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Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page7of13 Page 7 to engage in commercial sex acts, an element of the offense. The latter is evidence that the defendant and Epstein engaged in sex trafficking of minors, which requires that the minor victim be under eighteen rather than seventeen. Minor Victim-3’s testimony will show that she had sexual encounters with Epstein, and in combination with the testimony of other Minor Victims, the evidence will show that Epstein continually sought out girls under the age of 18 for sex from 1994 through the time period of the sex trafficking conspiracy.” B. Rule 404(b) In any event, evidence relating to Minor Victim-3 is relevant for multiple purposes that are permissible under Rule 404(b). First, it is relevant to the defendant’s knowledge that the massages were sexualized, an issue that is expected to be central at this trial. The Government anticipates that Minor Victim-3 will describe A jury could conclude from each of these facts that * Evidence related to Minor Victim-3 is similarly relevant to the Mann Act counts. The Mann Act counts require that the victims be under seventeen, rather than eighteen. But evidence that Epstein had a sexual preference for women much younger than him, including seventeen-year-olds, is robative of whether he had a sexual preference for sixteen- DOJ-OGR-00007424