DOJ-OGR-00006745.jpg
Extracted Text (OCR)
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 37 of 84
following the charged conduct. Both categories of evidence are admissible as direct evidence of
the charged conduct, or in the alternative under Rule 404(b).
a. Government Exhibits 401 through 404, 409 through 410, and 413
Turning first to the exhibits, the Government has notified the defense that it intends to offer
several emails that show that “the defendant took steps to please other influential men by providing
them access to women she selected for them.” (October 11, 2021 Letter, Def. Mot. 2 Ex. A at 1).
The defendant sent these emails during the timeframe of the charged conduct. In other words,
during the same time the defendant was taking steps to recruit and groom minor victims for Jeffrey
Epstein, she was also using her ability to provide access to women as a form of social currency
with other influential men with whom she sought to ingratiate herself.
36
DOJ-OGR-00006745
Extracted Information
Document Details
| Filename | DOJ-OGR-00006745.jpg |
| File Size | 467.5 KB |
| OCR Confidence | 93.9% |
| Has Readable Text | Yes |
| Text Length | 965 characters |
| Indexed | 2026-02-03 17:13:58.493962 |