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Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 38 of 84 The defendant claims that these exhibits show nothing more than the defendant arranging “dates” for adults. But the jury could easily draw different inferences from these exhibits. The exhibits go directly to the defendant’s intent and motive, because they show (1) the defendant’s willingness to facilitate encounters between powerful men and women they would like, and (2) the defendant’s understanding that providing such access is a way to ingratiate herself with powerful men. At trial, it may not be obvious to a jury that an adult woman would be willing to provide Jeffrey Epstein with access to young girls. These emails make clear that the defendant was willing to serve in such a role, and that she was eager to please wealthy and influential men by providing them with access to women. Accordingly, these exhibits are probative of the issues the jury will be asked to resolve at trial and should be admitted as direct evidence of the charged crimes.’ In the alternative, this evidence is probative of the defendant’s motive, intent, plan, and knowledge, and should be admitted pursuant to Rule 404(b)(2). And the defendant’s claim that these emails concern lawful 8 The remaining exhibits identified in the Government’s October 11, 2021 letter are necessary to identify the parties to the emails. ’ This evidence would also be admissible to rebut defense arguments concerning similar topics, and in cross-examination of the defendant. 37 DOJ-OGR-00006746