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Case 1:20-cr-00330-PAE Document600_ Filed 02/11/22 Page 27 of 37 Tr. 41:7-16 (emphasis added). The government was correct that the proof at trial established, at most, a single decade-long conspiracy between Epstein and Ms. Maxwell with multiple objects, rather than multiple independent conspiracies. An analysis of the Korfant factors confirms that the three conspiracies charged in Counts One, Three, and Five are virtually identical and are therefore multiplicitous.* 1. Overlap of Participants and Time There is no dispute that the central co-conspirators in all three charged conspiracies were Epstein and Ms. Maxwell. According to the government, Epstein and Ms. Maxwell were “partners in crime” who sexually exploited young girls throughout the entire ten-year time period charged in the Indictment. Tr. 33:7-34:13; Tr. 2842:11-2845:9. Epstein was the principal abuser and Ms. Maxwell was his “best friend and right hand” and his “closest associate and second in command.” /d. Although other participants later joined the scheme, such as Sarah Kellen, Epstein and Ms. Maxwell were the core of the conspiracy from its inception in 1994 through its conclusion in 2004. See United States v. Reid, 475 F. App’x 385, 387 (2d Cir. 2012) (“[C]hanges in membership do not necessarily convert a single conspiracy into multiple conspiracies, and there is no requirement that the same people be involved throughout the duration of the conspiracy.” (cleaned up)). Furthermore, the Mann Act conspiracies related to all four accusers who testified at trial—Jane, Kate, Carolyn, and Annie Farmer—and spanned the same relevant ten-year period, 1994-2004. Although the sex trafficking conspiracy (Count Five) related only to Carolyn and lasted for a shorter time period from 2001-2004, that count, which was later added to the S2 Indictment, did not describe a separate conspiratorial agreement. Rather, it was simply a subset * The first factor, an analysis of the criminal offenses charged in “successive indictments,” is inapplicable here because Ms. Maxwell has been charged with two § 371 conspiracies in the same indictment. The multifactor test, however, remains applicable. See Cooper, 886 F.3d at 155. Ze DOJ-OGR-00008951