Fron: ee Subject: FW: Rule 412 Date: Fri, 05 Nov 2021 17:38:04 +0000 Attachments: Def. 412 Mot. for edacted.pdf Very good to speak with you just now, thanks very much for taking the time to talk. As | mentioned, attached is the defense’s motion seeking to admit certain evidence aboutbackground at trial. The hearing on this motion will now be on November 10, 2021. As we discussed, | already intended to bring out at trial the fact that [J was previously sexually abused and sexually active with JJ because she discussed those facts with Maxwell and Epstein, so they are relevant to the charges. However, the remaining details referenced in this motion are irrelevant to the charges, so we intend to oppose their admission at trial. You and la both have a right to be heard on the motion at the November 10"" hearing, but there is no requirement that you appear. Please let me know if you or [J wish to be heard on this motion, in which case I'll coordinate with the Court regarding the logistics. As always, please feel free to call my cell (MM) if you have any questions or would like to discuss this or anything else. I'll keep you posted as we finalize the logistics for J travel to New York for her trial testimony. Thanks, — Sent: Friday, October 29, 2021 3:38 PM To: Ce: Subject: Rule 412 Attached please find a redacted version of the defense’s Rule 412 motion, which was filed under seal. Our response will be filed under seal on Monday. If the Court holds a hearing on the motion, it will be in camera on Friday, November 5, 2021. I'm also attaching the Court’s Order about the November 1 in-person pretrial conference. Thanks, Assistant United States Attorney United States Attorney’s Office EFTA00095747

--=PAGE_BREAK=--

Southern District of New York One St. Andrew’s Plaza New York, New York EFTA00095748