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Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 36 of 52 alleged scheme to cause minors to travel to engage in illegal sex acts, or her knowledge of the same. See Mot. at 11. Nor is the evidence of alleged “grooming” sufficiently unique to qualify as proof of “modus operandi.” See id. at 12. Furthermore, there is a strong likelihood that the jury will assume that Epstein’s alleged sex acts with yg were illegal and will misapply that evidence in evaluating Ms. Maxwell’s guilt or innocence to the charged Mann Act conspiracies. Her evidence should therefore be excluded under Rule 403. See id. at 12-13. If the Court decides to admit evidence, it should preclude the government and i from referring to her as a “minor” or asserting that she was a “minor” at the time of the alleged sex acts, (2) preclude the government and from representing that she was “sexually abused” by Jeffrey Epstein, and (3) give the jury the appropriate limiting instruction the defense has requested. See Mot. at 14-15. The government argues that the term “minor” is appropriate becausc was, for a brief time, below the age of 18, which is the age of consent under federal law. Resp. at 52-53. Although the government would like to believe that U.S. federal law is the only law that matters, even as to acts that allegedly took place in a foreign country, that is not the case. The Court should not permi{ggggg to be referred to as a “minor” because she was not a “minor” under the laws of the relevant jurisdiction when any of the alleged sex acts took place. It would not only be inaccurate to call her a “minor,” but it would also mislead the jury to believe that the acts that allegedly took place in the U.K. were “criminal sexual activity” when they were not. The same is true for the phrase “sexual abuse,” which connotes criminal activity. See Mot. at 14-15 (citing Esquivel-Quintana v. Sessions, 137 S. Ct. 1562, 1569 (2017)). Finally, the government opposes the defense’s requested jury instruction regarding the age of consent under U.K. law on the grounds that it is “irrelevant” and would “‘confuse the 30 DOJ-OGR-00006916