a broader scheme and agreement to entice and transport minor victims with the intent to commit illegal sex acts,” and in any event, admissible under Rule 404(b) as evidence of the defendant’s knowledge, intent, and modus operandi. (Gov’t Opp. at 157-169, Dkt. No. 204). The Government expects Minor Victim-3 to testify, in substance and in part, that she met the defendant when she was a. The defendant befriended Minor Victim-3 by, among other things, discussing Minor Victim-3’s life and family with Minor Victim-3. Lr 42 DOJ-OGR-00005826