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Case 1:20-cr-00330-PAE Document621 Filed 02/25/22 Page 48 of 51 Because the defendant cannot meet her “heavy burden” of establishing either element of unconstitutional delay, Cornielle, 171 F.3d at 752, let alone both, her motion to vacate her conviction or dismiss the Indictment for pre-indictment delay is meritless and should be denied. IV. The Court Should Deny the Defendant’s Motion for Judgment of Acquittal Under Rule 29 In a brief paragraph at the end of her motion, the defendant “reasserts th[e] same motion” under Rule 29 she made following the close of the Government’s case and the close of her case and “incorporates the arguments previously made to the Court.” (Def. Mot. at 30). The Court should reject those arguments as it has before. The defendant has only offered a specific challenge to the sufficiency of the evidence as to Counts One and Two, the enticement counts. Specifically, the defendant argued that the record lacked sufficient evidence that the defendant “or anyone else who allegedly participated in this conspiracy persuaded, induced, or enticed Jane to travel to New York to engage in illegal sexual activity.” (Tr. 2266-67; see Tr. 2269-70 (“There is not testimony whatsoever that Ghislaine Maxwell encouraged [Jane] to travel.”)). Of course, the jury acquitted the defendant on Count Two, the substantive enticement count. As to Count One, the jury could have readily concluded that the defendant conspired with Epstein to groom minor victims and entice them to travel to Epstein’s various properties, including his home in New York, to be sexually abused. For instance, Jane testified that she was abused by Epstein and the defendant in New York. (Tr. 320). And the record is replete with testimony regarding the manner in which the defendant worked with Epstein to groom minor victims and entice them to travel to Epstein’s properties. (See, e.g., Tr. 300 (Jane seeing the defendant topless), 348 (making Jane feel special, in part by taking her on “field trips”), 47 DOJ-OGR-00009610