DOJ-OGR-00004730.pdf

--- Page 1 --- **Document Header** * Case Number: 1:20-cr-00330-PAE * Document Number: 295 * Filed Date: 05/25/21 * Page Number: 23 of 26 **Text Body** detail as to the Government's theory of the case and the nature of the proof that will underlie the charges at trial"). Moreover, the discovery in this case has provided the defense with even more information regarding the charges contained in Counts Five and Six, thus providing another basis on which to deny this motion. To assist the defense in reviewing this discovery, the same day that the S2 Indictment was returned, the Government provided the defense with a list of particular Bates ranges that relate specifically to Minor Victim-4 and the charges contained in Counts Five and Six. As a result, the Government has identified particularly relevant pieces of evidence regarding these charges for the defense. (See Dkt. No. 188 at 3-4). This evidence includes, among other things, portions of message pads seized from Epstein's Palm Beach residence referencing messages left by Minor Victim-4 during the period charged in Counts Five and Six; phone records reflecting calls made by another Epstein employee to Minor Victim-4; Federal Express records reflecting a shipment from Epstein's address in New York to Minor Victim-4; and contemporary photographs of Minor Victim-4. The Government has also provided the defense with Minor Victim-4's birth month and year. Additionally, the defense has flight records for Epstein's private plane, reflecting when Epstein, the defendant, and other employees traveled to and from Palm Beach on the plane during the period charged in Counts Five and Six. In other words, the discovery provides the defendant with more than sufficient information about Minor Victim-4 to permit her to prepare for trial. Similar to the other three minor victims referenced in the S2 Indictment, any remaining detail regarding the specifics of abuse and particular interactions will come from witness testimony. As is to be expected when describing events more than a decade in the past, that testimony will provide approximate time periods when events occurred, rather than specific dates. **Footer** * DOJ-OGR-00004730 **Page Number** * 19