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Case 1:20-cr-00330-PAE Document600_ Filed 02/11/22 Page 28 of 37 of the same overarching conspiracy charged in Counts One and Three, with the same co- defendants, the same method of operation, and the same objectives. See Macchia, 35 F.3d at 669 (“The Government cannot be permitted to retry defendants on smaller and smaller conspiracies, wholly contained within the scope of a large conspiracy, until it finds one small enough to be proved to the satisfaction of a jury.” (citation omitted)). 2. Similarity of Operation, Common Objectives, and Geographic Scope The government’s charging theory in the Indictment and its presentation of the evidence at trial was that Epstein and Maxwell engaged in a single criminal scheme with a common method of operation to recruit and “groom” underage females to engage in illegal sexual activity in multiple locations, including Epstein’s residences in New York, Palm Beach, New Mexico, and the U.S. Virgin Islands. Indeed, in summarizing the evidence for the jury, the government highlighted that Epstein and Ms. Maxwell used the same “playbook” with all four of the accusers and argued that this common method of operation was one of the principal reasons that the jury could convict Ms. Maxwell on all counts: The second reason that you know that Maxwell is guilty is that she ran the same playbook over and over and over again as she exploited young girls. The similarities between what happened to Jane and Annie and Carolyn and Kate are incredibly powerful evidence of the defendant’s guilt. So I want to talk to you about the playbook that Maxwell ran again and again and again. Tr. 2848:16-22 (emphasis added); see also Tr. 2853:14-16 (“The patterns you saw throughout this trial, the playbook that Maxwell ran for years, is just one of the many ways that you know that Maxwell is guilty.’’). The common “playbook” that the government described started by targeting vulnerable kids, like the four accusers, who all came from single-mother households with financial or other hardships. Tr. 2849:18-2850:17. Epstein and Ms. Maxwell then isolated the girls from their parents and began “grooming” them for sexual abuse by taking an interest in their lives, making 23 DOJ-OGR-00008952