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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

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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