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Case 1:20-cr-00330-PAE Document 444 _ Filed 11/12/21 Page13 of 21 allege three distinct episodes of alleged sexual abuse, in three different locations, involving three separate accusers. The allegations of Accuser-3 stand on their own and are not “inextricably intertwined” with the allegations of Accuser-1 or Accuser-2, nor do they stem from “the same series of transactions.” In fact, they have no bearing on or connection to those allegations whatsoever. Because Accuser-3’s allegations are conceptually distinct, they are also not “necessary to complete the story” of the charged conspiracies. See Cummings, 60 F. Supp. 3d at 438 (defendant’s prior crack arrests and firearms conviction not sufficiently connected to underlying conspiracy to distribute crack and possessing firearms to be admissible); Townsend, 2007 WL 1288597, at *2 (defendant’s prior narcotics and firearm transactions with the same confidential informant not “inextricably intertwined” with the charged narcotics conspiracy, even though the conduct was “generally similar to the conduct underlying the offenses charged in the indictment”); United States v. Mahaffy, 477 F. Supp. 2d 560, 566 (E.D.N.Y. 2007) vacated in part on other grounds 285 Fed. App’x 797 (2d Cir. 2008) (similar prior financial crime not inextricably linked to the charged crime where prior act “was a separate, discrete offense that may be conceptually segregated from the charged offenses without impairing the jury’s ability to understand the facts underlying the schemes alleged in the indictment”); Nektalov, 325 F. Supp. 2d at 369-70 (prior similar money laundering transactions between defendant and cooperating witness not “inextricably intertwined” with the charged money laundering offense or “necessary to complete the story” of the charged conspiracy (emphasis in original)). The fact that the government included Accuser-3’s allegations in the S2 Indictment is of no consequence. Although Rule 404(b) typically governs the admissibility of “other acts” that are not charged in the indictment, in this case, the government evidently charged the conduct under the mistaken belief that Accuser-3 was a minor when she engaged in sex acts with Epstein: DOJ-OGR-00006639