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Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page5of13 Page 5 charged in the Indictment. But even if it is not, it is certainly admissible under Rule 404(b). A. Direct Evidence As the Government argued in its motion, evidence relating to Minor Victim-3 is direct evidence of the Mann Act conspiracies. The defendant’s conduct regarding Minor Victim-3 overlaps in time and place with the other Minor Victims charged in the Mann Act conspiracies: Counts One and Three charge conduct from 1994 to 2004 in New York and Palm Beach, and Minor Victim-3 began giving Epstein sexualized massages in 1994, traveling to meet Epstein and the defendant in both New York and Palm Beach. The Government expects the defendant’s 399 relationship with Epstein to be a “‘critical factual dispute’”—-specifically, whether that relationship included conspiring with him and aiding or abetting Epstein’s sex crimes. United States v. Robinson, 702 F.3d 22, 37 (2d Cir. 2012). Minor Victim-3’s testimony will help establish that it did. Evidence relating to Minor Victim-3 also “fills in a narrative” about “why [the defendant] took actions to” arrange sexualized massages. United States v. Rodriguez, 727 F. App’x 24, 26 Finally, evidence related to Minor Victim-3 is direct evidence as corroboration for the other three Minor Victims. Those Minor Victims will describe a conspiracy that operated to recruit girls for the purposes of massage, groom them, and transform the massages into sexual encounters. The conspirators then traveled with the girls or invited girls to travel, and asked the girls to find others DOJ-OGR-00007422