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Case 18-2868, Document 286, 08/09/2019, 2628248, Pagel of 55 EXHIBIT NN

Case 18-2868, Document 286, 08/09/2019, 2628248, Page2 of 55 United States District Court Southern District Of New York Virginia L. Giuffre, Plaintiff, v. 15-cv-07433-RWS Ghislaine Maxwell, : Defendant. DEFENDANT GHISLAINE MAXWELL’S INITIAL F.R.C.P. 26(a)(1)(A) DISCLOSURES Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following disclosures: L IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH PARTICULARITY IN THE PLEADINGS 1. Ghislaine Maxwell c/o Laura A. Menninger, Esq. Haddon, Morgan & Foreman, P.C. 150 E. 10" Ave. Denver, CO 80203 303-831-7364 LMenninger@HMFLaw.com Ms. Maxwell is the Defendant and may have knowledge concerning matters at issue, including the events of 1999-2002 and the publication of statements in the press in 2011-2015. 2. Virginia Lee Roberts Giuffre c/o Sigrid S. McCawley, Esq. Boies, Schiller & Flexner LLP 401 East Las Olas Boulevard, Suite 1200

Case 18-2868, Document 286, 08/09/2019, 2628248, Page3 of 55 Miami, Florida 33301 (954) 356-0011 smcecawley @bsfllp.com Ms. Giuffre is the Plaintiff and has knowledge concerning the matters at issue in her Complaint, including the events of 1996-2015 and the publication of statements in the press in 2011-2015. 3. Philip Barden Devonshires Solicitors LLP 30 Finsbury Circus London, United Kingdom EC2M 7DT DX: 33856 Finsbury Square (020) 7628-7576 Philip.Barden @devonshires.co.uk Mr. Barden has knowledge concerning press statements by Plaintiff and Defendant in 2011-2015 at issue in this matter. 4. Paul Cassell College of Law, University of Utah 383 South University Street Salt Lake City, UT 84112 801-585-5202 paul.cassell @law.utah.edu Mr. Cassell has knowledge concerning press statements by Plaintiff, Plaintiff's court pleadings, and Plaintiffs sworn testimony. 5. Alan Dershowitz c/o Richard A. Simpson, Esq. WILEY REIN, LLP 1776 K Street NW Washington, D.C. 20006 (202) 719-7000 Mr. Dershowitz has knowledge concerning Plaintiff’s false statements to the press, in court pleadings, and in sworn testimony, at issue in this matter. 6. Bradley Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Ft. Lauderdale, FL 33301 (954) 524-2820 brad @pathtojustice.com

Case 18-2868, Document 286, 08/09/2019, 2628248, Page4 of 55 Dated: February 24, 2016. Respectfully submitted, s/ Laura A, Menninger Laura A. Menninger (LM-1374) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10 Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 Imenninger@hmflaw.com Attorney for Ghislaine Maxwell CERTIFICATE OF SERVICE I certify that on February 24, 2016, I electronically served this DEFENDANT Sigrid S. McCawley BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smcecawley @bsfllp.com GHISLAINE MAXWELL'S INITIAL F.R.C.P. 26(A)(1) DISCLOSURES via e-mail on the following: s/ Laura A. Menninger Laura A. Menninger

Case 18-2868, Document 286, 08/09/2019, 2628248, Page5 of 55 EXHIBIT OO

To: Sharon cheP RG Re S RE rdaPHM SSA ORS ARAR RDF 88, ky Page6 of 55 From: Virginia Giuttre Sent: Thur 5/42/2014 2:24:43 AM Importance: Normal Subject: Re: Good News!! Received: Thur 5/12/2044 2:21:43 AM Thanks again Shazza, I'm bringing down the house with this book!!! xoxo Jenna, --~- On Wed, 11/5/11, Sharon.Churcher@mailonsunday.co.uk <Sharon. Churcherémuilonsunday.co.uk> wrote From. Sharon. Churcher@ mailonsuuday co.uk <Sharon.Churcher@:mailonsunday co.uk> Subject: Re: Good News!! To: "Virginia Giuffre" < = Received: Wednesday, 11 May, 2011, 4.17 PM Don't forget Alan Dershowitz. JE's buddy and tawyer..good name tor your pitch as he repped Claus von Bulow and a movie was made about that case...title was Reversal of Fortune. We all suspect Alan is a pedo and tho no proof of that, you probably met him when he was hanging put w JE 011 23:00 GDT |-- “ |Hi Sharon, | | |Hcllo gorgeous, I hope this message comes to you on a bright, sunny day!!!| |I took your advice about what to offer Sandra and she accepted. Were | \drawing up a contract through her agent right now and getting busy to meet| 1 Copyright Protected Matenal CONFIDENTIAL GTUFFREDOAQO6

Case 18-2868, Document 286, 08/09/2019, 2628248, Page7 of 55 |my deadline. Just wondering if you have any information on you from when | lyou and I were doing interviews about the LE story. [ wanted to put the | |names of some of these assholes, oops, ! meani to say, pedo's. that tH |scnt me to. With cyerything going on my brain fecis like mush and it woutd| [be a great deal of help! | |Having fun swectic? | | |Thanks, | \Tenna | his email has been scanned by the MessageLabs Emat! Security System Tor more information please visit hun: ego Jonail This c-mail and any attached files are intended for the named addressee only, it contains information, which may be confidential and fcgally privileged and also protceted by copyright. Unless you are the named addressee (ar authorised to receive for the addressee) you may not copy or use it, or disclose it to anyone else. If you recetved it in crror please notify the sender immediately and then delete it from your system, Please be advised that the views and opinions expressed in this ¢-mail may not reflect the vicws and opinions of Associated Newspapers Limited or any of its subsidiary companies. We make every effort to keep our network free from viruses. However. you do need to cheek this e-mail and any attachments to it for viruses as we can take no responsibility for any computer virus which may be wansfetred by way of this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully carry out to prevent abuse of these facilitics. Associated Newspapers Ltd. Registered Office: Northcliffe House, 2 Derry St, Kensington, London, W8 STT. Registered No 84121 England. 1 Copyright Protected Maverial CONFIDENTIAL, GTUEFREDAG97T

ro: sharon chiA RR CS RORYRDSENLARG, QP9O/2019, 2628248, PageB of 55 From: Virginia Giuftre Sent Wad 6/8/2011 11:19:55 PM Importance: Normal Subject: Re: Virginia Roberts Received: Wed 6/8/2041 11:19:55 PM Hi Buddy, You are absolutely right...nail biting is an understatement of the century!!! We didn't have any trouble with spiders or anything like that yesterday, it was more my daughter that gave everyone a spook! She wandered off when I turned ny back to look at homemade jam and found her outside in the bush chasing the roo's!! My own miniature Tarzan!!! My fingers and toes are crossed and I'm thinking positive!!! Much Love, Jenna -- On Wed, 8/6/11, Sharon Churcher <Sharen. Churcher@mailonsunday.co.uk> wrote. From: Sharon Churcher <Sharon.Churcher@mailonsunday. Subject: Re: V a Robert To." Received: Wednesday, 8 June, 2011, 11:59 AM uk> have to duck under spider -vels? They were sirung between trees when 1 went. Re Jareest: i are others. Di tit HOH her be ws nly one 9: mu send i” 1cli iS good, UF he does t go Xx From: Virginia Ginitie Seat: Wednesday, Juoe 08, 201 1 07:27 AM To: Sharon Churcher Subject: Re: Viryinia Roberts Dearest Shazza. Ounce again you have really outdone yourself... MANY, MANY, THANKS!!! Ttook the kids to the Australian Walkabout Park today and enjoyed the scenic watks and many kangaroos, Rob and I hac good chuckle about our adventures at the Reptile Park with you and Mike ...good times!!! Have you heard from Mike? I hope he is weil and if you ever speak, tell him I sent a BIG hello. Treally appreciate everything you have helped with, as a triend you have gone beyond the call of duty!!! T hope we hear back trom Jarred soon!! xoxoxo Jonna --- On Wed, 8/6/11, Sharon Churcher <Sharon. Churcher@mailonsunilay.co.uk> wrote: From: Sharon Churcher <Sharoa.Churcher@mailoasunday.co.uk> Subject: Virginia Roberts To: "jarred halperin agent (arred| Ce: "Virginia Giuifre” < Received: Wednesday, 8 June, 201}, 2:31 AM bo tivecnt.com)" <jarred@objcctivcent.com> 1 Copyright Protected Maverial CONFIDENTIAL SHUFFREDD4028

Case 18-2868, Document 286, 08/09/2019, 2628248, Page9 of 55 Hi Jarred Hopefully you have Virginia’s book pitch by now. She has some amazing names which she can share with you in confidence and | think she also has a human interest story that could appeal to the Oprah/female set as well as the Wall Streeters who follow Epstein — a hedge fund king. Here are a few of our stories about Virginia, plus some examples of the massive US and other international media pickup. Vanity Fair are doing a piece | believe in their August issue. The FBI have reopened the Epstein case due to Virginia’s revelations. | also am attaching a link to a NY Magazine profile of Epstein.....written before his world combusted. The FBI believe he was essentially running a private — and mobile -- brothel for some of the world’s richest and most influential men. He got off the first ime round after retaining Kenneth Starr (who witchhunted Bill Clinton) and Alan Dershowitz (von Bulow's appeal lawyer, who inspired the movie Reversal of Fortune). The US Justice Dept is investigating corruption allegations against at least one prosecutor involved in the case. Best regards, Sharon get the gist) http./Awew. telegraph, co.uk/news/uknews/theroyalfamily/8362690/Prince-Andrew.html Noa dailvielears http://nymag.com/nymetro/news/people/n_7912/ This e-mail and any attached files are intended for the named addressee only It contains information, which may be confidential and legally privileged and also protected by copyright, Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or use it, or disclose it to anyone else. If you received it in error please notify the sender immediately and then delete it from your system. Please he advised that the views and opinions expressed in this e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of iis subsidiary companies. We make every effort to kecp our network fee from viruses. However, you do need to check this c-mail and any attachments to it for viruses as we can take Bo responsibility for any computer virus which may be transferred by way of this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully carry out to prevent abuse of these facilitics. Associated Newspapers Lid, Registered Office: Northcliffe House, 2 Derry St, Kensington, London, W8 STT. Registered No 84121 England. Shis email has been scanned by the MessageLabs Email Security System Tor more information please visit http:/www.messagclabs. comiemait This email has been scanned by the MessageLabs Email} Sceusity System. | Copyright Protected Maveral CONFIDENTIAL, CTUFFREDN029

Case 18-2868, Document 286, 08/09/2019, 2628248, Page10 of 55 For more information please visit http://www messagclabs.com/email This c-mail and any attached files are intended for the named addressce only. It contains information, which may be confidential and legally privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or usc it, or disclose it to anyone else, If you reecived it in error please notify the sender immediately and then delete it from your system. Please be advised that the views and opinions expressed in th e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of i subsidiary companies. We make every effort to keep our network free trom viruses. However, you do necd to check this e-mail and any attachments it for viruses as we can take no responsibility for any computer virus which may be transferred by way of this e-mail. Use this or any other c-mail facility signifies consent to any interecption we might lawfully carry out to prevent abuse of thes: facilities. Associated Newspapers Ltd. Registered Office: Northcliffe House, 2 Derry St, Kensington, London, W8 STT. Registered No 84121 England. 1 Copyright Protected Material CONFIDENTIAL GTUFFRED04030

Case 18-2868, Document 286, 08/09/2019, 2628248, Page11 of 55 EXHIBIT PP

Case 194gren Blande,Coust Reporting & Video, TAGe12 of 55 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS CONFIDENTIAL VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME ITI November 14, 2016 VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. APPEARANCES: BOIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301 Phone: 954.356.0011 smccawley@bsfllp.com Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE VOLUME II 11/14/2016 348

Case 194gren Blande,Covst Reporting & Video, Tage13 of 55 APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura Menninger, Esq. 10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 imenninger@hmflaw.com jpagliuca@hmflaw.com Appearing on behalf of the Defendant Also Present: Ann Lundberg, Paralegal Maryvonne Tompkins, Videographer VIRGINIA GIUFFRE VOLUME II 11/14/2016 349

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 19Agren Blande,Covst Reporting & Video, Tage14 of 55 Pursuant to Notice and the Federal Rules of Civil Procedure, the continued video deposition of VIRGINIA GIUFFRE, called by Defendant, was taken on Monday, November 14, 2016, commencing at 8:04 a.m., at 150 East 10th Avenue, Denver, Colorado, before Pamela J. Hansen, Registered Professional Reporter, Certified Realtime Reporter and Notary Public within Colorado. VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME IT EXAMINATION PAGE By Ms. Menninger 354 VIRGINIA GIUFFRE VOLUME II 11/14/2016 350

10 11 12 13 14 15 16 a? 18 19 20 21 22 23 24 25 Case 194gren Blande,Coust Reporting & Video, TaGe15 of 55 DESCRIPTION Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit 1. 10 11 12 13 14 INDEX OF EXHIBITS (continued) INITIAL REFERENCE Settlement Agreement and General 355) Release List of names 370 Photocopy of photograph 408 Photocopy of photograph, with 411 attachments Photocopy of photograph, with 417 attachments Photocopy of photograph, with 423 attachments Statements 437 History of education, with 462 attachment Application for Employment, 474 with attachment The Great Outdoors Community 481 Services Association, Inc. Termination Form, with attachments 7/6/2016 letter to Schultz 484 from Hayek, with attachments Patient Registration 490 Information, with attachments CVS Prescription Records 502 document, 7/29/2016, with attachment Affidavit of Custodian of 507 Records, Walgreen Company, with attachments VIRGINIA GIUFFRE VOLUME II 11/14/2016 351

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 DESCRIPTION Ex Ex Ex Case 19Agren Blande,Covst Reporting & Video, TaGe16 of 55 hibit hibit hibit Exhibit Ex Ex hibit hibit 15 16 17 18 19 20 INITIAL REFERENCE Patient Health Summary, Clifton 512 Beach Medical & Surgical, printed on 6/28/2016 Portions of deposition transcript 533 of Virginia Giuffre taken May 3, 2016 Amendment/Errata Sheet signed 540 May 31, 2016 by Virginia Giuffre Ad for Mar-a-Lago Club 548 The Mar-a-Lago Club, L.C. 549 Employment Policies, October 28, 1995 Page from the Mar-a-Lago Club 550 Employment Policies, Revised 10/2001 VIRGINIA GIUFFRE VOLUME II 11/14/2016 352

10 11 12 13 14 15 16 a? 18 19 20 21 22 23 24 25 Case 194gren Blande,Coust Reporting & Video, Tage17 of 55 didn't see them take pictures of the backs of them. I'm not too sure who. QO You don't remember sending to them a photograph that included this wood around another photograph? A No. Q Okay. You have mentioned a journalist by the name of Sharon Churcher. A Yes. Q You are aware that Sharon Churcher published news stories about you? A Ves. MS. MCCAWLEY: Objection. Go ahead. QO (BY MS. MENNINGER) Is anything that you have read in Sharon Churcher's news stories about you untrue? A I think Sharon did print some things that I think she elaborated or maybe misheard. But, I mean, if you have a specific document to show me, I'd love to look at it and read it and tell you what I think. QO Is there anything, as you sit here today, that you know of that Sharon Churcher printed about you that is not true? VIRGINIA GIUFFRE VOLUME II 11/14/2016 435

10 11 12 13 14 15 16 a? 18 19 20 21 22 23 24 25 Case 194gren Blande,Covst Reporting & Video, Tngeis of 55 A Not off the top of my head. If you show me, like, a news clipping article or something, I can definitely read it for you. Q Is there anything that you know of that Sharon Churcher has printed about Ghislaine Maxwell that is not true? A No, not off -- no, not off the top of my head. QO Is there anything that you recall saying to Sharon Churcher that she then printed something different than what you had said to her? A Yeah, I've read stuff. I mean, I just -I can't remember what, but I read something that I think was, Oh, she got that wrong. I can't remember an exact example off the top of my head. Q Did you ever complain to Sharon Churcher about things that she got wrong? A I didn't see a point. I might have, but I -- I didn't see a point really because it's already printed, you know. Q You had a fairly voluminous set of communications with Sharon Churcher by e-mail, correct? MS. MCCAWLEY: Objection. A Voluminous, like a lot of them? VIRGINIA GIUFFRE VOLUME II 11/14/2016 436

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 194gren Blande,Coust Reporting & Video, TAGe19 of 55 Q (BY MS. MENNINGER) Yes. A Yes. Q And during any of those communications, do you know whether she printed things about you after you had any of those communications? MS. MCCAWLEY: Objection. A I don't know. I know a lot of stuff was printed, and I never really stopped to read who printed the article, or wrote the article, I should say. Sorry. QO (BY MS. MENNINGER) Okay. I'll show you Defendant's Exhibit 7. (Exhibit 7 marked.) THE DEPONENT: Thank you. Q (BY MS. MENNINGER) I'll let you read through the statements on the first page there, and if there is anything that is not absolutely true, just put a check by it and we'll come back to it. A It's not very clear how she wrote it. wT flew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill in a huge black helicopter that Jeffrey had bought her." That wasn't an eyewitness statement. Like, I didn't see her do it. Ghislaine was the one who told me about that; that she's the one who flew VIRGINIA GIUFFRE VOLUME II 11/14/2016 437

10 11 12 13 14 15 16 a? 18 19 20 21 22 23 24 25 Case 194gren Blande,Covst Reporting & Video, TAGe20 of 55 Bill. Q All right. If you just want to put a check by it, then we'll just come back and talk about each one. A Okay. Q Just to move things along. A Okay. I have made three checkmarks. Q All right. MS. MCCAWLEY: And I just -- before you continue, I just want to identify for the record, since this doesn't have any identifiers on it, are you representing that these are statements from Sharon Churcher? MS. MENNINGER: I'm not representing anything. I'm asking the witness questions about these statements. I asked her is anything on here not true. That's all I asked her. Q (BY MS. MENNINGER) So which ones did you put checkmarks by, Ms. Giuffre? A I'd have been -- I'm sorry. "I'd have been about 17 at the time. I flew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill in a huge black helicopter that Jeffrey had bought her." Q Okay. And what else did you put a check VIRGINIA GIUFFRE VOLUME II 11/14/2016 438

10 11 12 13 14 15 16 a? 18 19 20 21 22 23 24 25 Case 194gren Blande,Covst Reporting & Video, TAGe21 of 55 by? A "T used to get frightened flying with her but Bill had the Secret Service with him and I remember him talking about what a good job" -—sorry -- "job she did." Q Okay. And what else did you put a check by? A "Donald Trump was also a good friend of Jeffrey's. He didn't partake in any sex with any of us but he flirted with me. He'd laugh and tell Jeffrey, ‘you've got the life.'" Q Other than the three you've just mentioned -A Yeah. Q -—- everything else on here is absolutely accurate? MS. MCCAWLEY: Objection. A Yes. Well, to the best of my recollection, yes. QO (BY MS. MENNINGER) All right. What is inaccurate about, "I'd have been about 17 at the time. I flew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill in a huge black helicopter that Jeffrey had bought her"? A Because it makes it kind of sound like an VIRGINIA GIUFFRE VOLUME II 11/14/2016 439

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 194gren Blande,Covst Reporting & Video, TAGe22 of 55 eyewitness thing. oO Okay. Did you say that statement to Sharon Churcher? A I said to Sharon that Ghislaine told me that she flew Bill in the heli- -- the black helicopter that Jeffrey bought her, and I just wanted to clarify that I didn't actually see her do that. I heard from Ghislaine that she did that. Q You heard that from Ghislaine, and then you reported to Sharon Churcher that you had heard that from Ghislaine. A Correct. MS. MCCAWLEY: Objection. A I heard a lot of things from Ghislaine that sounded too true -- too outrageous to be true, but you never knew what to believe, so... QO (BY MS. MENNINGER) Okay. And after Sharon Churcher printed what she said you said, did you complain to her that it was inaccurate? A I might have verbally with her, but again, I didn't see a point in making a hissy over it because what was done was done. She had already printed. QO What was inaccurate about, "I used to get frightened flying with her but Bill" said -- "had the VIRGINIA GIUFFRE VOLUME II 11/14/2016 440

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 194gren Blande,Covst Reporting & Video, Tage23 of 55 Secret Service with him and I remember him talking about what a good job she did"? A I just don't remember saying that to her. I don't remember saying I remember him talking about what a good job she did. QO All right. A I just don't remember that at all. QO Okay. And I guess, just to be clear, my questions wasn't do you remember saying this to Sharon Churcher; my question is, is that statement accurate? MS. MCCAWLEY: Well, objection. Q (BY MS. MENNINGER) Did you used to get frightened flying with her? A Yes. Q Okay. Did Bill have the Secret Service with him? A They were there, but not like on the -not where we were eating. QO Do you remember Bill talking about what a good job she did? A I don't remember that. Q So what is inaccurate about that statement? A I just -- it's inaccurate because I don't VIRGINIA GIUFFRE VOLUME II 11/14/2016 441

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 194gren Blande,Coust Reporting & Video, Tage24 of 55 remember him talking about what a good job she did. I don't remember that. QO Does it inaccurately suggest that Bill had the Secret Service with him on a helicopter? MS. MCCAWLEY: Objection. A Well, not being an eyewitness to it, I wouldn't be able to tell you. I can't tell you what I don't know. Q (BY MS. MENNINGER) And do you believe you said that statement to Sharon Churcher? A I mean, Sharon and I talked a lot, and if she misheard me or just wrote it in the way that she thought she should, I have no control over that. So I'm not too sure. QO Did she record your interviews? A Some of them. Some of them she didn't. I mean, we, like -- we, like, met for like a week, and we spent a lot of time together, and then even after that we just continued, like, kind of a friendship. Q All right. What's inaccurate about the last statement on that page? A "Donald Trump was also a good friend of Jeffrey's." That part is true. "He didn't partake in any" of -- "any sex with any of us but he flirted with me." It's true VIRGINIA GIUFFRE VOLUME II 11/14/2016 442

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 194gren Blande,Coust Reporting & Video, Tage25 of 55 that he didn't partake in any sex with us, and but it's not true that he flirted with me. Donald Trump never flirted with me. Then the next sentence is, "He'd laugh and tell Jeffrey, ‘you've got the life.'" I never said that to her. Q When you say, “he didn't partake in any sex with any of us," who is "us"? A Girls. Just -QO How do you know who Donald Trump -- Trump had sex with? A Oh, I didn't physically see him have sex with any of the girls, so I can't say who he had sex with in his whole life or not, but I just know it wasn't with me when I was with other girls. QO And who were the other girls that you were with in Donald Trump's presence? A None. There -- I worked for Donald Trump, and I've met him probably a few times. QO When have you met him? A At Mar-a-Lago. My dad and him, I wouldn't say they were friends, but my dad knew him and they would talk all the time -- well, not all the time but when they saw each other. Q Have you ever been in Donald Trump and VIRGINIA GIUFFRE VOLUME II 11/14/2016 443

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 194gren Blande,Coust Reporting & Video, Tage26 of 55 Jeffrey Epstein's presence with one another? A No. Q What is the basis for your statement that Donald Trump is a good friend of Jeffrey's? A Jeffrey told me that Donald Trump is a good friend of his. Q But you never observed them together? A No, not that I can actually remember. I mean, not off the top of my head, no. QO When did Donald Trump flirt with you? A He didn't. That's what's inaccurate. QO Did you ever see Donald Trump at Jeffrey's home? A Not that I can remember. QO On his island? A No, not that I can remember. Q In New Mexico? A No, not that I can remember. Q In New York? A Not that I can remember. QO All right. If you could turn to the second page and read through those. Let me know if any of those are inaccurate. Just put a check by them and then we'll come back. A Okay. VIRGINIA GIUFFRE VOLUME II 11/14/2016 444

10 11 12 13 14 15 16 a? 18 19 20 21 22 23 24 25 Case 1s4gren Blande,Covst Reporting & Video, IAGe27 of 55 MS. MCCAWLEY: Before you go, Virginia, I'm going to object to the use of the second page of this document. There's no time frame on it. There's no source reference to it, so it's entirely unclear where this has come from. QO (BY MS. MENNINGER) Okay. Are you done? A Yes. QO Okay. What's the first one you've put a check by? A "The hammock photo was all over the houses," in parentheses. And Bill Clinton and -- I'm sorry, "Bill Clinton and Andrew," in parentheses, "had to have seen it." "All over the houses" is not my statement and an exaggeration. They did have that picture in the houses. And I believe, if I remember the conversation correctly, she asked, Could have Bill Clinton and Andrew seen the picture? And I said, Yes, it's possible that they could have seen it. So, I mean, it's just that -- it's not that it's totally inaccurate. I just think it's like journalist writing, had to have seen it. It doesn't mean they saw it. I just think that if it was in front of them, they would have seen it. oO So she told you that -- you told her that VIRGINIA GIUFFRE VOLUME II 11/14/2016 445

10 11 12 13 14 15 16 a? 18 19 20 21 22 23 24 25 Case 194gren Blande,Coust Reporting & Video, Tageos of 55 the photograph was in the houses -- houses? A Yes. I know he had it in New York on his desk. I know he had it in Palm Beach. I know he had it in the Caribbean. And I don't know if he had it in New Mexico. I can't remember New Mexico. Maybe. QO Where in Palm Beach was the photograph? A The massage room. Q Was that -- you did not say that they -it was all over the houses? A Correct. All over the houses would imply that it's everywhere in the house, so... Q You did not say that Andrew and Clinton had to have seen the photograph? A Correct. I -- it was more of a, if they were in front of it, they would have seen it, kind of a thing. I'm not saying it right. But it wasn't, like, had to have seen it. QO All right. What's the next statement that you put a check by? A I'm sorry, excuse me. My kids shared a beautiful cough with me again. "I spent four years as a millionaire's personal masseuse." Q What is inaccurate about that statement? A We now know, according to the timelines VIRGINIA GIUFFRE VOLUME II 11/14/2016 446

10 11 12 13 14 15 16 a? 18 19 20 21 22 23 24 25 Case 194gren Blande,Covst Reporting & Video, TAGe29 of 55 that Mar-a-Lago was able to provide for us, that it was not four years. Q How many years was it? A More like 2-1/2, I think, if I'm right, or two. I'm sorry, I'm really bad at math. But yes, the two period. QO What's the next statement that you have put a check by? A "I was a pedophile's dream." I think she took that out of context and made that her own little headline. QO Did you say that to her? A I said something along the line like, I -the -- the pedos loved me because I would do everything that they wanted for them. But do I think that -- yeah, I -- I know she made that line up herself, the pedos -- pedophile's dream. QO What's the next one you put a check by? A I put a question mark next to the next one. It says, "Three years later she was reunited with her family." I don't know what that pertains to. I don't know what timeline that means. Q Was there a period of three years where you were not with your family? A There's been longer periods than that VIRGINIA GIUFFRE VOLUME II 11/14/2016 447

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 194gren Blande,Covst Reporting & Video, TAGe30 of 55 that -- when I wasn't with my family. That's what I mean, I don't understand where that comes from. "Three years later she was reunited with her family." QO Prior to 2002, was there a period of three years where you were not with your family? A No. Q Okay. Did you say to Sharon Churcher, three years later, she was reunited with her family? A That's what I don't understand. I don't even know what that time periods pertains to. oO Do you recall saying that to Sharon Churcher? A No. QO What's the next one you put a check by? A "After about two years he started to ask me to entertain his friends." oO What's wrong with that statement? A It wasn't two years. I don't know where she got that from. Q Okay. How long was it? A Like, I can't give you an exact time period, but it wasn't right in the beginning. It was after my training, or so to speak training. So, I mean, my best guesstimate would be anywhere between four to six months. VIRGINIA GIUFFRE VOLUME II 11/14/2016 448

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 194gren Blande,Coust Reporting & Video, TaGe31 of 55 Q So you did not say to Sharon Churcher, "After about two years he asked me to entertain his friends"? A Correct. QO What's the next one you put a check by? A That's it. That's all I put a checkmark next to. Q So the rest of these are absolutely accurate? A Nothing a journalist writes is absolutely accurate, but it's -- it sounds accurate, yes. QO Do you recall Jeffrey Epstein saying to you, "I've got a good friend and I need you to fly to the island to entertain him, massage him and make him feel how you make me feel"? MS. MCCAWLEY: Objection. Go ahead. A I do remember him saying that, and I think that's more of a general- -- generalization for all the times that I was sent to the -- where is this -the island to entertain people. And that would be a quote that she made but from my words saying that's what he said to me when I had to go be with these people that he sent me to. Q (BY MS. MENNINGER) Did you say that VIRGINIA GIUFFRE VOLUME II 11/14/2016 449

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 194gren Blande,Covst Reporting & Video, TAGe32 of 55 sentence to her? MS. MCCAWLEY: Objection. A I -- I can't remember. Like I said, I think it's more of a generalization. QO (BY MS. MENNINGER) Did you meet Al Gore? A Yes. Q Did you meet Heidi Klum? A Yes. Q Did you meet Naomi Campbell? A Yes. QO Did you go on a six-week trip with Epstein in 2001? A Yeah. Yes. Sorry. Q When in 2001 did you go on a six-week trip with him? A I don't remember exactly when it was, but it's that -- it's the one where we went to Tangier, Morocco, England. I can't remember where else we went. France. QO Did the FBI tell you that Epstein had hidden cameras watching you the entire time, even when you were in the bathroom? A Yes. Q Did the FBI tell you "Everything he did was illegal because I was under age"? VIRGINIA GIUFFRE VOLUME II 11/14/2016 450

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 194gren Blande,Covst Reporting & Video, Tage33 of 55 A Yes. QO Who in the FBI told you that? A Whichever agent I was talking to. QO Which agent were you talking to? A I can't remember. I know I was talking to Jason Richards, and there was a girl, I think -- I want -- I want to say her name was Christina Pryor, just off the top of my head. And then I think there was two other agents actually at the consulate building. I don't remember their names. Very hazy. 0 When was this conversation with the FBI? A After Sharon printed the articles, the first articles that came out. I don't know how many she printed, but when the first articles came out, after that the FBI contacted me. Q And was the statement that the FBI told you "Everything he did was illegal because I was under age," in response to you telling them that you were age 15 when you met Jeffrey? MS. MCCAWLEY: Objection. A Well, that was the closest proximity I had to go off of. QO (BY MS. MENNINGER) Okay. A So, yes. Although I still was under age, I mean, even if I was 16 and 17. VIRGINIA GIUFFRE VOLUME II 11/14/2016 451

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 194gren Blande,Covst Reporting & Video, Tage34 of 55 Q Okay. And then if you could do the last page, same way; a check by anything that's not absolutely accurate. MS. MCCAWLEY: Okay. I'm going to object to this as the last page has no identifier of time or source on it. A Okay. I'm ready. Q (BY MS. MENNINGER) All right. Which ones are inaccurate? A The first one is, "Virginia got a part-time job as a changing room assistant." I was a full-time person there. Sorry. Q Okay. So did you say that to Sharon? A Again, I don't remember that exact conversation, but I know it was a full-time job, and -- I mean, full-time as in the, you know, the 9 to 5 or whatever hours it was, so it wasn't part-time. I don't remember the exact conversation that we had. QO Okay. What's the next thing you put a check by? A I put a question mark next to, "Another lady led me into Jeffrey's bedroom. The lady walked me straight through into the massage room." I have no idea what circumstance that VIRGINIA GIUFFRE VOLUME II 11/14/2016 452

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 1s4gren Blande,Covst Reporting & Video, Tage35 of 55 pertains to. Again, I don't know what that means. I don't even know what other lady she's talking about. So... Q So you don't recall saying that to Sharon Churcher? A Correct. I don't even know what it means. Q Okay. What's the next one you have a check by? A "Afterwards, she was given two $100 bills and told to return the next day. That was the beginning of the four years she spent with Epstein." Q All right. What's wrong about that statement? A Well, again, I just want to say that the four years was inaccurate based upon memory and not an actual timeline that we were able to get. Q Did you say that to Sharon Churcher, that it was four years? A I don't know if I said that to her or -oh, yeah, did I tell her it was four years? Yes, I did. I'm sorry. QO Okay. What else did you put a check by? A Well, this one is a question mark again. "Radar online has obtained exclusive diary entries of a Teen Sex Slave." VIRGINIA GIUFFRE VOLUME II 11/14/2016 453

10 11 12 13 14 15 16 a? 18 19 20 21 22 23 24 25 Case 194gren Blande,Covst Reporting & Video, Ta¢e36 of 55 It wasn't really a diary. It was, like, I don't know how many pages of something that I wrote, and Sharon used it, so... QO Did you tell Sharon it was your diary entry? A She knew it wasn't a diary entry. No. QO Okay. Were you a teen sex slave? A Yes. QO What's the next one you have a checkmark by? A "T also saw Prince Andrew at a Ranch in New Mexico." oO Did you tell that to Sharon Churcher? A No. And I think it's a mistake. Maybe she meant somewhere else, but because we had been talking about so much, maybe she just put New Mexico. I don't think Sharon intentionally lied on any of these. I just -- I think we talked so much over a period of a week, and then after that we had phone conversations, and so on and so forth, that some of the information just got misheard or mishandled, or whatever. Q And what was printed was inaccurate? A Was that printed? I don't -- I don't remember reading that in the papers, but if it was VIRGINIA GIUFFRE VOLUME II 11/14/2016 454

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 194gren Blande,Coust Reporting & Video, TA¢e37 of 55 printed it's inaccurate. Q Do you recall reading any of the ones that you put a checkmark by in the papers? A There's been so much printed, it's hard for me to remember. I mean, yes, it does sound like stuff I read before. Q When you spoke with Sharon Churcher, you agreed to waive your anonymity, right? A I did. Q Why did you agree to do that? A I felt it was time for me to tell my story. I felt it was a good time for me to come forward. I had done so much healing, and I thought that it would be good for other people to hear what's going on, how it's happening, how vulnerable other girls can be and not even know the damage that it causes later in life. And I just thought it would be the right thing to do to come forward. QO You authorized her to publish your name? A I did. oO And your photograph? A Yes. QO In 2011? A I think that was the year, yes. Q You posed for photographs with her, VIRGINIA GIUFFRE VOLUME II 11/14/2016 455

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 194gren Blande,Covst Reporting & Video, Tagess of 55 I, VIRGINIA GIUFFRE, do hereby certify that I have read the foregoing transcript and that the same and accompanying amendment sheets, if any, constitute a true and complete record of my testimony. Signature of Deponent ( ) No amendments ( ) Amendments attached Acknowledged before me this _____ss ayy of ry 20. Notary Public: My Commission Expires: Seal: PJH VIRGINIA GIUFFRE VOLUME II 11/14/2016 562

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 194gren Blande,Coust Reporting & Video, TAGe39 of 55 STATE OF COLORADO) ) ss. REPORTER'S CERTIFICATE COUNTY OF DENVER ) I, Pamela J. Hansen, do hereby certify that I am a Registered Professional Reporter and Notary Public within the State of Colorado; that previous to the commencement of the examination, the deponent was duly sworn to testify to the truth. I further certify that this deposition was taken in shorthand by me at the time and place herein set forth, that it was thereafter reduced to typewritten form, and that the foregoing constitutes a true and correct transcript. I further certify that I am not related to, employed by, nor of counsel for any of the parties or attorneys herein, nor otherwise interested in the result of the within action. In witness whereof, I have affixed my signature this 23rd day of November, 2016. My commission expires September 3, 2018. Pamela J. Hansen, CRR, RPR, RMR 216 —- 16th Street, Suite 600 Denver, Colorado 80202 VIRGINIA GIUFFRE VOLUME II 11/14/2016 563

Case 18-2868, Document 286, 08/09/2019, 2628248, Page40 of 55 Epstein did invite two young brunettes to a dinner which he gave on his Caribbean island for Mr. Clinton shortly after he left office. | I'd have been about 17 at the time. I flew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill in a huge black helicopter that Jeffrey had bought her. I remember she was very excited because she got her license around the first year we met. | [used to get frightened flying with her but Bill had the secret service with him and I remember J him talking about what a good job she did. I don't remember seeing Bill again on the trip but ] assume Ghislaine flew him back. Virginia disclosed that Mr. Clinton's vice-president Al Gore and his wife, Tipper, were also guests of Epstein on his island. Virginia said that yet another American liberal icon, Senator George Mitchell, frequently visited Epstein's New York residence. Mr. Mitchell, aged 77, was very close to Jeffrey, Virginia recalled. I also met Naomi Campbell at a birthday party of hers on a yacht in the South of France. She is a friend of Ghislaine's but she was a real bitch to me. d Donald Trump was also a good friend of Jeffrey's. He didn't partake in any sex with any of us ~ but he flirted with me. He'd laugh and tell Jeffrey, 'you've got the life.’ mci 7 Evuthre AGREN TO ERIN

Case 18-2868, Document 286, 08/09/2019, 2628248, Page41 of 55 Ghislaine took nude picture of me lying naked in a hammock, posed with my legs open, a bit provocatively that I gave to Jeffrey for his birthday. 7 The hammock photo was "all over the houses" and Bill Clinton and Andrew “had to have seen" ~ it. JS I spent four years as millionaire's personal masseuse. I was living on the streets, beaten up and slept with at least two older men in return for food. While on the streets, I slept with men for money. J Iwasa paedophile’s dream. V Three years later she was reunited with her family. J After about two years, he started to ask me to ‘entertain’ his friends. She recalls he said “I’ve got a good friend and I need you to fly to the island to entertain him, massage him and make him feel how you make me feel.” The way it usually worked was I'd been sent to meet a man on the private island Jeffrey owned in the Caribbean, or at his ranch in New Mexico, which was really isolated. I met famous friends of his such as Al Gore and Heidi Klum and Naomi Campbell. She was, she says, delighted when Epstein invited her to accompany him on a six-week trip in 2001. FBI told me that Epstein had hidden cameras watching me the entire time even when I was in the bathroom. I was so embarrassed. The FBI told me everything he did was illegal because I was under age.

Case 18-2868, Document 286, 08/09/2019, 2628248, Page42 of 55 J Virginia got a part-time job as a changing room assistant. I told Ghislaine I wanted to become a masseuse and she said she worked for a very wealthy gentleman who was looking for a traveling masseuse. I’d get training and be paid well. - Another lady led me into Jeffrey's bedroom. The lady walked me straight through into the i massage room. Afterwards, she was given two $100 bills and told to return the next day. That was the beginning if of the four years she spent with Epstein. / Radar Online has obtained exclusive "Diary entries" of "Teen Sex Slave". I led Prince Andrew into the upstairs bathroom next to the room I was staying in. I was doing my best trying to put on a good show for him by slowly undressing and started to pour a bath. He was caressing every part of my naked body and filling my head with endless compliments about my blossoming figure. He paid careful attention to my toes and was licking them. | I also saw Prince Andrew at the Ranch in New Mexico.

Case 18-2868, Document 286, 08/09/2019, 2628248, Page43 of 55 EXHIBIT QQ

Fram: Vigna Glut cee eS WEB GTS! BE “dBlo9/2019, 2628248, Paged4 of 55 Sent: Fri 5/20/2011 2:20:09 AM Importance: Normal Subject: How ya doing?? Received: Fri 5/20/2011 2:20:09 AM Hi Buddy, T hope you are stopping to smell the daffodils once in a while and having a good day!! Iam so excited today because I ca go sign with an agent as my contract is finished with "Mail On Sunday"... YEAH!! Sandra and I have been working really hard to get me ready for my trip to the U.S in a few weeks and I was wondering if I could use your advice again. She has got an INT'L agent who is interested in speaking with me and I don't want to say "Yes" to the first bite because I'm not su what to look for in an agent. What could you recommend that I do? I will send Jarred and Irene (your recommended agen a copy of the synopsis and sample chapters but how do I choose the right one for "The Story"? Do you know anyone else that might be interested in this as well? If so, i am keen on speaking with anyone who might be. I am soooooo000 excited about this and will keep you updated with the progressing events. When I am in New York we have to meet up for some city shopping and take the kids to Central Park to see the Zoo, given there will be no masturbating kangaroo's for you to make friends with, but who know's? I am looking forward to showing Robbie around and he's got some family out there < well we have to catch up with. Such busy times, but I'm loving it!! Anyways I hope your taking care and catch me up on your fun times!! Take care, Jenna CONFIDENTIAL GIUFFRE003959

Case 18-2868, Document 286, 08/09/2019, 2628248, Page45 of 55 EXHIBIT RR

Case 184gKen (Rlande,Coust Repgrting & Video, Tagea6 of 55 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS CONFIDENTIAL VIDEOTAPED DEPOSITION OF VIRGINIA GIUFFRE May 3, 2016 VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. APPEARANCES: FAMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. By Brad Edwards, Esq. 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954.524.2820 brad@pathtojustice.com Appearing on behalf of the Plaintiff BOIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. (For Portion) 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301-2211 Phone: 954.356.0011 smccawley@bsfllp.com Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE 5/3/2016

Case 184gKen (Rlande,Coust Repgrting & Video, Fagea7 of 55 APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura A. Menninger, Esq. 10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 imenninger@hmflaw.com jpagliuca@hmflaw.com Appearing on behalf of the Defendant Also Present: Brenda Rodriguez, Paralegal Nicholas F. Borgia, CLVS Videographer VIRGINIA GIUFFRE 5/3/2016

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 184gKen (Rlande,Coust Repgrting & Video, Fageas of 55 Pursuant to Notice and the Federal Rules of Civil Procedure, the VIDEOTAPED DEPOSITION OF VIRGINIA GIUFFRE, called by Defendant, was taken on Tuesday, May 3, 2016, commencing at 9:00 a.m., at 150 East 10th Avenue, Denver, Colorado, before Kelly A. Mackereth, Certified Shorthand Reporter, Registered Professional Reporter, Certified Realtime Reporter and Notary Public within Colorado. EXAMINATION PAGE MS. MENNINGER 8 PRODUCTION REQUEST (S): (None.) VIRGINIA GIUFFRE 5/3/2016

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 1849Ken (Rlande,Coust Repgrting & Video, Tagea9 of 55 DESCRIPTION INDEX OF EXHIBITS INITIAL REFERENCE Complaint and Demand for Jury Ly Trial re Jane Doe No. 102 v. Jeffrey Epstein Jane Doe #3 and Jane Doe #4's 21 Motion Pursuant to Rule 21 for Joinder in Action Declaration of Virginia L. 23 Giuffre re Jane Doe #1 and Jane Doe #2 vs. United States of America Declaration of Jane Doe 3 re 31 Jane Doe #1 and Jane Doe #2 vs. United States of America Declaration of Virginia Giuffre 33 re Bradley J. Edwards and Paul G. Cassell vs. Alan M. Dershowitz FBI documentation, date of entry 36 1/9743 Document titled Telecon, 39 Participants Jack Scarola, Brad Edwards, Virginia Roberts. Re Edwards adv. Epstein, 4/7/11, (23 pages of transcription) The Billionaire's Playboy Club, 41 By Virginia Roberts Plaintiff's Response and 44 Objections to Defendant's First Set of Discovery Requests to Plaintiff re Giuffre v. Maxwell VIRGINIA GIUFFRE 5/3/2016

10 11 12 13 14 15 16 a? 18 19 20 21 22 23 24 25 Case 184gKen (Rlande Coust Repgrting & Video, Fageso of 55 uv @ n a ys) G to 4 H 9 Z INITIAL REFERENCE Plaintiff's Supplemental 46 Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff Undated Declaration of Virginia 46 Giuffre re Plaintiff's Supplemental Response and Objections to Defendant's First Set of Discovery Requests served on March 22, 2016 Plaintiff's Second Amended 47 Supplemental Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff Mrs. Virginia Giuffre resume 67 Compilation of e-mails re Open 68 Position - Virginia Giuffre Virginia Lee Roberts passport 180 application Composite of e-mail strings 251 Compilation of e-mails between 259 Giuffre and Silva and others Compilation of e-mails between 265 Virginia Giuffre and Sandra White Compilation of e-mails between 269 Marianne Strong and Virginia Giuffre Compilation of e-mails between 276 Virginia Roberts and Jason Richards VIRGINIA GIUFFRE 5/3/2016

10 11 12 13 14 5 16 ay 18 19 20 21 22 23 24 25 Case 1849Ken (RlandeCoust Repgrting & Video, Tages of 55 DESCRIPTION INITIAL REFERENCE Compilation of e-mails between 284 Sharon Churcher and Virginia Giuffre Compilation of e-mails among 287 Sharon Churcher, Michael Thomas, Virginia Giuffre and others Compilation of May 2011 e-mails 288 among Sharon Churcher, Virginia Giuffre, Paulo Silva and others Compilation of June 2011 e-mails 289 between Virginia Giuffre and Sharon Churcher PR Hub Statement on Behalf of 300 Ghislaine Maxwell article 1/2/15 e-mail from Ross Gow to 309 To Whom It May Concern VIRGINIA GIUFFRE 5/3/2016

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 1849Ken (RlandeCoust Repgrting & Video, Tages? of 55 Some names have been changed in order to protect other people. Q (BY MS. MENNINGER) Protect their privacy? A Protect their privacy, yeah, I would say, just not getting them involved in, if this were to ever go public. QO Well, again, without rereading the whole manuscript -—-— A Reading it, yeah. I'm trying to see if I can -- see something in here. QO Let me narrow my question and maybe that will help. A Yes. QO Is there anything -- well, first of all, did you author that entire manuscript? A Yes, I. did. Q Did anyone else author part of that manuscript? A Do you mean did anyone else write this with me? Q Right. A No. Q That's all your writing? A This is my writing. QO Okay. To the best of your recollection, VIRGINIA GIUFFRE 5/3/2016 42

10 11 12 13 14 15 16 a? 18 19 20 21 22 23 24 25 Case 184gKen (Rlande,Coust Repgrting & Video, Fages3 of 55 as you sit here right now, is there anything in that manuscript about Ghislaine Maxwell that is untrue? A I don't believe so. Like I said, there is a lot of stuff that I actually have left out of here. Q Um-hum. A So there is a lot more information I could put in there. But as far as Ghislaine Maxwell goes, I would like to say that there is 99.9 percent of it would be to the correct knowledge. Q All right. Is there anything that you -and I understand you're doing this from memory. Es. there anything that you recall, as you're sitting here today, about Ghislaine Maxwell that is contained in that manuscript, that is not true? A You know, I haven't read this in a very long time. I don't believe that there's anything in here about Ghislaine Maxwell that is not true. MR. EDWARDS: I'd just ask, Counsel, if you have anything specific to show her about Ghislaine Maxwell -MS. MENNINGER: I'll ask questions. MR. EDWARDS: -- I'll have her look at it. MS. MENNINGER: I'll ask questions. MR. EDWARDS: I know, but I want the record clear that if she hasn't read it in a long VIRGINIA GIUFFRE 5/3/2016 43

10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 184gKen (Rlande,Coust Repgrting & Video, Tages of 55 I, VIRGINIA GIUFFRE, do hereby certify that I have read the foregoing transcript and that the same and accompanying amendment sheets, if any, constitute a true and complete record of my testimony. Signature of Deponent ( ) No Amendments (_) Amendments Attached Acknowledged before me this day of ¢ BOLE. Notary Public: Address: My commission expires Seal: KAM VIRGINIA GIUFFRE 5/3/2016 344

10 11 12 13 14 15 16 a? 18 19 20 21 22 23 24 25 Case 194gren Blande,Coust Reporting & Video, Tagess of 55 STATE OF COLORADO) ) ss. REPORTER'S CERTIFICATE COUNTY OF DENVER ) I, Kelly A. Mackereth, do hereby certify that I am a Registered Professional Reporter and Notary Public within the State of Colorado; that previous to the commencement of the examination, the deponent was duly sworn to testify to the truth. I further certify that this deposition was taken in shorthand by me at the time and place herein set forth, that it was thereafter reduced to typewritten form, and that the foregoing constitutes a true and correct transcript. I further certify that I am not related to, employed by, nor of counsel for any of the parties or attorneys herein, nor otherwise interested in the result of the within action. In witness whereof, I have affixed my signature this 11th day of May, 2016. My commission expires April 21, 2019. Kelly A. Mackereth, CRR, RPR, CSR 216 - 16th Street, Suite 600 Denver, Colorado 80202 VIRGINIA GIUFFRE 5/3/2016 345

Case 18-2868, Document 280, 08/09/2019, 2628232, Pagel of 74 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT Sigrid McCawley BOIES, SCHILLER & FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011

Case 18-2868, Document 280, 08/09/2019, 2628232, Page2 of 74 TABLE OF CONTENTS Page I. -—- PRELIMINARY STATEMENT ......-scccossscsssssssssssseessssssnnsssssnsssssnunsssnnassssnnnssseeennssee 1 Th, AUNDISPUTEIS PACTS isi oie descscctvasitind aviciieicecsloste in ceccbevtvernciniieentees 4 A. It is an Undisputed Fact That Multiple Witnesses Deposed in This Case Have Testified That Defendant Operated as Convicted Pedophile Jeffrey Epstein’s Procuter of Undetage Girls. ssccansisccsiscctemnianvinnncciecie nin nsinsnisnsteanst 4 1; It is an undisputed fact that Joanna Sjoberg testified Defendant lured her from her school to have sex with Epstein under the guise of hiring her for a job answering phones... It is an undisputed fact that Tony Figueroa testified that Defendant would call him to bring over underage girls and that Defendant and Epstein would have threesomes with Ms. Giuffie..........ccceseeeeeeeseeeeeeeee 6 It is an undisputed fact that Rinaldo Rizzo testified that Defendant took the passport of a 15-year-old Swedish girl and threatened her when she refused to have sex with Epstein. 0.00.00... ccc 8 It is an undisputed fact that Lyn Miller testified that she believed Defendant became Ms. Giuffre’s “new mama’’.......0...ccceeceeeeeeeeeeee It is an undisputed Fact that Detective Joseph Recarey testified that he sought to investigate Defendant in relation to his investigation of Jeffrey: Epstein sssiccscsisivvestvsstaszeter cote sata usauvsacssiecsscnersseaveaaviesbiniosavtecstasnaneiie 9 It is an undisputed fact that Pilot David Rodgers testified that he flew Defendant and Ms. Giuffre at least 23 times on Epstein’s jet, the “Lolita Express” and that “GM” on the flight logs Stands for Ghislaine It is an undisputed fact that Sarah Kellen, Nadia Marcinkova, and Jeffrey Epstein invoked the fifth amendment when asked about Defendant trafficking girls for Jeffery Epstein... LO It is an undisputed fact that Juan Alessi testified that Defendant was one of the people who procured some of the over 100 girls he witnessed visit Epstein, and that he had to clean Defendant’s sex toys. ...11 It is an undisputed fact that Defendant is unable to garner a single witness throughout discovery who can testify that she did not act as the procurer of underage girls and young women for Jeffrey Epstein. ........... 12

Case 18-2868, Document 280, 08/09/2019, 2628232, Page3 of 74 B. Documentary Evidence also Shows that Defendant Trafficked Ms. Giuffre and Procured her for Sex with Convicted Pedophile Jeffrey Epstein while She Was Mn ea BC ics ctssscvevensosscacevacwsvegtanve stuns sivasadcussuvesers hems sucecsescasetgnthiunnsesibitacsteoiseigatote 12 aes The Plight Lo gS: sscciccisieinin sestvicccstecssveciantennsviconievecivin tonivan cite ccccecioneneanis 12 2. The Photographs si<iiccanunncnccnacnnaninncntacnonnndanciimanaden 13 3. The Victim Identification Letter.....0..0.ccccsceseeeesessessesteseeseeseeseeeeeeeseeseenee 15 4. New York Presbyterian Hospital Records........c..cccssseseseseeeseeseeeseeeeeeeee 15 5: Judith Lightfoot Psychological Records.........ccceeseseeseseseseeseseeeeneseseeeeeee 16 6. Message Padgissssisccvisccissvsssstssssvassssetecaiseanvestsnatenitvascsustaapnvsatbaasvvestcoceuaaenvs 17 h THe Blache Boos <csccc.sctsssssswvissassasevensessisyynsttvsnsensenceacesnasvdaviasstuaasesieeeetstennt’ 22 8. Sex Slave Amazon.com Book Receipt 9. Thailand Folder with Defendant’s Phone Numbet..............:csessesseeeee 24 10. It is undisputed fact that the FBI report and the Churcher emails reference Ms. Giuffre’s accounts of sexual activity with Prince Andrew that she made in 2011, contrary to Defendant’s argument that Ms. Giuffre never made such claims until 2014. Cc. Defendant Has Produced No Documents Whatsoever That Tend to Show That She Did Not Procure Underage Girls For Jeffrey Epstein.........cceeeeeeeeeeeees 26 Ill. LEGAL STANDARD sis casassvcsssiciitsinindssvcassvesesicielstadsesseosebacvnsics daseasasessasssuaasaadsaaiinatessose 27 Iv. LEGAL ARGUMENT siiisiniesasictcrscsraneinnecininvicnianianiveniicitnninmnina niacin 27 A. Defendant is Liable for the Publication of the Defamatory Statement and Datnages for Its Publicationy..ccasissssisesenscessscsrseniiven stesciveconciamnimnnncin Hevivecnieets 27 le Under New York Law, Defendant is liable for the media’s publication of her press release. .... 2, Defendant is liable for the media’s publication of the defamatory SEALSENGIIL sis dees secs ed Sevsse cseteventas int vct edit saat tablatacchonstsd ps tensapanelececeseaterieed So B. Material Issues of Fact Preclude Summary Judgment... cesses G4 1. The Barden Declaration presents disputed issues of fact. .........0ceeeee 34

VI. VIL. VIII. Case 18-2868, Document 280, 08/09/2019, 2628232, Page4 of 74 a. The Barden Declaration is a deceptive back-door attempt to inject Barden’s advice without providing discovery of all attorney communications. db. Defendant’s summary judgment argument requires factual findings regarding Barden’s intent, thereby precluding SUMMALY JUUQIMENL: sisi ccescccrsisressvivensvicnetecirciensavivesesisecrercemeneene 35 c. There are factual disputes regarding Barden’s Declaration........... 36 Cc. Defendant’s Defamatory Statement Was Not Opinion as a Matter of Law. ......... 38 Dz. The Pre-Litigation Privilege Does Not Apply to Defendant’s Press Release....... 40 a Defendant fails to make a showing that the pre-litigation privilege applies. 2, Defendant is foreclosed from using the pre-litigation privilege because she acted with malice 3 Defendant cannot invoke the pre-litigation privilege because she has no “meritorious claim” for “good faith” litigation. «2.0.0.0... 46 DEFENDANT HAS NOT - AND CANNOT - SHOW THAT HER DEFAMATORY STATEMENT IS SUBSTANTIALLY TRUE.........cssssssssssssssssssssssssssssosssssssscsseevesssssssoses 47 PLAINTIFF DOES NOT NEED TO ESTABLISH MALICE FOR HER DEFAMATION CLAIM, BUT IN THE EVENT THE COURT RULES OTHERWISE, THERE IS MORE THAN SUFFICIENT RECORD EVIDENCE FOR A REASONABLE JURY TO DETERMINE DEFENDANT ACTED WITH PACTUAL MALICE S csssssssststicsnssscslecsussssastvsouassasissonesoavevebnatssensencetesoncaanpanieosasasessesetatayeis 49 THE COURT NEED NOT REACH THE ISSUE, AT THIS TIME, OF WHETHER MS. GIUFFRE IS A LIMITED PURPOSE PUBLIC FIGURE............ccseseeeeeeeee DL THE JANUARY 2015 STATEMENT WAS NOT “SUBSTANTIALLY TRUE,” AND MS. GIUFFRE HAS PRODUCED CLEAR AND CONVINCING EVIDENCE TUS RAMS UY 2522 cet caved caeais ss ins tee aehasvinsatssaas tases pepesavapcanaaastsacthseendaviapaatesaisasieeate viper 55 A. When Ms. Giuffre Initially Described Her Encounters With Defendant and Epstein, She Mistakenly Believed the First Encounter Occurred During the MCAT 1909 i sassssecsteeneaeaninietanes vervstonsinee a B. Defendant’s January 2015 Statement Claiming as “Untrue” and an “Obvious Lie” the Allegation That She Regularly Participated in Epstein’s Sexual Exploitation of Minors and That the Government Knows Such Fact is Not Substantially True But Instead Completely False. . iii

Ix. Case 18-2868, Document 280, 08/09/2019, 2628232, Paged of 74 Cc. Defendant’s January 2015 Statement Claiming as “Untrue” or an “Obvious Lie” That Maxwell and Epstein Converted Ms. Giuffre Into a Sexual Slave is Not Substantially True. Dz. Any Statement of Misdirection Regarding Professor Alan Dershowitz is Nothing More Than an Irrelevant Distraction to The Facts of This Case and Matters Not on the Defense of Whether Defendant’s Statement Was Substantially True ss sicscsscisrrmnnanincncnannniennetintarannnnincniananen OL E. Contrary to Defendant’s Position, There is a Genuine Issue of Material Fact as to Whether She Created or Distributed Child emhiue or Whether the Government Was Aware of Same. . oecesbes iiinensevacneevievoeigeanas OD F. Defendant Did Act as a “Madame” For Epstein to Traffic Ms. Giuffre to The RiGhi and Famous, .cvesncaciiccsvesiarvstvvnssivacitocssenteevevewvenssieesacesedeccttevssecuseseccessansssvivnn OS

Case 18-2868, Document 280, 08/09/2019, 2628232, Page6 of 74 TABLE OF AUTHORITIES Page Cases Baiul v. Disson, GOT FF Apap! 18, (Od Cie 2015) ssa cacensncvsccgnusvnteracdcevenctvoiseassinsovandusaovesvov usin sosibdesvarst asians 50 Black v. Green Harbour Homeowners’ Ass'n, Inc., 19:A;D.3d:962, 798 N.Y.S:2d 753 (2005) vsisvsssirsesissccccsnstesecveavvvenvsasesssvcvseventavivess dinsceneremanesnnse 43 Block v. First Blood Associates, 691 F. Supp. 685 (Sweet, J.) (S.D.N.Y. 1988) c.essssscsssssssssscssssssssessesessssseseeesnesseseseeee 41, 42, 43 Brady v. Town of Colchester, BOSE 20205: (Qdi Cite TOSS) acciscsassscctaectaseseseteseabenstreadesaasstatsiaatntelsiidans asadhondtanieaaniatn atest 27 Chambers v. TRM Copy Ctrs. Corp. 43 F.3d 29 (2d Cir. 1994) Contemporary Mission, Inc. v. N.Y. Times Co 842 F.2d 612 (2d Cir. 1988) Da Silva v. Time Inc., 908 F. Supp. 184 (S.D.N.Y. 1995) vacccssssssscssssssssssccssssssscscesessssseeecessnssseeseesunsseseseeusessseeseeees 47 Davis v. Costa-Gavras, 580 F. Supp. 1082 (S.D.N.Y. 1984). De Sole v. Knoedler Gallery, LLC, 139 F, Supp. 3d 618 (S.D.N.Y. 2015) ccssssssscssssssscssccsssssssesecsssssssesseussssssseseesassssseesessasessseeeeee5O Eliah v. Ucatan Corp., A533, Supp: 309: CW DN: YA977) sacsssssisssossssossacacassstssssessvssvnicqstasinesbacvasssonincciasssseCetpens 29 Flomenhaft v. Finkelstein, 127 A.D.3d 634, 8 N.Y.S.3d 161 (N.Y. App. Div. 2015) cccesssssssssssssssssessssssnsesseenssssenennseee 42 Frechtman v. Gutterman, 115 A.D.3d 102, 979 N.Y.S.2d 58: (2014). .csseccsssssscccsssssesssssscosasasoncavonsoossnsansavasssenaasonesessssansasees 42 Friedman v. Meyers, ASD B2d'435 (Od Cite L973 sas sssicanscocdassasssaesss sasasnsaxaasuabieavesssfosibaseiessua aaistoiodessspapsancsaaaviasisessnis 36 Front v. Khalil, 24.N.Y.3d 713 (2015)..

Case 18-2868, Document 280, 08/09/2019, 2628232, Page7 of 74 Gerts v. Robert Welch, In 418 U.S. 323 (1974)... Giuffre v. Maxwell, 165'F.Supp:-3d 147 (S.DIN-Y< 2016) s scccisssssesvsesteacecseesnstsconstverveseresccvonavens tessvveyavicovcenensy passim Greenberg v. CBS Inc., 69'A.Di2d:693;419 N-YS,20 988 (1979) csisnsstricinssecssverintinsrvacenstvecineneunivnnitereccecenneneanne 54 Harte-Hanks Comme'ns, Inc. v. Connaughton, 491 U.S. 657, 109 S. Ct. 2678, 105 L. Ed. 2d 562 (1989) on. ceecsscsesecsssesessessseceescseeeeneseseesenee 49 HB v. Monroe Woodbury Cent. School Dist., 2012 WL 4477552. (S:ID.NLY. Sept. 27,2012) \sccisiccsesseteastssasssssseseccnoaecsessabasesossnsdvensvoaszssserbessss 34 Herbert v. Lando, 596 F. Supp. 1178 (S.D.N.Y. 1984) c.esscsssssccsssssssssccssssssscssceesssssceecesssseseseceuaseseesscennessseeeeeee 51 Hutchinson v. Proxmire, 443 U.S. 111, 99 S. Ct. 2675, 61 L.Ed.2d 411 (1979) ..cessesessssssssessecssssssesssssssssssssseresssessessee OS In re “Agent Orange” Prod. Liab. Litig. 517 F.3d 76 (2d Cir. 2008)........... Karaduman v. Newsday, Inc., AVG INBi2d $57! (1980) ees ccsssnninissceesadinsscovsuansbnisbicdesiechobtaguavistsbarcssieartbuoeinssdbuneasciociigi GL Kirk v. Heppt, 532 F. Supp. 2d 586 (S.D.N.Y, 2008) .cssscsscssssssssssccsssssssessessssssecescessnssseeseessnseseeseeenesesecseees 42 Lerman vy. Flynt Distrib. Co., 745 F.2d 123 (2d Cir. 1984).. Levy v. Smith, 18 NLY.S 34.438 (NLY.A.D. 2 Dept. 2015) sscccissssscccsosssssssssscasssssescavosssosssssnsavasssenzanonesedsssasosooes 28 Lopez v. Univision Communications, Inc., 45 F. Supp.2d 348 (S.D.N.Y. 1999)... Mitre Sports Int’! Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240 (S.D.N.Y. 2014)....... National Puerto Rican Day Parade, Inc. v. Casa Publications, Inc., 914.N.Y.S.2d 120, 79 A.D.3d 592 (N.Y.A.D. 1 Dept. 2010) Nehls v. Hillsdale Coll., 178 F. Supp. 2d 771 (B.D. Mich. 2001) ...sssssssssssssssssssssssssessssssssssstsssssesssssssssssssssssassesseseene SL vi

Case 18-2868, Document 280, 08/09/2019, 2628232, Page8 of 74 Net Jets Aviation, Inc. vy. LHC Commce’ns, LLC, 537 F.3d 168 (2d Cir. 2008) New York Times Co. v. Sullivan, 376 U.S. 254, 84S. Ct. 710, 11 L.Ed.2d 686 (1964) oo. eecesecessesesesessesesesesecesseseeceneseseesens 50 Pacenza v. IBM Corp., 363.0, Agppix 128 (2d Cite 2010) a cacessessoscnesvinncasdvavtonevonigei volaadenctionssovsinenedtboonarnncmides 34 Patrick y. Le Fevre, TAS 2G 153: (Qi Cit VOSA) yt b0, eds ssoacerapaasesatesesaabeaareadeasaateanerrtacresamtanasadabonauanicaisireanat erie 36 Petrus v Smith, 91 AD 2d! 1190: GN LY ACD: W983) iiss. accssatssodssssensavessseniteasassedancasasencncde cata cabatedoassiasesevnazeasoesbeasedd 42 Philadelphia Newspapers, Inc. v. Hepp. 475 U.S. 767 (1986)... Rand v. New York Times Co., 430 N.Y.S.2d 271, 75 A.D.2d:417 (N.Y.A.D. 1980)......ccccsssssesssccnosesseseseassessessavenesoassssseasesones 32: Rubens vy. Mason, B87 BS! 183 (2d Cit: 2004) cs sassicasssesss cssecssstnesvsvstasanssevsssecedonnvstvsscssasassssssensseabvesissieabiendecesogionnty 35 Sexter & Warmflash, P.C. v. Margrabe, 38 A.D.3d 163 (N.Y.A.D. 1 Dept. 2007) -ssccsesssssssscsssssssssscessssssesscessnssseeseessnssseesscenesesesseeee 42 Stern v. Cosby, 645 F. Supp. 2d 258 (S.D.N.Y, 2009) vcesscssccsssssssssscssssssseesesssssssessssessssssesseussnssssessersnsesne27, 47 Swan Brewery Co. Ltd. y. U.S. Trust Co. of New Yor 832 F. Supp. 714 (S.D.N.Y. 1993) Rules Fed. R. Civ. P. 56. Other Authorities Merriam-Webster (11"" ed. 2006) RESTATEMENT (SECOND) OF TorTs § 576 (1977) .. SACK ON DEFAMATION § 2.7.2 at 2-113 to 2-114 (4th ed. 2016) vii

Case 18-2868, Document 280, 08/09/2019, 2628232, Page9 of 74 I. PRELIMINARY STATEMENT There can be no question that disputed issues of material facts preclude granting summary judgment when, in a one-count defamation case, Defendant presents the Court with a 68-page memorandum of law, a 16-page statement of purported facts, and approximately 700 pages of exhibits. The sheer scope of Defendant’s response, if anything, conclusively demonstrates that volumes of disputed facts surround the core question of whether Defendant abused Ms. Giuffre. Indeed, Defendant acknowledges a dispute between the parties as to whether she abused Ms. Giuffre. See, e.g., Motion for Summary Judgment at 1; Motion to Dismiss at 1. This Court already said that this disputed factual question is central to this case: Either Plaintiff is telling the truth about her story and Defendant’s involvement, or defendant is telling the truth and she was not involved in the trafficking and ultimate abuse of Plaintiff. The answer depends on facts. Defendant’s statements are therefore actionable as defamation. Whether they ultimately prove to meet the standards of defamation (including but not limited to falsity) is a matter for the fact-finder. Order Denying Defendant’s Motion to Dismiss at 10. While this fact remains in dispute, summary judgment is foreclosed. But even turning to Defendant’s claims, the avalanche of aspersions she casts upon Ms. Giuffre and her counsel should not distract the Court from the fact that the instant motion cannot come within sight of meeting the standard for an award of summary judgment. The most glaring and emblematic example of the Defendant’s far-fetched claims appears in her attempt to move away from her defamatory statement by arguing that it was her attorney and not her, who issued the defamatory statement for the press to publish, though she is forced to admit the statement was made on her behalf. This is an untenable position to take at trial, and an impossible argument to advance at the summary judgment stage, as both the testamentary and documentary evidence positively refute that argument. Defendant incorrectly asks this Court to make a factual

Case 18-2868, Document 280, 08/09/2019, 2628232, Page10 of 74 finding that her defamatory press release was actually a legal opinion, issued not by her, but by her lawyer, to the media, despite documentary evidence showing otherwise. Defendant also argues that she has proven the truth of her statement calling Ms. Giuffre a liar with respect to the statements Ms. Giuffre made about Defendant. To the contrary, voluminous evidence, both documentary and testimonial from numerous witnesses, corroborate Ms. Giuffre’s account of Defendant’s involvement in the sexual abuse and trafficking of Ms. Giuffre. Just to briefly highlight a few, Johanna Sjoberg, testified that Defendant recruited her under the guise of a legitimate assistant position, but asked her to perform sexual massages for Epstein, and punished her when she didn’t cause Epstein to orgasm.' Tony Figueroa testified that Defendant contacted him to recruit high school-aged girls for Epstein, and also testified that Maxwell and Epstein participated in multiple threesomes with Virginia Giuffre. Even more shockingly, the butler for Defendant’s close friend witnessed, first-hand, a fifteen-year-old Swedish girl crying and shaking because Defendant was attempting to force her to have sex with Epstein and she refused. This is a fraction of the testimony that will be elicited at trial about Defendant’s involvement in the sexual abuse and trafficking of Ms. Giuffre. Defendant’s primary argument in support of her contention that she did not abuse and traffic Ms. Giuffre as a minor child is that employment records show that Ms. Giuffre was either sixteen or seventeen when Defendant recruited her from her job at Mar-a-Lago for sex with Epstein, not fifteen-years-old as Plaintiff originally thought. Call this the “yes-I’m-a-sextrafficker-but-only-of-sixteen-year-old-girls” defense. Defendant does not explain why sexual abuse of a fifteen year old differs in any material way from sexual abuse of a sixteen or seventeen year old. All instances involve a minor child, who cannot consent, and who is 'See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr, at 8:5-10; 13:1-3; 12:17-14:3; 15:1-5; 32:9-16; 34:5-35:1; 36:2-1.

Case 18-2868, Document 280, 08/09/2019, 2628232, Page11 of 74 protected by federal and state laws. The fact remains that Defendant recruited Ms. Giuffre while she was a minor child for sexual purposes and then proceeded to take her all over the world on convicted pedophile Jeffrey Epstein’s private jet, the “Lolita Express,”” as well as to his various residences, and even to her own London house. Flight logs even reveal twenty-three flights that Defendant shared with Ms. Giuffre — although Defendant claims she is unable to remember even a single one of those flights. Inconsequential details that Ms. Giuffre may have originally remembered incorrectly do not render her substantive claims of abuse by Defendant false, much less deliberate “lies.” At most, these minor inaccuracies, in the context of a child suffering from a troubled childhood and sexual abuse, create nothing more than a fact question on whether Defendant’s statement that Ms. Giuffre lied when she accused Defendant of abuse is “substantially true,” thereby precluding summary judgment. See Mitre Sports Int’l Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240, 255 (S.D.N.Y. 2014) (“Because determining whether COI is substantially true would require this court to decide disputed facts ... summary judgment is not appropriate”). Defendant has tried to spin these inconsequential mistakes of memory into talismanic significance and evidence of some form of bad-faith litigation, but this claim fails under the weight of the evidence. As the Court knows, the clear weight of the evidence establishes Defendant’s heavy and extensive involvement in both Jeffrey Epstein’s sex trafficking ring and in recruiting Ms. Giuffre, living with her and Jeffrey Epstein in the same homes while Ms. Giuffre was a minor, and traveling with Ms. Giuffre and Jeffrey Epstein — including 23 documented flights. Even the house staff testified that Defendant and Ms. Giuffre were regularly * See, e.g.: “All aboard the ‘Lolita Express’: Flight logs reveal the many trips Bill Clinton and Alan Dershowitz took on pedophile Jeffrey Epstein’s private jet with anonymous women” at The Daily Mail, http://www.dailymail.co.uk/news/article-2922773/Newly-released-flight-logs-reveal-time-trips-Bill-ClintonHarvard-law-professor-A lan-Dershowitz-took-pedophile-Jeffrey-Epstein-s-Lolita-Express-private-jet-anonymouswomen.html.

Case 18-2868, Document 280, 08/09/2019, 2628232, Page12 of 74 together. See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 103:4-9 (“Q. After that day, do you recall that she started coming to the house more frequently. A. Yes, she did. Q. In fact, did she start coming to the house approximately three times a week? A. Yes, probably.”). It is also undisputed that witnesses deposed in this case have testified about Defendant’s role as a procurer of underage girls and young women for Jeffrey Epstein. At the very least, a trier of fact should determine whether the evidence establishes whether or not Ms. Giuffre’s claims of Defendant being involved in her trafficking and abuse are true. Defendant’s summary judgment motion should be denied in its entirety. Il. UNDISPUTED FACTS The record evidence in this case shows that Defendant shared a household with convicted pedophile Jeffrey Epstein for many years. While there, she actively took part in recruiting underage girls and young women for sex with Epstein, as well as scheduling the girls to come over, and maintaining a list of the girls and their phone numbers. Ms. Giuffre was indisputably a minor when Defendant recruited her to have sex with convicted pedophile Jeffrey Epstein. Thereafter, Ms. Giuffre flew on Epstein’s private jets — the — Lolita Express” — with Defendant at least 23 times. A. It is an Undisputed Fact That Multiple Witnesses Deposed in This Case Have Testified That Defendant Operated as Convicted Pedophile Jeffrey Epstein’s Procurer of Underage Girls. 1. It is an undisputed fact that Joanna Sjoberg testified Defendant lured her from her school to have sex with Epstein under the guise of hiring her for a job answering phones. Ms. Sjoberg’s account of her experiences with Defendant are chillingly similar. As with Ms. Giuffre, Defendant, a perfect stranger, approached Ms. Sjoberg while trolling Ms. Sjoberg’s school grounds. She lured Ms. Sjoberg into her and Epstein’s home under the guise of a legitimate job of answering phones, a pretext that lasted only a day. A young college student, 4

Case 18-2868, Document 280, 08/09/2019, 2628232, Page13 of 74 nearly 2,000 miles from home, Defendant soon instructed Ms. Sjoberg to massage Epstein, and made it clear that Sjoberg’s purpose was to bring Epstein to orgasm during these massages so that Defendant did not have to do it. Q. And when did you first meet Ms. Maxwell? A. 2001. March probably. End of February/beginning of March. Q. And how did you meet her? A. She approached me while I was on campus at Palm Beach Atlantic College. eR Q. And how long did you work in that position answering phones and doing -A. Just that one day. eR Q. And what happened that second time you came to the house? A. At that point, I met Emmy Taylor, and she took me up to Jeffrey’s bathroom and he was present. And her and I both massaged Jeffrey. She was showing me how to massage. And then she -- he took -- he got off the table, she got on the table. She took off her clothes, got on the table, and then he was showing me moves that he liked. And then I took my clothes off. They asked me to get on the table so I could feel it. Then they both massaged me. 2 Q. Who did Emmy work for? 2 A. Ghislaine. 3 Q. Did Maxwell ever refer to Emmy by any particular term? 5 A. She called her her slave. RE Q. Did Jeffrey ever tell you why he received so many massages from so many different girls? A. He explained to me that, in his opinion, he needed to have three orgasms a day. It was biological, like eating. eR Q. Was there anything you were supposed to do in order to get the camera? THE WITNESS: I did not know that there were expectations of me to get the camera until after. She [Defendant] had purchased the camera for me, and I was over there giving Jeffrey a massage. I did not know that she was in possession of the camera until later. She told me -called me after I had left and said, I have the camera for you, but you cannot receive it yet because you came here and didn’t finish your job and I had to finish it for you. Q. And did you -- what did you understand her to mean? A. She was implying that I did not get Jeffrey off, and so she had to do it. Q. And when you say “get Jeffrey off,” do you mean bring him to orgasm? A. Yes. eR Q. Based on what you knew, did Maxwell know that the type of massages Jeffrey was getting typically involved sexual acts? THE WITNESS: Yes. Q. What was Maxwell’s main job with respect to Jeffrey?

Case 18-2868, Document 280, 08/09/2019, 2628232, Page14 of 74 THE WITNESS: Well, beyond companionship, her job, as it related to me, was to find other girls that would perform massages for him and herself. Ms. Sjoberg also testified about sexual acts that occurred with her, Prince Andrew, and Ms. Giuffre, when she and Defendant were staying at Epstein’s Manhattan mansion: Q. Tell me how it came to be that there was a picture taken. THE WITNESS: I just remember someone suggesting a photo, and they told us to go get on the couch. And so Andrew and Virginia sat on the couch, and they put the puppet, the puppet on her lap. And so then I sat on Andrew’s lap, and I believe on my own volition, and they took the puppet’s hands and put it on Virginia’s breast, and so Andrew put his on mine.* Ms. Sjoberg’s testimony corroborates Ms. Giuffre’s account of how Defendant recruited her (and others) under a ruse of a legitimate job in order to bring them into the household to have sex with Epstein. Ms. Sjoberg’s testimony also corroborates Ms. Giuffre’s account of being lent out to Prince Andrew by Defendant, as even the interaction Ms. Sjoberg witnessed included a sexual act: Prince Andrew using a puppet to touch Ms. Giuffre’s breast while using a hand to touch Ms. Sjoberg’s breast. 2, It is an undisputed fact that Tony Figueroa testified that Defendant would call him to bring over underage girls and that Defendant and Epstein would have threesomes with Ms. Giuffre.” Tony Figueroa testified that Plaintiff told him about threesomes Ms. Giuffre had with Defendant and Epstein which included the use of strap-ons: Q. Okay. And tell me everything that you remember about what Ms. Roberts said about being intimate with Ms. Maxwell and Mr. Epstein at the same time. A. [remember her talking about, like, strap-ons and stuff like that. But, I mean, like I said, all the details are not really that clear. But I remember her talking about, like, how _ they would always be using and stuff like that. Q. She and Ms. Maxwell and Mr. Epstein would use strap-ons? A. Uh-huh (affirmative). ae 3 See MeCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 8:5-10; 13:1-3; 12:17-14:3; 15:1-5; 32:9-16; 34:5-35:1; 36:2-15. * See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 82:23-83:9. ° Defendant attempts to discredit Figueroa’s damaging testimony by repeatedly mentioning that he has been convicted for a drug-related offense. Unsurprisingly, in this attack, Defendant does not mention that she has a DUI conviction. See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 390:13-15. (April 22, 2016). 6

Case 18-2868, Document 280, 08/09/2019, 2628232, Page15 of 74 Q. Other than sex with the Prince, is there anyone else that Jeffrey wanted Ms. Roberts to have sex with that she relayed to you? A. Mainly, like I said, just Ms. Maxwell and all the other girls. Q. Ms. Maxwell wanted -- Jeffrey wanted Virginia to have sex with Ms. Maxwell? A. And him, yeah. Q. And did she tell you whether she had ever done that? A. Yeah. She said that she did. Bet Q. And what did she describe having happened? A. I believe I already told you that. With the strap-ons and dildos and everything.° on eeee—C™SC(‘(‘!CG Figueroa also testified that Defendant called him to ask if he had found any other girls for Epstein, thereby acting as procurer of girls for Epstein: Q. [W]hen Ghislaine Maxwell would call you during the time that you were living with Virginia, she would ask you what, specifically? A. Just if [had found any other girls just to bring to Jeffrey. Q. Okay. A. Pretty much every time there was a conversation with any of them, it was either asking Virginia where she was at, or asking her to get girls, or asking me to get girls. eR Q. Okay. Well, tell me. When did Ms. Maxwell ask you to bring a girl? A. Never in person. It was, like, literally, like, on the phone maybe, like, once or twice. Q All right. Did Ms. Maxwell call you frequently? A.No. Q. All right. How many times do you think Ms. Maxwell called you, at all? A. I'd just say that probably a just a few, a couple of times. Maybe once or twice. Q. One or two -A. The majority of the time it was pretty much his assistant. Q. How do you know Ms. Maxwell’s voice? A. Because she sounds British. Q. So someone with a British accent called you once or twice and asked for -A. Well, she told me who she was. Q. Okay. And what did she say when she called you and asked you to bring girls? A. She just said, “Hi. This is Ghislaine. Jeffrey was wondering if you had anybody that could come over.”* ® See McCawley Dec. at Exhibit 4, Figueroa June 24, 2016 Dep. Tr. Vol. 1 at 96-97 and 103. T See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 55:19-58:23 (July 22, 2016). * See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 200:6-18; 228:23-229:21. 7

Case 18-2868, Document 280, 08/09/2019, 2628232, Page16 of 74 3. It is an undisputed fact that Rinaldo Rizzo testified that Defendant took the passport of a 15-year-old Swedish girl and threatened her when she refused to have sex with Epstein. Rinaldo Rizzo was the house manager for one of Defendant’s close friends, Eva Dubin. Mr. Rizzo testified - through tears — how, while working at Dubin’s house, he observed Defendant bring a 15 year old Swedish girl to Dubin’s house. In distress, the 15 year old girl tearfully explained to him that Defendant tried to force her to have sex with Epstein through threats and stealing her passport: Q. How old was this girl? A. 15 years old. Ret Q. Describe for me what the girl looked like, including her demeanor and anything else you remember about her when she walks into the kitchen. A. Very attractive, beautiful young girl. Makeup, very put together, casual dress. But she seemed to be upset, maybe distraught, and she was shaking, and as she sat down, she sat down and sat in the stool exactly the way the girls that I mentioned to you sat at Jeffrey’s house, with no expression and with their head down. But we could tell that she was very nervous. Q. What do you mean by distraught and shaking, what do you mean by that? A. Shaking, I mean literally quivering. Bet Q. What did she say? A. She proceeds to tell my wife and I that, and this is not -- this is blurting out, not a conversation like I’m having a casual conversation. That quickly, I was on an island, I was on the island and there was Ghislaine, there was Sarah, she said they asked me for sex, I said no. And she is just rambling, and I’m like what, and she said -- I asked her, I said what? And she says yes, I was on the island, I don’t know how I got from the island to here. Last afternoon or in the afternoon I was on the island and now I’m here. And I said do you have a -- this is not making any sense to me, and I said this is nuts, do you have a passport, do you have a phone? And she says no, and she says Ghislaine took my passport. And I said what, and she says Sarah took her passport and her phone and gave it to Ghislaine Maxwell, and at that point she said that she was threatened. And I said threatened, she says yes, I was threatened by Ghislaine not to discuss this. And I’m just shocked. So the conversation, and she is just rambling on and on, again, like I said, how she got here, she doesn’t know how she got here. Again, I asked her, did you contact your parents and she says no. At that point, she says I’m not supposed to talk about this. I said, but I said: How did you get here. I don’t understand. We were totally lost for words. And she said that before she got there, she was threatened again by Jeffrey and Ghislaine not to talk about what I had mentioned earlier, about -- again, the word she used was sex. Q. And during this time that you’re saying she is rambling, is her demeanor continues to be what you described it?

Case 18-2868, Document 280, 08/09/2019, 2628232, Page17 of 74 A. Yes. Q. Was she in fear? A. Yes. Q. You could tell? A. Yes. A. She was shaking uncontrollably.” 4. It is an undisputed fact that Lyn Miller testified that she believed Defendant became Ms. Giuffre’s “new mama”. Lyn Miller is Ms. Giuffre’s mother. She testified that when Ms. Giuffre started living with Defendant, Defendant became Ms. Giuffre’s “new momma.”!° Incredulously, Defendant testified that she barely remembered Ms. Giuffre.'! 5. It is an undisputed Fact that Detective Joseph Recarey testified that he sought to investigate Defendant in relation to his investigation of Jeffrey Epstein. Detective Recarey led the Palm Beach Police’s investigation of Epstein. He testified that Defendant procured girls for Epstein, and that he sought to question her in relation to his investigation, but could not contact her due to the interference of Epstein’s lawyer: Q. A cross-reference of Jeffrey Epstein’s residence revealed which affiliated names? A. It revealed Nadia Marcinkova, Ghislane Maxwell, Mark Epstein. Also, the crossreference, any previous reports from the residence as well. Q. During your investigation, did you learn of any involvement that Nadia Marcinkova had with any of the activities you were investigating? cet Q. The other name that is on here as a cross-reference is Ghislane Maxwell. Did you speak with Ghislane Maxwell? A. I did not. Q. Did you ever attempt to speak with Ghislane Maxwell? A. I wanted to speak with everyone related to this home, including Ms. Maxwell. My contact was through Gus, Attorney Gus Fronstin, at the time, who initially had told me that he would make everyone available for an interview. And subsequent conversations later, no one was available for interview and everybody had an attorney, and I was not going to be able to speak with them. Q. Okay. During your investigation, what did you learn in terms of Ghislane Maxwell’s involvement, if any? ° See McCawley Dec. at Exhibit 14, Rinaldo Rizzo's June 10, 2016 Dep. Tr. at 52:6-7; 52:25-53:17; 55:23-58:5 ° See McCawley Dec. at Exhibit 12, Lynn Miller's May 24, 2016 Dep. Tr. at 115. "' See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 77:25-78:15 (April 22, 2016). 9

Case 18-2868, Document 280, 08/09/2019, 2628232, Page18 of 74 THE WITNESS: Ms. Maxwell, during her research, was found to be Epstein’s long-time friend. During the interviews, Ms. Maxwell was involved in seeking girls to perform massages and work at Epstein’s home.” 6. It is an undisputed fact that Pilot David Rodgers testified that he flew Defendant and Ms. Giuffre at least 23 times on Epstein’s jet, the “Lolita Express” and that “GM” on the flight logs Stands for Ghislaine Maxwell. Notably, at Defendant’s deposition, Defendant refused to admit that she flew with Ms. Giuffre, and denied that she appeared on Epstein’s pilot’s flight logs.'* However, David Rodgers, Epstein pilot, testified that the passenger listed on his flight logs bearing the initials - GM — was, in fact, Ghislaine Maxwell, and that he was the pilot on at least 23 flights in which Defendant flew with Plaintiff.'* The dates of those flights show that Ms. Giuffre was an underage child on many of them when she flew with Defendant. ° 7. It is an undisputed fact that Sarah Kellen, Nadia Marcinkova, and Jeffrey Epstein invoked the Fifth Amendment when asked about Defendant trafficking girls for Jeffery Epstein. Both Sarah Kellen and Nadia Marcinkova lived with Jeffrey Epstein for many years. They both invoked the Fifth Amendment when asked about Defendant’s participation in recruiting underage girls for sex with Epstein. Marcinkova testified as follows: Q. Did Ghislaine Maxwell work as a recruiter of young girls for Jeffrey Epstein when you met her? A. Same answer. [Invocation of Fifth Amendment] ke Q. Have you observed Ghislaine Maxwell and Jeffrey Epstein convert what started as a massage with these young girls into something sexual? A. Same answer.'® !? See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 27:10-17; 28:21-29:20. See McCawley Dec. at Exhibit 11, Maxwell’s April 22, 2016 Dep. Tr. at 78-79, 144. See McCawley Decl. at Exhibit 41, Rodgers Dep. Ex. 1, GIUFFRE 007055-007161 (flight records evidencing Defendant (GM) flying with Ms. Giuffre). 'S See McCawley Dec. at Exhibit 15, David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36; see also Exhibit 41, Rodgers Dep. Ex. | at flight #s 1433-1434, 1444-1446, 1464-1470, 1478-1480, 1490-1491, 1506, 1525-1526, 1528, 1570 and 1589. "© See McCawley Dec. at Exhibit 10, Marcinkova Dep. Tr. at 10:18-21; 10 2:11-15.

Case 18-2868, Document 280, 08/09/2019, 2628232, Page19 of 74 Kellen testified as follows: Q. Did Ghislaine Maxwell work as a recruiter for young girls for Jeffrey Epstein when you met her? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege . . . Bec Q. Isn’t it true that Ghislaine Maxwell would recruit underage girls for sex and sex acts with Jeffrey Epstein? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege . . _ Similarly, Jeffrey Epstein invoked the Fifth Amendment when asked about Defendant’s involvement in procuring underage girls for sex with him. Q. Maxwell was one of the main women whom you used to procure underage girls for sexual activities, true? THE WITNESS: Fifth. ae Q. Maxwell was a primary co-conspirator in your sexual abuse scheme, true? THE WITNESS: Fifth. Q. Maxwell was a primary co-conspirator in your sex trafficking scheme, true? THE WITNESS: Fifth. Q. Maxwell herself regularly participated in your sexual exploitation of minors, true? THE WITNESS: Fifth.'* 8. It is an undisputed fact that Juan Alessi testified that Defendant was one of the people who procured some of the over 100 girls he witnessed visit Epstein, and that he had to clean Defendant’s sex toys. Juan Alessi was Epstein’s house manager. He testified as follows: Q. And over the course of that 10-year period of time while Ms. Maxwell was at the house, do you have an approximation as to the number of different females — females that you were told were massage therapists that came to house? A. I cannot give you a number, but I would say probably over 100 in my stay there. eR Q. I don’t think I asked the right — the question that I was looking to ask, so let me go back. Did you go out looking for the girls — A. No. Q. —to bring — A. Never Q. —as the massage therapists? A. Never. Q. Who did? "” See McCawley Dec. at Exhibit 8, Kellen Dep. Tr. at 15:13-18; 20:12-16. 'S See McCawley Dec. at Exhibit 3, Epstein Dep. Tr. at 116:10-15; 117:18-118:10. 11

Case 18-2868, Document 280, 08/09/2019, 2628232, Page20 of 74 A. Ms. Maxwell, Mr. Epstein and their friends, because their friend relay to other friends they knew a massage therapist and they would send to the house. So it was referrals. bet Q. Did you have occasion to clean up after the massages? A. Yes. Q. Okay. And that is after both a massage for Jeffrey Epstein, as well as clean up after a massage that Ghislaine Maxwell may have received? A. Yes. Q. And on occasion, after -- in cleaning up after a massage of Jeffrey Epstein or Ghislaine Maxwell, did you have occasion to find vibrators or sex toys that would be left out? A. yes, I did.” 9. It is an undisputed fact that Defendant was unable to garner a single witness throughout discovery who can testify that she did not act as the procurer of underage girls and young women for Jeffrey Epstein. Defendant has not been able to procure a single witness - not one — to testify that Defendant did not procure girls for sex with Epstein or participate in the sex. Even one of her own witnesses, Tony Figueroa, testified that she both procured girls and participated in the sex. Another one of Defendant’s witnesses, Ms. Giuffre’s mother, named Defendant as Ms. Giuffre’s “new mamma.” Indeed, those who knew her well, who spent considerable time with her in Epstein’s shared household, like Juan Alessi, Alfredo Rodriguez and Joanna Sjoberg, have testified that she was Epstein’s procuress. Others who lived with her — Jeffrey Epstein, Nadia Marcinkova, and Sarah Kellen — invoked the Fifth Amendment so as not to answer questions on the same. No one has testified to the contrary. B. Documentary Evidence also Shows that Defendant Trafficked Ms. Giuffre and Procured her for Sex with Convicted Pedophile Jeffrey Epstein while She Was Underage. 1. The Flight Logs Defendant has never offered a legal explanation for what she was doing with, and why she was traveling with, a minor child on 21 flights while she was a child, including 6 international flights, aboard a convicted pedophile’s private jet all over the world. Her motion for " See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 28:6-15; 30:51-25; 52:9-22. 12

Case 18-2868, Document 280, 08/09/2019, 2628232, Page21 of 74 summary judgment — as well as all previous briefing papers — are absolutely silent on those damning documents. 2. The Photographs Throughout a mountain of briefing and, and even in her own deposition testimony, Defendant never offered an explanation regarding Ms. Giuffre’s photographs of her, Defendant, and Epstein. She never offered a legal explanation for why Prince Andrew was photographed with his hand around Ms. Giuffre’s bare waist while she was a minor child, while posing with Defendant, inside Defendant’s house in London. This particular photograph corroborates Ms. Giuffre’s claims, and there is no other reasonable explanation why an American child should be in the company of adults not her kin, in the London house owned by the girlfriend of a now: 20 convicted sex offender. Ms. Giuffre also produced pictures of herself taken when she was in New York with Defendant and Epstein, and from a trip to Europe with Defendant and Epstein:*! °” See McCawley Dec at Exhibit 42, GIUFFRE007167, Prince Andrew and Defendant Photo. *! See McCawley Dec at Exhibit 42, GIUFFRE007182 - 007166. 13

Case 18-2868, Document 280, 08/09/2019, 2628232, Page22 of 74 And, Ms. Giuffre has produced a number of pictures of herself taken at the Zorro Ranch, 22 Epstein’s New Mexico Ranch, two of which are below.” Finally, among other nude photos, which included full nudes of Defendant, Ms. Giuffre produced images of females that the Palm Beach Police confiscated during the execution of the » See McCawley Dec at Exhibit 42, GIUFFRE007175; 007173. 14

Case 18-2868, Document 280, 08/09/2019, 2628232, Page23 of 74 warrant, including one photograph revealing the bare bottom of a girl who appears to be prepubescent (Ms. Giuffre will only submit its redacted form):”° 3. The Victim Identification Letter In 2008, the United States Attorney’s office for the Southern District of Florida identified Ms. Giuffre as a protected “victim” of Jeffrey Epstein’s sex abuse. The U.S. Attorney mailed Ms. Giuffre a notice of her rights as a crime victim under the CVRA.*4 Re: Jeffrey Epstein/ ____ NOTIFICATION OF IDENTIFIED VICTIM Dear By virtue of this letter, the United States Attomey’s Office for the Southern District of Florida provides you with the following notice because you are an identified victim of a federal offense. 4, New York Presbyterian Hospital Records Ms. Giuffre has provided extensive medical records in this case, including medical records from the time when Defendant was sexually abusing and trafficking her. Ms. Giuffre produced records supporting her claim of being sexually abused in New York resulting in both * See McCawley Dec at Exhibit 44, GIUFFRE007584. 4 See McCawley Dec. at Exhibit 30, GIUFFRE 002216-002218, Victim Notification Letter. 15

Case 18-2868, Document 280, 08/09/2019, 2628232, Page24 of 74 Defendant and Epstein taking Plaintiff to New York Presbyterian Hospital in New York while she was a minor.”* The dates on the hospital records show she was seventeen years old. 5. Judith Lightfoot Psychological Records As the Court is aware, Defendant propounded wildly overbroad requests for production concerning the past eighteen years of Ms. Giuffre’s medical history. Defendant repeatedly and vehemently argued to the Court that it was essential to procure every page of these records ina fanfare of unnecessary motion practice. See, e.g., Defendant’s Motion to Compel (DE 75); Defendant’s Motion for Sanctions at 10 (“Ms. Maxwell has been severely prejudiced by Plaintiff's failure to provide the required identifying information and documents from her health care providers.”). Ms. Giuffre and her counsel took on the considerable burden and significant expense of retrieving and producing over 250 pages of medical records from over 20 providers, spanning two continents and nearly two decades. Now that those records have been collected, Defendant’s 68 page motion makes no reference to a single medical record produced by Ms. Giuffre, nor a single provider, nor a single treatment, nor or a single medication prescribed. After Defendant’s repeated motion practice stressing the essentiality of these records, this may surprise the Court. But not Ms. Giuffre. Defendant’s requests unearthed documents that are highly unfavorable to Defendant that corroborate Ms. Giuffre’s claims against her. Years before this cause of action arose, Ms. Giuffre sought counseling from a psychologist for the trauma she continued to experience after being abused by Defendant and Epstein. A 2011 psychological treatment record, written by her treating psychologist, unambiguously describes Defendant as Ms. Giuffre’s abuser: * See McCawley Dec at Exhibit 33, GIUFFRE003259-003290. 16

Case 18-2868, Document 280, 08/09/2019, 2628232, Page25 of 74 . .. [Ms. Giuffre] was approached by Ghislaine Maxwell who said she could help her get a job as a massage therapist . . . seemed respectable . . . was shown how to massage, etc., Geoff [sic] Epstein. Told to undress and perform sexual acts on person. Miss Maxwell promised her $200 a job.° Therefore, years before Defendant defamed her, Ms. Giuffre confided in her treating psychologist that Maxwell recruited her for sex with Epstein. 6. Message Pads Detective Recarey, the lead investigator of the criminal investigation into Epstein and his associates’ sex crimes, recovered carbon copies of hand-written messages taken by various staff, including Defendant, at Epstein’s Palm Beach residence.2” These were collected both from trash pulls from the residence and during the execution of the search warrant where the pads were found laying out in the open in the residence.”* The search warrant was executed in 2005 and the message pads collected include messages recorded in 2004 and 2005. Numerous witnesses have described that these copies of collected messages accurately reflect those taken by various staff at the Palm Beach Epstein mansion between 2004 and 2005.” The messages raise a question of fact as to Maxwell’s involvement in the sexual abuse of minors and are relevant to refute Maxwell’s denial of any involvement with Epstein during relevant time periods, and, accordingly her denial of knowledge of certain events. While there were hundreds of these messages recovered during the investigation, this small sample demonstrates the undeniable reality that there exists a genuine issue of material fact with respect to Defendant’s involvement in and knowledge of the activities described by Giuffre which Maxwell has said we “untrue” and “obvious lies.” °6 See McCawley Dec. at Exhibit 38, Lightfoot Records, GIUFFRE005437. 27 See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 45:13-25; 97:9-98:8. *8 See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 25:12-21; 40:5-15; 41:16-23; 42:14-43:10; 45:13-25; see also search warrant video showing the pads openly displayed on the desk. » See McCawley Dec. at Exhibit 21, 1, 16, 11, Rodriguez Dep. Tr. at 73:19-74:12; Alessi Dep. Tr. at 141:18-21; Sjoberg Dep. Tr. at 64:1-6; Maxwell Dep. Tr. at 147:23-148:3; 148:19-149:14. 17

Case 18-2868, Document 280, 08/09/2019, 2628232, Page26 of 74 This sampling reveals that Maxwell, “GM,” took messages at the residence, including from underage girls who were calling to schedule a time to come over to see Epstein. This demonstrates that Maxwell was at Epstein’s Palm Beach mansion in 2004 and 2005, incidentally a time period she has denied being around the house in her deposition. See supra GIUFFRE001412; 001435; 001449. The messages also reveal that multiple “girls” were leaving messages that were being taken and memorialized and left out in the open for anyone to see. Certain messages also make clear that a number of these “girls” were in school. In addition to taking messages herself (and the staff working under her direction taking these relevant messages), staff employees were taking and leaving messages for Defendant. This is evidence that Maxwell was in the house at relevant times, including times that she has now testified under oath that she was not there. Other messages demonstrate Epstein and Maxwell’s friends, including Jean Luc Brunel, leaving messages relating to underage females. The following is a small sampling of such messages: IMPORTANT MESSAGE IMPORTANT MESSAGE IMPORTANT MESSAGE saonidss GIUFFREO01412 (SAQ01092) GIUFFREO01427 (SAQ01456) GIUFFRE001388 (SAQ01067)

Case 18-2868, Document 280, 08/09/2019, 2628232, Page27 of 74 IMPORTANT MESSAGE SAO01461 GIUFFRE001432 (SAQ01461) IMPORTANT MESSAGE iswmesrarcal| — [esc aoae justdid a gp) 2G, yeas - ae ee eet rere | GIUFFREO01426 (SA001455) IMPORTANT MESSAGE GIUFFREO01448 (SAQ01476) IMPORTANT MESSAGE aihles ROR = » fbn = aero ——[ rneco [ou 0 wero = [emeranou| —fexeu aiaaoe ote has a feather “Por you to teach you tot! to speak Vus@ian Ser 7s Zu F Yeors eked | sedel GIUFFREO01423 (SA001452) a framrenso _X[mracecar fees eras cyl fc a Trim Beach Yeeosy te skeuy | Secs nn Inulp hee ne ShoGE voit Cabostescye — sao GIUFFREO01454 (SA002830)

Case 18-2868, Document 280, 08/09/2019, 2628232, Page28 of 74 The following are descriptions of a sampling of messages pads*” that create a genuine dispute of material fact: One message pad reflects a who is identified in the Palm Beach Police Report as a minor, contacting Jeffrey Epstein for “work” explaining that she does not have any money. The term “work” was often used by members of Jeffrey Epstein’s sexual trafficking ring to refer to sexual massages. (See GIUFFRE05660 (“She stated she was called by Sara for her to return to work for Epstein stated ‘work’ is the term used by Sarah to provide the massage in underwear.”). Giuffre 001462: July 5th no year to JE from am) ”T need work. I mean I don’t have money. Do you have some work for me?” Other message pads reflect J who was a minor, calling and leaving a message at the Palm Beach mansion that she has recruited another girl for Jeffrey Epstein. The second message demonstrates that Jeffrey Epstein required different girls to be scheduled every day of the week. The third shows an offer to have two minor girls come to the home at the same time to provide sexual massages. These type of messages indicate the lack of secrecy of the fact that multiple young females were visiting every day and at least raises a question of fact whether Maxwell was knowledgeable and involved as Giuffre has said, or whether Giuffre was lying and Maxwell was not at all involved or aware of this activity, as Defendant would attempt to have the world believe. Giuffre 001428 — undated Jeffrey From - “Has girl for toni ht” ;Giuffre 001432 (pictured above)— 7/9/04 — Mr. Epstein From is available on Tuesday no one for tomorrow”; GIUFFRE 001433 TTT04 = Mr. Epstein from — “Me and can come tomorrow any time or FBalone” ; ; Giuffre — 001452 — undated Jeffrey from “Has girl for tonight.” Other message pads demonstrate that there was a pattern and practice of using young females to recruit additional young females to provide sexual massages on a daily basis. Giuffre 001413 (pictured above)— JE from “N” — ‘ hasn’t confirmed for 11:00 yet, so she is keeping on hold in case doesn’t call back; Giuffre 001448 -8/20/05 JE from - confirmed _ at 4 pm. Who is scheduled for morning? I believe wants to work.” This message pad reflects that a friend of Jeffrey Epstein is sending him a sixteen year old Russian girl for purposes of sex. Giuffre 001563 (pictured above)- 6/1/05 For Jeffrey From Jean Luc “He has a teacher for you to teach you how to speak Russian. She is 2X8 years old not blonde. Lessons are free and you can have your 1st today if you call.” This message pad directly refutes Maxwell’s sworn testimony that she was not present during the year 2005 at Jeffrey Epstein’s Palm Beach mansion because this shows leaving a message for Jeffrey at the Palm Beach home that she was going to work out *” See McCawley Dec. at Exhibit 28. 20

Case 18-2868, Document 280, 08/09/2019, 2628232, Page29 of 74 with the Defendant on September 10, 2005. The police were only able to retrieve a fraction of these message pads during their trash pull but even in the few they recovered, it shows Maxwell was regularly at the Palm Beach home during the time period she claimed she was not. To the contrary, she was both sending and receiving messages and messages, like this one, reflect her presence at the mansion. Giuffre 001412 — 9/10/05 (during the year Maxwell says she was never around) JE from — “I went to Sarah and made her water bottle and I went to work out with GM.” These message pads further corroborate that Defendant lied in her testimony and she was in fact in regular contact with Jeffrey Epstein during the years 2004 and 2005. For example, the message from “Larry” demonstrates that Defendant is at the Palm Beach mansion so frequently that people, including Epstein’s main pilot Larry Visoski, are leaving messages for Maxwell at the Palm Beach house. Giuffre 001435 7/25/04 — Mr. Epstein from Ms. Maxwell — “tell him to call me”; Giuffre — 001449 — 8/22/05 — JE from GM; Giuffre — 001453 — 4/25/04 for Ms. Maxwell From Larry “returning your call”; This message pad shows that Defendant was clearly actively involved in Jeffrey Epstein’s life and the activities at his Palm Beach mansion. Giuffre — 001454 — undated Jeffrey From Ghislaine — “Would be helpful to have come to Palm Beach today to stay here and help train new staff with Ghislaine.” This message pad clearly reflects an underage female (noted by the police redaction of the name) leaving a message asking if she can come to the house at a later time because she needs to “stay in school.” Giuffre 001417 (pictured above)— Jeffrey 2/28/05 Redacted name “She is wondering if 2:30 is o.k. She needs to stay in school.” This message pad reflects a message from who was under the age of eighteen at the time she was going over to Jeffrey Epstein’s home to provide sexual massages according to the Palm Beach Investigative Report. Giuffre 001421 3/4/05 to Jeffrey from “Tt is o.k. for to stop by and drop something?” These message pads reflect the pattern of underage girls (noted by the police redaction of the name on the message pad) calling the Palm Beach mansion to leave a message about sending a “female” over to provide a sexual massage. Giuffre 001423 11/08/04 To Mr. JE — redacted from — “I have a female for him” Giuffre 001426 (pictured above) — 1/09/05 JE To JE from Redacted — “I have a female for him.” This message pad reflects the pattern and practice of having young girls bring other young girls to the house to perform sexual massages. Indeed the = reflected in this message pad corresponds in name to the a” that Tony Figueroa testified he initially brought to Jeffrey Epstein during the time period that the Defendant was requesting that Tony find some young females to bring to Jeffrey Epstein’s home. See Figueroa at 184185. The Palm Beach Police Report reflects that ; | hl and ; ff also brought seventeen year old to the home to perform sexual massages. See GIUFFRE 05641. =i thereafter recruited a number of other young girls to perform sexual 21

Case 18-2868, Document 280, 08/09/2019, 2628232, Page30 of 74 massages as reflected in the Palm Beach Police Report. Giuffre 001427 (pictured above) — 1/2/03 — JE from =a “Wants to know if she should bring her friend Ea with tonight.” e This message pad reflects multiple sexual massages being scheduled for the same day which corroborates Virginia GIUFFRE, a: Johanna Sjorberg’s testimony that Jeffrey Epstein required that he have multiple orgasms in a day which occurred during these sexual massages. Giuffre 001449 (pictured above) — 9/03/05 JE from —“T left message for i to confirm for 11:00 a.m. and fy for 4:30 p.m.” e This message pad shows a friend of Jeffrey Epstein’s discussing with him how he had sex with an 18 year old who had also been with Jeffrey Epstein. Giuffre — 001456 (pictured above)— undated JE from Jean Luc — “He just did a good one — 18 years — she spoke to me and said “I love Jeffrey.” Law enforcement was able to confirm identities of underage victims through the use of the names and telephone numbers in these message pads: Q. The next line down is what I wanted to focus on, April 5th, 2005. This trash pull, what evidence is yielded from this particular trash pull? THE WITNESS: The trash pull indicated that there were several messages with written items on it. There was a message from HR indicating that there would be an 11:00 appointment. There were other individuals that had called during that day. Q. And when you would -- when you would see females’ names and telephone numbers, would you take those telephone numbers and match it to -- to a person? THE WITNESS: We would do our best to identify who that person was. Q. And is that one way in which you discovered the identities of some of the other what soon came to be known as victims? THE WITNESS: Correct. Bet Q. Did you find names of other witnesses and people that you knew to have been associated with the house in those message pads? THE WITNESS: Yes. Q. And so what was the evidentiary value to you of the message pads collected from Jeffrey Epstein’s home in the search warrant? THE WITNESS: It was very important to corroborate what the victims had already told me as to calling in and for work.*! is The Black Book Palm Beach Police confiscated an extensive lists of contacts with their phone numbers form Defendant and Epstein’s residence.*” Ghislaine Maxwell maintained a contact list in an *! See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 42:14-43:17; 78:25:-79:15. 22

Case 18-2868, Document 280, 08/09/2019, 2628232, Page31 of 74 approximately 100-page-long hard copy, which was openly available to other house employees. It consisted primarily of telephone numbers, addresses, or email addresses for various personal friends, associates, employees, or personal or business connections of Epstein or Defendant. Prior to being terminated by Defendant, the Palm Beach house butler Alfredo Rodriguez printed a copy of this document and ultimately provided it to the FBI. This document reflects the numerous phone numbers of Defendant, Epstein as well as staff phone numbers. Additionally, and importantly, there are several sections entitled “Massage” alongside a geographical designation with names of females and corresponding telephone numbers. These numbers included those of underage females (with no training in massage therapy ) — including fF identified during the criminal investigation of Epstein. This document is an authentic reflection of the people who were associated with Epstein, Defendant, and the management of their properties, and the knowledge each had of the contents of the document. 8. Sex Slave Amazon.com Book Receipt Detective Recarey authenticated an Amazon.com receipt that the Palm Beach Police collected from Jeffrey Epstein’s trash. The books he ordered are titled: (1) SM 101: A Realistic Introduction, Wiseman, Jay; (2) SlaveCraft: Roadmaps for Erotic Servitude — Principles, Skills and Tools by Guy Baldwin; and (3) Training with Miss Abernathy: A Workbook for Erotic Slaves and Their Owners, by Christina Abernathy, as shown below: *® See McCawley Dec. at Exhibit 45, Phone List, Public Records Request No.: 16-268 at 2282 — 2288. 23

Case 18-2868, Document 280, 08/09/2019, 2628232, Page32 of 74 i This disturbing 2005 purchase corroborate Ms. Giuffre’s account of being sexually exploited by Defendant and Epstein — not to mention the dozens of underage girls in the Palm Beach Police Report. Additionally, Defendant testified that she was not with Jeffrey Epstein in 2005 and 2006 when he was ordering books on how to use sex slaves; however, record evidence contradicts that testimony. 9. Thailand Folder with Defendant’s Phone Number Defendant also was integral in arranging to have Virginia go to Thailand. While Epstein had paid for a massage therapy session in Thailand, there was a catch. Defendant told Virginia she had to meet young girls in Thailand and bring her back to the U.S. for Epstein and Defendant. Indeed, on the travel records and tickets Defendant gave to Virginia, Defendant wrote on the back the name of the girl Virginia was supposed to meet, and she was also instructed to check in frequently with Defendant as it was further signified by the words “Call Ms. Maxwell O) i”: on Virginia’s travel documents. In this case, Virginia also produced the hard copy records from her hotel stay in Thailand paid for by Epstein. See McCawley Dec. at Exhibit 32, 43, GIUFFRE 003191-003192; GIUFFRE 00741 1-007432. 24

Case 18-2868, Document 280, 08/09/2019, 2628232, Page33 of 74 10. It is undisputed fact that the FBI report and the Churcher emails reference Ms. Giuffre’s accounts of sexual activity with Prince Andrew that she made in 2011, contrary to Defendant’s argument that Ms. Giuffre never made such claims until 2014. Based on the FBI’s Interview of Ms. Giuffre in 2011, they wrote a report reflecting Ms. Giuffre’s claims concerning her sexual encounters with Prince Andrew:*? GIUEFRE anal kent shopping and purchased makeup, clothing, and a Sepparcy nag, The Tpeme were purchased with JcrureRe, ani jreturnedf instructed GIUFFRE to get ready. When GIUFFRE came down after gettin ready, she was introduced tof GIGETRE traveled to coos Taw Taree danced Jat CLUB TRAMP Tayed at CLUB TRANP Tor an hour or hour and a half and drank @ couple of cocktails before returning GIUFERE had not received any direction tron [ ‘After returning toL GivFFRE Taquested fo Take a photograph of hey TUPERE advised that she still had the original photograph in her possession and would provide it to the interviewing agents. GIUVEFRE proceeded with| Approximately two months later, GIUFFRE net Jac [siorrRe cecaiea] JarorenE recatied oking about trading GIUFFRE In because Tie was getting too old 3 See McCawley Dec. at Exhibit 31, GIUFFRE001235-1246, FBI Redacted 302. 25

Case 18-2868, Document 280, 08/09/2019, 2628232, Page34 of 74 Additionally, 2011 correspondence with Sharon Churcher shows that Ms. Giuffre disclosed her sexual encounters with Prince Andrew, but Churcher had to check with the publisher’s lawyers “on how much can be published,” -----Original Message----From: Sharon.Churcher@mailonsunday.co.uk Sent: Friday, 18 February 2011 7:25 AM To: Virginia Giuffre Hi there Have been up all night writing. Won't have an opinion from our lawyer on how much can be published until London wakes up. The lawyers wanted internal FBI documents but | think the Justice Dept letter is all you have from the feds??? Anyway can | give you a call early afternoon? Maybe have a late lunch? Ss See McCawley Dec. at Exhibit 34, GIUFFRE003678. Accordingly, there is documentary evidence that refutes Defendant’s meritless argument that Ms. Giuffre did not allege she had sex with Prince Andrew until 2014. To the contrary, two sources, including the FBI, show Ms. Giuffre made these claims in 2011. Cc. Defendant Has Produced No Documents Whatsoever That Tend to Show That She Did Not Procure Underage Girls For Jeffrey Epstein. Defendant has produced no documents that even tend to show that she did not procure underage girls for sex with Epstein, and no documents that tend to show that she did not participate in the abuse. Indeed, Defendant refused to produce any documents dated prior to 2009, which includes the 2000-2002 period during which she abused Ms. Giuffre. Against this backdrop of an avalanche of evidence showing the Defendant sexually trafficked Ms. Giuffre, summary judgment on any of the issues advanced by Defen dant is inappropriate. While we discuss the particulars of the individual claims below, the larger picture is important too. Ms. Giuffre will prove at trial that Epstein and Defendant sexually trafficked her. And yet, when Ms. Giuffre had the courage to come forward and expose what Defendant had done to world — in a Court pleading trying to hold Epstein accountable — Defendant 26

Case 18-2868, Document 280, 08/09/2019, 2628232, Page35 of 74 responded by calling her a liar in a press release intended for worldwide publication. Such heinous conduct is not a mere “opinion,” but rather is defamation executed deliberately and with actual malice. The jury should hear all of the evidence and then render its verdict on Ms. Giuffre’s complaint. Ill. LEGAL STANDARD Rule 56 of the Federal Rules of Civil Procedure provides that a motion for summary judgment may be granted only when “there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” The Second Circuit has repeatedly held that “all ambiguities and inferences to be drawn from the underlying facts should be resolved in favor of the party opposing the motion, and all doubts as to the existence of a genuine issue for trial should be resolved against the moving party.” Swan Brewery Co. Ltd. v. U.S. Trust Co. of New York, 832 F. Supp. 714, 717 (S.D.N.Y. 1993) (Sweet, J.), citing Brady v. Town of Colchester, 863 F.2d 205, 210 (2d Cir. 1988) (internal quotations omitted). In other words, in deciding a motion for summary judgment, the court must construe the evidence in the light most favorable to the non-moving party and draw all reasonable inferences in the non-moving party’s favor. In re “Agent Orange” Prod. Liab. Litig., 517 F.3d 76, 87 (2d Cir. 2008). Stern v. Cosby, 645 F. Supp. 2d 258, 269 (S.D.N.Y.2009). Summary judgment should be denied “if the evidence is such that a reasonable jury could return a verdict” in favor of the non-moving party. See Net Jets Aviation, Inc. v. LHC Commc’ns, LLC, 537 F.3d 168, 178-79 (2d Cir. 2008). IV. LEGAL ARGUMENT A. Defendant is Liable for the Publication of the Defamatory Statement and Damages for Its Publication Defendant’s lead argument is that, when she issued a press release attacking Ms. Giuffre to members of the media, she somehow is not responsible when the media quickly published her 27

Case 18-2868, Document 280, 08/09/2019, 2628232, Page36 of 74 attacks. If accepted, this remarkable claim would eviscerate defamation law, as it would permit a defamer to send defamatory statements to the media and then stand back and watch — immune from liability — when (as in this case) the defamatory statements are published around the world. This absurd position is not the law, particularly given that the Defendant released a statement to media asking them to “[p]lease find attached a quotable statement on behalf of Ms. Maxwell.” To make her claim seem plausible, Defendant cites older cases, some dating back as far as 1906. This presents a distorted picture of the case law on these issues. As a leading authority on defamation explains with regard to liability for republication by another of statement by a defendant: “Two standards have evolved. The older one is that the person making the defamatory statement is liable for republication only if it occurs with his or her express or implied authorization of consent. The more modern formulation adds responsibility for all republication that can reasonably be anticipated or that is the ‘natural and probable consequence’ of the publication.” SACK ON DEFAMATION § 2.7.2 at 2-113 to 2-114 (4th ed. 2016). In this case, however, the nuances of the applicable legal standards make little difference because Defendant so clearly authorized — indeed, desired and did everything possible to obtain — publication of her defamatory statements attacking Ms. Giuffre. 1. Under New York Law, Defendant is liable for the media’s publication of her press release. Given the obvious purposes of defamation law, New York law unsurprisingly assigns liability to individuals for the media’s publication of press releases. Indeed, New York appellate courts have repeatedly held that an individual is liable for the media publishing that individual’s defamatory press release. See Levy v. Smith, 18 N.Y.S.3d 438, 439, 132 A.D.3sd 961, 962-63 (N.Y.A.D. 2 Dept. 2015) (Generally, [o]ne who makes a defamatory statement is not responsible for its recommunication without his authority or request by another over whom he 28

Case 18-2868, Document 280, 08/09/2019, 2628232, Page37 of 74 has no control . . . Here, however . . . the appellant intended and authorized the republication of the allegedly defamatory content of the press releases in the news articles”); National Puerto Rican Day Parade, Inc. v. Casa Publications, Inc., 914 N.Y.S.2d 120, 123, 79 A.D.3d 592, 595 (N.Y.A.D. 1 Dept. 2010) (affirming the refusal to dismiss defamation counts against a defendant who “submitted an open letter that was published in [a] newspaper, and that [the defendant] paid to have the open letter published,” and finding that the defendant “authorized [the newspaper] to recommunicate his statements.”) See also RESTATEMENT (SECOND) OF TORTS § 576 (1977) (“The publication of a libel or slander is a legal cause of any special harm resulting from its repetition by a third person if. . . the repetition was authorized or intended by the original defamer, or . . . the repetition was reasonably to be expected.”)** Defendant deliberately sent her defamatory statement to major news media publishers for worldwide circulation because Defendant wanted the public at large to believe that Ms. Giuffre was lying about her abuse. Defendant even hired a public relations media specialist to ensure the media would publish her statement. Her efforts succeeded: her public relations agent instructed dozens of media outlets to publish her “quotable” defamatory statement and they did. Despite this deliberate campaign to widely publicize her defamatory statement, Defendant now disclaims any responsibility for the media publishing her press release. If we understand Defendant’s position correctly, because she somehow lacked “control” over what major newspapers and other media finally put in their stories, she escapes liability for defamation. This nonsensical position would let a defamer send a false and defamatory letter to major media, and then, when they published the accusation, escape any liability. Such an MCf, Eliah v. Ucatan Corp., 433 F. Supp. 309, 312-13 (W.D.N.Y. 1977) (“The alleged multistate publication of plaintiff's photograph without her consent thus gives rise to a single cause of action. ... However, evidence of the multistate publication of the magazine and the number of copies sold would be competent and pertinent to a showing of damages, if any, suffered by plaintiff.”) 29

Case 18-2868, Document 280, 08/09/2019, 2628232, Page38 of 74 argument is not only an affront to logic, but it is contrary to prevailing New York case law, cited above. Perhaps even more important, in the context of the pending summary judgment motion, it would require Defendant to convince the jury that she did not “authorize or intend” for the major media to publish her press release. Obviously the disputed facts on this point are legion, and summary judgment is accordingly inappropriate. Even the cases Defendant cites contradict her argument. She first cites Geraci v. Probst, in which a defendant sent a letter to the Board of Fire Commissioners, and, years later, a newspaper published the letter. The court held that the defendant was not liable for that belated publication, “made years later without his knowledge or participation.” /d., at 340. By contrast, Defendant not only authorized the defamatory statement, but paid money to her publicist to convince media outlets to publish it promptly — actions taken with both her knowledge and consent. Defendant’s statement was thus not published “without [her] authority or request,” as in Geraci, but by her express authority and by her express request. Defendant’s publicist’s testimony and the documents produced by Defendant’s publicist unambiguously establish that the media published her press release with Defendant’s authority and by her request: Q. When you sent that email were you acting pursuant to Ms. Maxwell’s retention of your services? A. Yes, I was ae Q. The subject line does have “FW” which to me indicates it’s a forward. Do you know where the rest of this email chain is? A. My understanding of this is: It was a holiday in the UK, but Mr. Barden was not necessarily accessible at some point in time, so this had been sent to him originally by Ms. Maxwell, and because he was unavailable, she forwarded it to me for immediate action. I therefore respond, “Okay, Ghislaine, I'll go with this.” It is my understanding that this is the agreed statement because the subject of the second one is “Urgent, this is the statement” so J take that as an instruction to send it out, as a positive command: “This is the statement.”*° * See McCawley Dec. at Exhibit 6, Ross Gow Dep. Tr. at 14:15-17; 44:6-45:13 (emphasis added). 30

Case 18-2868, Document 280, 08/09/2019, 2628232, Page39 of 74 Similarly, another case cited by Defendant, Davis v. Costa-Gavras, involved a libel claim against a book author who wrote an account of the 1972 military coup in Chile. Years later, the plaintiff attempted to ascribe defamation liability to a third-party publishing house’s decision to republish the book in paperback form and a third-party filmmaker who released a movie based on the book. The Court held that a “party who is ‘innocent of all complicity’ in the publication of a libel cannot be held accountable . . . [but that] a deliberate decision to republish or active participation in implementing the republication resurrects the liability.” 580 F. Supp. 1082, 1094 (S.D.N.Y. 1984). Here, Defendant made a deliberate decision to publish her press release, and actively participated in that process. At the very least, the jury must make a determination of whether Defendant was “innocent of all complicity” for a libelous statement contained in her press release. Finally, Defendant cites Karaduman v. Newsday, Inc., 416 N.E.2d 557 (1980), which held that reporters of a series of articles on narcotics trade “cannot be held personally liable for injuries arising from its subsequent republication in book form absent a showing that they approved or participated in some other manner in the activities of the third-party republisher.” Id., 416 N.E.2d at 559-560. Again, the jury could reasonably find that Defendant both approved of, and even participated in, the media’s publication of her press release. Indeed, it is hard to understand how any jury could find anything else. Defendant was obviously “active” in influencing the media to publish her defamatory press release, she both “approved” of and pushed for the publication of the press release. Accordingly, she is liable for its publication.*° *° On page 14 of her motion, Defendant makes wholly contradictory statements. In back-to-back sentences, she tells the Court that (1) she has no control over whether the media published the statement she sent to the media (with instructions to publish it by an influential publicist); (2) her public relations representative gave instructions to the media on how to publish it (in full); and (3) her public relations representative “made no effort to control” how the media would publish it. Indeed, the best evidence of Defendant’s control over the press is the fact dozens of media outlets obeyed her directive to publish her defamatory statement. 31

Case 18-2868, Document 280, 08/09/2019, 2628232, Page40 of 74 Therefore, disclaiming responsibility for the media’s publication of a statement (for which she hired a publicist for the purpose of influencing the media to publish that statement) is contrary to both prevailing case law, and the cases cited by Defendant. 2. Defendant is liable for the media’s publication of the defamatory statement. After arguing, contrary to New York law, that she is not liable for the media’s publication of her own press release, Defendant next argues that she is not liable for the media’s publications of the defamatory statement contained within her press release if the media chose to make even the tiniest of editorial changes. If we understand Defendant’s argument correctly, any omission of any language from a press release is somehow a “selective, partial” publication for which she escapes liability. Mot. at 14. Once again, this claim is absurd on its face. It would mean that a defamer could send to the media a long attack on a victim with one irrelevant sentence and, when the media quite predictably cut that sentence, escape liability for the attack. Moreover, even on its face, the claim presents a jury question of what changes would be, in context, viewed as “selective” or “partial” publications — something that only a jury could determine after hearing all of the evidence. In support of this meritless argument, Defendant cites Rand v. New York Times Co., for the proposition that a defendant cannot be liable for a publisher’s “editing and excerpting of her statement.” 430 N.Y.S.2d 271, 274, 75 A.D.2d 417, 422 (N.Y.A.D. 1980). This argument fails for several reasons. First, there is no “republication” by the media as a matter of law. Defendant issued a defamatory statement to the press, and its publication (as Defendant intended) is not a “republication” under the law, as discussed above. Second, there was no “editing” or paraphrasing or taking the quote out of context of the core defamatory statement in the press release: that Ms. Giuffre is a liar. The “obvious lies” passage is the heart of the message 32

Case 18-2868, Document 280, 08/09/2019, 2628232, Page41 of 74 Defendant sent to the press: that Ms. Giuffre was lying about her past sexual abuse. Even in isolation, Defendant’s quote stating that Ms. Giuffre’s claims are “obvious lies” does not distort or misrepresent the message Defendant intended to convey to the public that Ms. Giuffre was lying about her claims. As this Court explained in denying Defendant’s Motion to Dismiss, this case “involves statements that explicitly claim the sexual assault allegations are false.” Giuffire v. Maxwell, 165 F. Supp. 3d 147, 152 (S.D.N.Y. 2016). Furthermore, the facts at issue here make the Rand holding inapposite. In Rand, a newspaper paraphrased and “sanitized” defendant’s words. No such changing, sanitizing, or paraphrasing occurred in the instant case: the media quoted Defendant’s statement accurately. Further, the phrase at issue in Rand was that certain people “screwed” another person. The speaker/newspaper used the term “screwed” in reference to a record label’s dealings with a performing artist, and not did not mean “screwed” in the literal sense, but as “rhetorical hyperbole, and as such, is not to be taken literally.” Jd. By contrast, there is no hyperbole in Defendant’s defamatory statement, and it was never distorted or paraphrased by any publication known to Ms. Giuffre. A jury could reasonable conclude that Defendant’s statement that Ms. Giuffre’s claims of child sexual abuse are “obvious lies” is not a rhetorical device, nor hyperbole, but a literal and particular affirmation that Ms. Giuffre lied. Accordingly, there is no support in the factual record that the media reporting that Defendant stated that Ms. Giuffre’s claims of childhood sexual abuse are “obvious lies” is a distortion of Defendant’s message or hyperbole. Even a cursory review of the press release would lead to that conclusion. Moreover, to the extent that there is any dispute that Defendant’s statement had a different meaning outside of the context of the remainder of the press release, 33

Case 18-2868, Document 280, 08/09/2019, 2628232, Page42 of 74 such a determination of meaning and interpretation is a question of fact for the jury to decide, and is inappropriate for a determination upon summary judgment. B. Material Issues of Fact Preclude Summary Judgment. 1. The Barden Declaration presents disputed issues of fact. The primary basis of Defendant’s motion for summary judgment is her attorney’s selfserving, post hoc affidavit wherein he sets forth his alleged “intent” with regard Defendant’s defamatory statement.*” Ms. Giuffre disputes Defendant’s attorney’s alleged and unproven “intent” (not to mention Defendant’s “intent”), not only because Defendant refuses to turn over her attorney’s communications, but also because questions of intent are questions of fact to be determined by a trier of fact. Furthermore, ample record evidence contradicts the claimed “intent.” a. The Barden Declaration is a deceptive back-door attempt to inject Barden’s advice without providing discovery of all attorney communications. In her brief, Defendant discloses her attorney’s alleged legal strategy and alleged legal advice; however, she deliberately states that her attorney “intended,” instead of her attorney “advised,” when discussing her attorney’s legal strategy and advice, using that phrase at least 37 9939 ce, 1740 ce, ol times,** and using phrases such as Barden’s “beliefs, purposes, ‘goals,””” and >” The Barden declaration is problematic for other reasons as well. In addition to Defendant’s over-length, 68-page motion and among Defendant’s 654 pages of exhibits lies an eight-page attorney affidavit that proffers legal conclusions and arguments. This exhibit is yet another improper attempt to circumvent this Court’s rules on page limits. See Pacenza v. IBM Corp., 363 F. App'x 128, 130 (2d Cir. 2010) (affirming lower court decision to strike “documents submitted . . . in support of his summary judgment motion [that] included legal conclusions and arguments” because those “extraneous arguments constituted an attempt . . . to circumvent page-limit requirements submitted to the court.”); cf, HB v. Monroe Woodbury Cent. School Dist., 2012 WL 4477552, at *6 (S.D.N.Y. Sept. 27, 2012) (“The device of incorporating an affirmation into a brief by reference, as Plaintiffs have done here, in order to evade the twenty-five page limit, rather obviously defeats the purpose of the rule”). The court should disregard the Barden Declaration for that reason alone 38 MSI at 7 (three times), 8 (three), 15 (four), 16, 25 (five), 26, 33, 35 (two), 36 (three); Statement of Facts at 6 (two), 7 (five); Decl. of Philip Barden at 4 (four), 5 (three). °° MSJ at 25, 35; Statement of Facts at 7 (two); Decl. of Philip Barden at 3, 4 (three), 5 (two). 4° MSJ at 8, 25, 35; Statement of Facts at 7 (three); Decl. of Philip Barden at 4 (two), 5 (three). 34

Case 18-2868, Document 280, 08/09/2019, 2628232, Page43 of 74 “contemplations” 25 other times. All the while Defendant has claimed a privilege as to her communications with Barden. Defendant attempts to convince the Court that she only granted Gow permission to publish the defamatory statement as part of “Mr. Barden’s deliberated and carefully crafted” (MSJ at 16) legal strategy and advice. Yet, she still refused to turn over her communications with Barden under the auspices of attorney-client privilege.” Such gamesmanship should not be permitted. If the Court were to consider the Barden Declaration (which it shouldn’t), it would be ruling on a less than complete record because, based on this Declaration, it is necessary that Defendant disclose all communications with him and possibly others. Ms. Giuffre doesn’t have those communications, the court doesn’t have those communications; therefore, Defendant is asking for summary judgment on an incomplete record. The Court should also not consider the Barden Declaration because it will be inadmissible as unduly prejudicial. It is a self-serving declaration by a non-deposed witness made without turning over the documents that are relevant to the declaration. See, e.g., Rubens v. Mason, 387 F.3d 183, 185 (2d Cir. 2004) (“We find that the District Court predicated its grant of summary judgment as to liability on an affidavit from the arbitrator who presided over the underlying arbitration, the probative value of which was substantially outweighed by the danger of unfair prejudice. The affidavit, therefore should not have been admitted. We therefore vacate the grant of summary judgment to the defendants on liability and remand to the District Court.”). b. Defendant’s summary judgment argument requires factual findings regarding Barden’s intent, thereby precluding summary judgment. Even were the Court to consider this Declaration and representations therein — which it should not — the declaration itself demonstrates that the Court would have to make factual 4 MSJ at 27. ® See McCawley Dec. at Exhibit 22, Defendant’s Privilege Log. 35

Case 18-2868, Document 280, 08/09/2019, 2628232, Page44 of 74 finding as to what Mr. Barden’s intent really was. Finding about intent are inappropriate at the summary judgment stage, as this Court and the Second Circuit have recognized. This Court has explained, “if it is necessary to resolve inferences regarding intent, summary judgment is not appropriate.” Id. (Sweet, J.) (emphasis added), citing Patrick v. Le Fevre, 745 F.2d 153, 159 (2d Cir. 1984); Friedman v. Meyers, 482 F.2d 435, 439 (2d Cir. 1973) (other citations omitted). G. There are factual disputes regarding Barden’s Declaration. Finally, there are material disputes over the statements in the Barden Declaration because they are directly refuted by record evidence. For example, the instant motion and the Barden Declaration describe the press release merely as a document expressing “his [Mr. Bardent’s] opinion — in the form of a legal argument —as a lawyer would be,” as opposed to a press release for dissemination by the media to the public. Record evidence refutes this claim, as (1) the press release was sent to journalists, not media publishers or in-house counsel; (2) the press release instructed the journalists to publish the defamatory statement (“Please find attached a quotable statement on behalf of Ms. Maxwell”); (3) it was issued by a publicist on Defendant’s behalf and not by an attorney, without any reference to attorneys or laws — indeed, Gow testified that Barden was unavailable to approve the statement; and (4) Gow testified that he issued the statement only after he understood Defendant to have “signed off” it, an understanding he formed based on Defendant's “positive command” to him: “This is the agreed statement.” Q. When you sent that email were you acting pursuant to Ms. Maxwell’s retention of your services? A. Yes, I was. eR Q. When you say “agreed statement” can you tell me more about what you mean? Who agreed to the statement? A. Ineed to give you some context, if I may, about that statement. So, this is on New Year’s Day. I was in France so the email time here of 21:46, in French time was 22:46, and I was getting up early the next morning to drive my family back from the south of France to England, which is a 14-hour journey, door to door. So on the morning of th® 2nd of January, 36

Case 18-2868, Document 280, 08/09/2019, 2628232, Page45 of 74 bearing in mind that Ms. Maxwell, I think was in New York then, she was five hours behind, so there was quite a lot of, sort of time difference between the various countries here, I sent her an email, I believe, saying - parsing this-- forwarding this email to her saying “How do you wish to proceed?” And then I was on the telephone-- I had two telephones in the car, I received in excess of 30 phone calls from various media outlets on th° 2nd of January, all asking for information about how Ms. Maxwell was looking to respond to the latest court filings, which were filed on the 30th of December as I understand. And by close-- towards close of play on the 2nd, I received an email forwarded by Ms. Maxwell, containing a draft statement which my understanding was the majority of which had been drafted by Mr. Barden with a header along the lines of “This is the agreed statement.”: At close of play on th® 2nd. So—I was—I had gone under the Channel Tunnel and I was sitting on the other side and that email, which my understanding was that it had been signed off by the client, effectively, was then sent out to a number of media, including Mr. Ball and various other UK newspapers. Q. Mr. Gow, when you say “end of play” and “close of play,” are you referring to sending the email that is Exhibit 2? A. Yes, lam ae Q. The subject line does have “FW” which to me indicates it’s a forward. Do you know where the rest of this email chain is? A. My understanding of this is: It was a holiday in the UK, but Mr. Barden was not necessarily accessible at some point in time, so this had been sent to him originally by Ms. Maxwell, and because he was unavailable, she forwarded it to me for immediate action. I therefore respond, “Okay, Ghislaine, I’ll go with this.” It is my understanding that this is the agreed statement because the subject of the second one is “Urgent, this is the statement” so I take that as an instruction to send it out, as a positive command: “This is the statement.”* Accordingly, record evidence shows that the press release was intended as press release, and not as a “legal argument.” Record evidence also establishes that Defendant circulated the press release to Barden and Gow, and then gave a “positive command” to Gow to publish it. Additionally, there is no indicia that the press release is a legal opinion. To the contrary, it was issued by, and specifically attributed to, a woman who has personal knowledge of whether Ms. Giuffre’s claims of sexual abuse are true, and she states that Ms. Giuffre is a liar.“ At the very least, all of these factual issues must be considered by a jury. ® See McCawley Dec. at Exhibit 6, Ross Gow Dep. Tr. at 14:15-17; 31:19-33:7; 44:6-45:13 (emphasis added). Unsurprisingly, Defendant cites no case law to support her argument that her attorney’s alleged influence in preparing the statement Defendant issued to the media somehow shields her from liability. 37

Case 18-2868, Document 280, 08/09/2019, 2628232, Page46 of 74 Another example is that Defendant states that “Gow served only as Mr. Barden’s conduit to the media” (MTD at 25), and “Mr. Barden was directing the January 2-15 statement to a discrete number of media representatives.” Barden wasn’t directing anything — he wasn’t even in the loop when Defendant decided to publish the statement - and the documents prove it. Indeed, the press release itself states that it is “on behalf of Ms. Maxwell,” not Barden, and it was Defendant who gave the “positive command” to Gow to publish it. These are just a couple of examples, among many, of the purported facts asserted in Defendant’s motion and Barden’s Declaration that are directly refuted by facts in the record. Finally, neither the media nor the general public could have known that the statement should be attributed to Barden. His name was nowhere in it, nor is there any reference to counsel. Defendant’s argument that the “context” is the media knowing Barden’s intent or involvement is unsupported by the record. The significant factual disputes about Barden, alone, prevent summary judgment. Cc. Defendant’s Defamatory Statement Was Not Opinion as a Matter of Law. As this Court previously held, correctly, Defendant stating that Ms. Giuffre’s claims of sexual assault are lies is not an expression of opinion: “First, statements that Giuffre’s claims ‘against [Defendant] are untrue,’ have been ‘shown to be untrue,’ and are ‘obvious lies’ have a specific and readily understood factual meaning: that Giuffre is not telling the truth about her history of sexual abuse and Defendant’s role, and that some verifiable investigation has occurred and come to a definitive conclusion proving that fact. Second, these statements (as they themselves allege), are capable of being proven true or false, and therefore constitute actionable fact and not opinion. Third, in their full context, while Defendant’s statements have the effect of generally denying Plaintiff's story, they also clearly constitute fact to the reader.” Giuffre v. Maxwell, 165 F. Supp. 3d 147, 152 (S.D.N.Y. 2016). This Court further explained: “Plaintiff cannot be making claims shown to be untrue that are obvious lies without being a liar. Furthermore, to suggest an individual is not telling the truth 38

Case 18-2868, Document 280, 08/09/2019, 2628232, Page47 of 74 about her history of having been sexually assaulted as a minor constitutes more than a general denial, it alleges something deeply disturbing about the character of an individual willing to be publicly dishonest about such a reprehensible crime. Defendant’s statements clearly imply that the denials are based on facts separate and contradictory to those that Plaintiff has alleged.” Jd. Defendant argues that somehow the “context” of the entire statement “tested against the understanding of the average reader” should be the press release as a whole being read only by journalists. This is an unreasonable construct because the ultimate audience for a press release is the public. Indeed, the purpose of a press release is to reach readers. Unsurprisingly, Defendant cites no case that holds that journalists might somehow believe statements of fact are opinion while others do not. This Court has previously covered this ground when it clearly stated: Sexual assault of a minor is a clear-cut issue; either transgression occurred or it did not. Either Maxwell was involved or she was not. The issue is not a matter of opinion, and there cannot be differing understandings of the same facts that justify diametrically opposed opinion as to whether Defendant was involved in Plaintiffs abuse as Plaintiff has claimed. Either Plaintiff is telling the truth about her story and Defendant’s involvement, or Defendant is telling the truth and she was not involved in the trafficking and ultimate abuse of Plaintiff. Giuffre v. Maxwell, 165 F. Supp.at 152 (S.D.N.Y. 2016). The same conclusion applies now. At the motion to dismiss stage, Defendant had not yet produced the statement she issued to the press. That statement is now in evidence, so there is no ambiguity as to what defendant released to the press. The absurdity of Defendant characterizing his statements calling Ms. Giuffre a liar as mere “opinion” is revealed by the fact that Defendant was the one who was sexually trafficking and otherwise abusing Ms. Giuffre. No reasonable person in any context would construe that as Defendant’s mere “opinion” on the subject, since Defendant knew she was abusing Ms. Giuffre. Indeed, this argument is contradicted by Defendant’s own deposition testimony: 39

Case 18-2868, Document 280, 08/09/2019, 2628232, Page48 of 74 Q. Do you believe Jeffrey Epstein sexually abused minors? A. I can only testify to what I know. I know that Virginia is a liar and I know what she testified is a lie. So I can only testify to what I know to be a falsehood and half those falsehoods are enormous and so I can only categorically deny everything she has said and that is the only thing I can talk about because I have no knowledge of anything else. See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. (April 17, 2016) at 174:6-19. Defendant slyly contends in her motion that “Mr. Barden’s “arguments” in the press release constitute ‘pure opinion,” attempting to disclaim any involvement in making the defamatory statement. However, it is not Mr. Barden’s statement, nor his opinion, that it at issue here. At issue here is Defendant’s statement — a statement attributable to her, that she approved, whose publication she “command{ed],” and for which she hired a public relations representative to disseminate to at least 30 journalists for publication. While Mr. Barden could possibly have had his own opinion as to whether or not his client abused Ms. Giuffre, Defendant cannot express an opinion on a binary, yes/no subject where she knows the truth. As this Court previously articulated, “statements that Giuffre’s claims ‘against [defendant] are untrue,’ have been ‘shown to be untrue,’ and are ‘obvious lies’ have a specific and readily understood factual meaning.” Giuffre v. Maxwell, 165 F. Supp. 3d at 152. Again, at the very least, the jury must pass on such issues. D. The Pre-Litigation Privilege Does Not Apply to Defendant’s Press Release 1. Defendant fails to make a showing that the pre-litigation privilege applies. Defendant’s next argument seeks refuge in the pre-litigation privilege. If we understand the argument correctly, Defendant seems to be saying that because she was contemplating an (unspecified and never-filed) lawsuit involving the British Press, she somehow had a “green light” to make whatever defamatory statements she wanted about Ms. Giuffre. To prove such a 40

Case 18-2868, Document 280, 08/09/2019, 2628232, Page49 of 74 remarkably claim, Defendant relies on caselaw involving such mundane topics as “cease and desist” letters sent to opposing parties and the like. Obviously such arguments have no application to the press release that Defendant sent out, worldwide, attacking Ms. Giuffre’s veracity. The problems with the Defendant’s argument are legion. For starters, there is no record evidence — not even Defendant’s own testimony — suggesting that she was contemplating litigation against Ms. Giuffre, or that her press release was related to contemplated litigation against Ms. Giuffre. Tellingly, the only “evidence” Defendant cites of any alleged contemplated litigation is the self-serving, post hoc, partial waiver of attorney-client privilege found in the Barden Declaration. As discussed above, that Declaration fails to establish that there was good faith anticipated litigation between her and Ms. Giuffre, particularly when evidence in the record contradicts such assertions. At the very least, it is a matter of fact for the jury to decide. In another case in which a defendant attempted to claim pre-litigation privilege applied to statements made to the press, this Court denied summary judgment, and held, “[t]o prevail on a qualified privilege defense [defendant] must show that his claim of privilege does not raise triable issues of fact that would defeat it.” Block v. First Blood Associates, 691 F. Supp. 685, 699-700 (Sweet, J.) (S.D.N.Y. 1988) (denying summary judgment on the pre-litigation qualified privilege affirmative defense because there was “a genuine issue as to malice and appropriate purpose”). Defendant’s claim here likewise fails. First, Defendant’s testimony makes no mention of any contemplated lawsuit — much less, any contemplated lawsuit against Ms. Giuffre. Second, Defendant has offered no witnesses who will testify that she intended to bring any law suit. Third, she did not, in fact, bring any such lawsuit. The only “evidence” is a post hoc Declaration written by her attorney. Finally, it must be 41

Case 18-2868, Document 280, 08/09/2019, 2628232, Page5S0O of 74 remembered, as explained at length above, the Defendant had sexually trafficking Defendant and was attempting to continue to conceal her criminal acts. Whether her statements had an “appropriate purpose,” Block 691 F. Supp. at 699-700 (Sweet, J.) — or were, rather, efforts by a criminal organization to silence its victims — is obviously contested. Accordingly, obvious issues of fact exist as to whether or not Defendant contemplated litigation. Distorting reality, Defendant further argues: “Statements pertinent to a good faith anticipated litigation made by attorneys (or their agents under their direction) before the commencement of litigation are privileged.” (MSJ at 33). The record evidence shows that Defendant’s attorney did not make the defamatory statement. Further, Defendant’s attorney’s agents did not make the defamatory statement. Defendant did. And, there was no statement made by anyone “before the commencement of litigation” because /itigation never commenced. Accordingly, the cases Defendant cites where attorneys are making statements (or where clients are making statements to their attorneys regarding judicial proceedings including malpractice) are wholly inapposite as detailed below. 45 ¢ Front v. Khalil, 24 N.Y.3d 713, 720 (2015) - statement made by attorney. © Flomenhaft v. Finkelstein, 127 A.D.3d 634, 637 n.2, 8 N.Y.S.3d 161 (N.Y. App. Div. 2015) - did not even address pre-litigation privilege, and said that Front, Inc. was not relevant to the case. ¢ Kirk vy, Heppt, 532 F. Supp. 2d 586, 593 (S.D.N.Y. 2008) - the communication at i attorney’s client to the attorney’s malpractice carrier concerning the client’s justi attorney over which the clients actually sued. © Petrus v Smith, 91 A.D.2d 1190 (N.Y.A.D.,1983) - the court held: “[rJemarks of attorney to Surrogate are cloaked with absolute immunity as statements made in course of judicial proceedings — Attorney’s gratuitous opinion outside courthouse calling plaintiff liar . . . is not similarly immune.” (This case undermines the false argument Defendant tries to make). ¢ Klien - contrary to dicta quoted by Defendant from the Klein case, there were no communications made “between litigating parties or their attorneys,” just a press release Defendant instructed her press agent to disseminate to the media. © = Frechtman v. Gutterman, 115 A.D.3d 102, 103, 979 N.Y.S.2d 58, 61 (2014) - the communication at issue was a letter sent by a client to his attorney terminating the representation for malpractice. ¢ Sexter & Warmflash, P.C. v. Margrabe, 38 A.D.3d 163 (N.Y.A.D. 1 Dept. 2007) - privilege applied to letter client sent discharging law firm as the client’s attorneys as statements relating to a judicial proceeding and law firm sued for defamation. ue was made by an iable controversy against the 42

Case 18-2868, Document 280, 08/09/2019, 2628232, Page51 of 74 Similarly, in Black v. Green Harbour Homeowners’ Ass'n, Inc., 19 A.D.3d 962, 963, 798 N.Y.S.2d 753, 754 (2005), cited by Defendant, the Court held a privilege applied to a letter sent by a home owner’s association board of directors to the association’s members informing them of the status of litigation to which the association was a party, and to the association’s letter to the state attorney general sent to discharge it’s duties to the association. In this case, litigation was actually pending, the communication was sent by a party to that litigation as part of its duties, and the communication itself concerned the litigation. Defendant’s press release fits none of those descriptions. Unsurprisingly, Defendant cites to no case in which a Court has held that this or any qualified privilege extends to internationally disseminated press releases defaming a non-party to the purported “anticipated” litigation. Regardless of whether or not Barden had a hand in drafting the statement (another disputed issue of fact for the jury), Defendant issued the statement, instructed that it be published, and the statement she issued was attributed to her, and not to her attorney (or his agents). Accordingly, all the case law Defendant cites about an attorney making a statement (or a client making a statement to their attorney or malpractice carrier) is inapposite. 2. Defendant is foreclosed from using the pre-litigation privilege because she acted with malice. In any event, because Defendant acted with malice, she cannot avail herself of the prelitigation privilege. As this Court has explained denying Defendant’s motion to dismiss, “‘There is no qualified privilege under New York law when such statements are spoken with malice, knowledge of their falsity, or reckless disregard for their truth.’” Giuffre v. Maxwell, 165 F. Supp. 3d at 155 (citing Block, 691 F. Supp. at 699 (Sweet, J.) (S.D.N.Y. 1988). There is ample record evidence that Defendant acted with malice in issuing the press release, thereby making the litigation privilege inapplicable. See Block, 691 F. Supp. at 700 (Sweet, J.) (“Here, sufficient 43

Case 18-2868, Document 280, 08/09/2019, 2628232, Page52 of 74 evidence has been adduced to support the inference that [defendant] acted with malice, and may not, therefore, claim a qualified privilege under New York law . . . a genuine issue as to malice and appropriate purpose has properly been raised and is sufficient to preclude summary judgment.”). For example, Ms. Sjoberg testified that Defendant recruited her for sex with Epstein, thus corroborating Ms. Giuffre’s own account of Defendant’s involvement in abusing her with Epstein. For another example, Jeffrey Epstein’s pilot testified that Defendant flew with Ms. Giuffre on at least 23 flights, thus corroborating Ms. Giuffre’s claims against Defendant. See McCawley Dec. at Exhibit 15, Rodgers Dep. Tr., at 34:3-10. For another example, Tony Figueroa testified that Defendant asked him for assistance in recruiting girls for Epstein — more testimony that corroborates Ms. Giuffre’s claims against Defendant. Defendant’s statements that Ms. Giuffre was lying and her claims of sexual abuse were “obvious lies” were not pertinent to a good faith anticipated litigation but, instead, they were made for an inappropriate purpose — i.e., to bully, harass, intimidate, and ultimately silence Ms. Giuffre. As the record evidence shows, Defendant knew the statements were false because Defendant engaged in and facilitated the sexual abuse of this minor child, therefore, they were made for the inappropriate purpose of “bullying,” “harassment,” and “intimidation.” See Front v. Khalil, 24 N.Y.3d 713, 720 (2015). Simply put, Defendant sexually trafficked Ms. Giuffre — and then tried to silence Ms. Giuffre to keep her crimes secret — circumstances that prevent her from using privileges designed to shield legitimate legal disputes from court interference. New York case law fully confirms that pre-litigation qualified privilege does not apply to this case. Historically, statements made in the course of litigation were entitled to privilege from defamations claims “so that those discharging a public function may speak freely to zealously represent their clients without fear of reprisal or financial hazard.” Jd. at 718. A 2015 New York 44

Case 18-2868, Document 280, 08/09/2019, 2628232, Page53 of 74 Court of Appeals case somewhat extended this privilege by holding that statements made by attorneys prior to the commencement of the litigation are protected by a qualified privilege if those statements are pertinent to a good faith anticipated litigation. /d. at 718. (“Although it is well settled that statements made in the course of litigation are entitled to absolute privilege, the Court has not directly addressed whether statements made by an attorney on behalf of his or her client in connection with prospective litigation are privileged” . . . “to advance the goals of encouraging communication prior to the commencement of litigation” . . . “we hold that statements made prior to the commencement of an anticipated litigation are privileged, and that the privilege is lost where a defendant proves that the statements were not pertinent to a good faith anticipated litigation.”). The Court of Appeals’ reason for allowing this qualified privilege could not be more clear: “When litigation is anticipated, attorneys and parties should be free to communicate in order to reduce or avoid the need to actually commence litigation. Attorneys often send cease and desist letters to avoid litigation. Applying privilege to such preliminary communication encourages potential defendants to negotiate with potential plaintiffs in order to prevent costly and time consuming judicial intervention.” /d. at 719-20. Under this rationale, the Khalil court found that an attorney’s letters to the potential defendant were privileged because they were sent “in an attempt to avoid litigation by requesting, among other things, that Khalil return the alleged stolen proprietary information and cease and desist his use of that information.” /d. at 720. Here, quite unlike Khalil, the Defendant’s statements were (1) made by a non-attorney (Defendant through Gow); (2) concerning a non-party to any alleged anticipated litigation; (3) knowingly false statements; and (4) contained in a press release directed at, and disseminated to, 45

Case 18-2868, Document 280, 08/09/2019, 2628232, Page54 of 74 the public at large. Defendant’s statements cannot be considered “pertinent to a good faith anticipated litigation,” such that the qualified privilege should apply. Finally, though it strains credulity to even entertain the prospect, if Defendant could make even colorable showings on these basic issues, it would remain an issue of fact for the jury to determine whether or not Defendant’s press release, calling Ms. Giuffre’s sex abuse claims “obvious lies,” was any type of “cease-and-desist” statement or a statement that acted to “reduce or avoid” or resolve any “anticipated” litigation. Summary judgment is obviously inappropriate here as well. 3. Defendant cannot invoke the pre-litigation privilege because she has no “meritorious claim” for “good faith” litigation. Finally, Defendant cannot prevail in asserting this qualified privilege because, in order to invoke this privilege, she must have “meritorious claims” for “good faith anticipated litigation.” Khalil specifically states that for the qualified privilege to apply, the statements must be made “pertinent to a good faith anticipated litigation,” and it does not protect attorneys . . . asserting wholly unmeritorious claims, unsupported in law and fact, in violation of counsel’s ethical obligations.” Khalil, 24 N.Y.3d at 718, 720 (emphasis added). Defendant has neither “meritorious claims” nor “good faith anticipated litigation.” Defendant cannot have a “meritorious claim” for “good faith anticipated litigation” against the press (or Ms. Giuffre) because Ms. Giuffre’s reports of her sexual abuse are true, Defendant knows that they are true, and Defendant made a knowingly false statement when she called Ms. Giuffre a liar. Under these circumstances, Defendant has no “meritorious” claim to make in “good faith” relating to either Ms. Giuffre’s statements or their coverage in the press, thereby making her defamatory statements wholly outside the protection of this qualified privilege. At the very least, the issue of 46

Case 18-2868, Document 280, 08/09/2019, 2628232, Page55 of 74 whether Defendant has meritorious claims against the press on the grounds that she did not abuse Ms. Giuffre is a question of fact for the jury to decide. Vv. DEFENDANT HAS NOT - AND CANNOT - SHOW THAT HER DEFAMATORY STATEMENT IS SUBSTANTIALLY TRUE Defendant next claims that her press release calling Ms. Giuffre a liar about her past sex abuse was somehow “substantially true.” Here again, this is a highly disputed claim. On its face, to determine what is “substantially” true or not requires extensive fact finding, such as whether Defendant recruited Ms. Giuffre as a minor child for sex with Defendant’s live-in boyfriend and convicted pedophile, Jeffrey Epstein. Accordingly, summary judgment is not appropriate. See Mitre Sports Intern. Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240, 255 (S.D.N.Y.2014) (denying summary judgment because it would require the Court to decide disputed facts to determine whether the statement at issue was substantially true); Da Silva v. Time Inc., 908 F. Supp. 184, 187 (S.D.N.Y. 1995) (denying motion for summary judgment because there was a genuine issue of material act as to whether defamatory photo and caption were not true, stating “{iJn the instant case Da Silva’s contention that she was a reformed prostitute at the time of photography and publication provides a rational basis upon which a fact-finder could conclude that the photograph was not substantially true”). Additionally, Defendant has remarkably not submitted any evidence that she did not recruit Ms. Giuffre for sex with Epstein. Nor has Defendant offered any evidence that her role in Epstein’s household was not to recruit girls and young women for Jeffrey Epstein. Accordingly, summary judgment is inappropriate. See Stern v. Cosby, 645 F. Supp. 2d 258, 277 (S.D.N.Y. 2009) (because defendant had “not submitted any evidence to show that Statement 11 is substantially true, her motion for summary judgment as to Statement 11 is denied”). 47

Case 18-2868, Document 280, 08/09/2019, 2628232, Page56 of 74 Further, much of the purported evidence upon which Defendant relies to allege the truth of her defamatory statement is merely hearsay, including inadmissible hearsay statements made by Alan Dershowitz, who Defendant did not depose in this case (and whom Ms. Giuffre has not had an opportunity to cross examine). Hearsay cannot establish the truth of a defamatory statement as a matter of law at summary judgment. Lopez v. Univision Communications, Inc., 45 F. Supp.2d 348, 359 (S.D.N.Y.1999) (denying summary judgment and holding “defendants’ evidence as to what they were told by representatives of NYU and Kean College, to the extent offered for the truth of the matters asserted, is inadmissible hearsay and an insufficient basis upon which to grant summary judgment of dismissal on the ground that the statements were substantially true.”). Finally, many of the facts upon which Defendant bases her argument that her defamatory statement was true are wholly tangential to the claims against her by Ms. Giuffre and the defamatory statement. For example, Defendant supports her contention that she did not recruit Ms. Giuffre for sex with Epstein based on the fact that Ms. Giuffre lived independently of her parents before meeting Epstein and Ms. Maxwell. (Of course, a child outside the supervision of her parents makes it much more likely she would be recruited by Defendant into sex trafficking, but that is for the jury to decide.) That fact does not go to whether or not Defendant’s statement calling Ms. Giuffre a liar is true, because Ms. Giuffre never made any claims relating to where she lived prior to meeting Defendant. Moreover, it is immaterial with whom she was living: the fundamental and overarching fact remains that Defendant recruited Ms. Giuffre for sex with Epstein when she was a minor child. Defendant next proffers Ms. Giuffre’s limited high school enrollment and short-term jobs that she held as evidence that she and Epstein did not abuse her. The logic of this position is 48

Case 18-2868, Document 280, 08/09/2019, 2628232, Page57 of 74 unclear. The fact that Ms. Giuffre worked at Taco Bell for a few days hardly establishes she was not abused by Defendant and Epstein. Indeed, if anything its shows the vulnerability of Ms. Giuffre to enticements that a billionaire and his wealthy and powerful girlfriend could offer. In any event, what to make of such fact is something for the jury to consider. They are irrelevant for the same reason as above: Ms. Giuffre never made any claims about her studies or her prior employment. Indeed, neither Ms. Giuffre’s statement about being recruited by Defendant as a child, nor Defendant’s refutation even mentions Ms. Giuffre’s lack of schooling or lack of a stable home as a child. Purported facts that have nothing to do with Ms. Giuffre’s claims of sexual abuse against Defendant, and nothing to do with Defendant calling Ms. Giuffre a liar for such claims, do not establish the “substantial truth” of Defendant’s statement. Tellingly, Defendant cites to no analogous case in any jurisdiction that even suggests otherwise. VI. PLAINTIFF DOES NOT NEED TO ESTABLISH MALICE FOR HER DEFAMATION CLAIM, BUT IN THE EVENT THE COURT RULES OTHERWISE, THERE IS MORE THAN SUFFICIENT RECORD EVIDENCE FOR A REASONABLE JURY TO DETERMINE DEFENDANT ACTED WITH ACTUAL MALICE Defendant’s next (and, again, quite remarkable) argument is that Ms. Giuffre somehow will be unable to establish actual malice in this case. One would think that a sex trafficker calling one of her victims a liar would be a quintessential example of actual malice. Defendant’s spurious case citations and misplaced argument do not detract from this core fact. Though Defendant does not mention the legal standard for actual malice until she is 48 pages into her 68-page brief,” the legal definition of actual malice, as defined by the United 4 Though perhaps a scrivener’s error, Defendant errantly cites to two Supreme Court cases ~ Gerts v. Robert Welch, Inc., 418 U.S. 323 (1974) and Philadelphia Newspapers, Inc. v. Hepps, 475 U.S. 767 (1986) — that arose out of the laws of Illinois and Pennsylvania, respectively, to support a proposition concerning New York law. Defendant also cites to Harte-Hanks Commc'ns, Inc. v. Connaughton, 491 U.S. 657, 109 S, Ct. 2678, 105 L. Ed. 2d 562 (1989), wherein the ruling was not at summary judgment, and the plaintiff in the defamation case was a judicial candidate in a public election. 49

Case 18-2868, Document 280, 08/09/2019, 2628232, Page58 of 74 States Supreme Court, and reiterated by the Second Circuit, should be the light by which all of Defendant’s purported “facts” and argument should be viewed. “Actual malice” means that the statement was published with “knowledge that the statement was ‘false or with reckless disregard of whether it was false or not.’” Baiul v. Disson, 607 F. App'x 18, 20 (2d Cir. 2015), quoting New York Times Co. v. Sullivan, 376 U.S. 254, 280, 84 S. Ct. 710, 11 L.Ed.2d 686 (1964). Defendant argues that Ms. Giuffre is a limited purpose public figure. While Ms. Giuffre disputes that claim, the issue is entirely irrelevant here because Ms. Giuffre will prove at trial, with overwhelming evidence, that Defendant made her statement calling Ms. Giuffre a liar with malice, fully knowing — as a sex trafficker — that it was false. Put another way, Defendant knew that Ms. Giuffre was telling the truth when she described how Defendant recruited her for sex as an underage girl and then sexually trafficked her with her boyfriend Jeffrey Epstein. The Second Circuit instructs that, “[o]n a motion for summary judgment, a court cannot try issues of fact; it can only determine whether there are issues to be tried. If, as to the issue on which summary judgment is sought, there is any evidence in the record from any source from which a reasonable inference could be drawn in favor of the nonmoving party, summary judgment is improper.” Chambers v. TRM Copy Ctrs. Corp., 43 F.3d 29, 37 (2d Cir. 1994) (internal citations and quotations omitted). “As the moving party, Defendants have the burden of demonstrating an absence of clear and convincing evidence substantiating Plaintiffs’ claims.” De Sole v. Knoedler Gallery, LLC, 139 F. Supp. 3d 618, 640 (S.D.N.Y. 2015) (citing Chambers). Defendant fails to meet her burden of demonstrating an absence of clear and convincing evidence substantiating Ms. Giuffre’s claims that Defendant acted with actual malice. Ms. Giuffre will easily be able to meet any trial burden of clear and convincing evidence of actual 50

Case 18-2868, Document 280, 08/09/2019, 2628232, Page59 of 74 malice. Tellingly, Defendant does not even attempt to address the documentary evidence, nor the testimonial evidence showing she was a recruiter of girls for Epstein. As shown above, far beyond showing that a reasonable inference could be drawn in her favor, which is all that is required at this point to defeat Defendant’s motion, Ms. Giuffre will easily be able to meet her trial burden of clear and convincing evidence of actual malice. Of course, a plaintiff need only show “actual malice” on the part of a defendant if that plaintiff is a public figure or a limited public figure, which Ms. Giuffre is not, as explained infra. VII. THE COURT NEED NOT REACH THE ISSUE, AT THIS TIME, OF WHETHER MS. GIUFFRE IS A LIMITED PURPOSE PUBLIC FIGURE For the reasons just explained, Ms. Giuffre will easily be able to prove actual malice at the trial in this case. Defendant argues that Ms. Giuffre “is a public figure who must prove actual malice.” MSJ at 49. Given the overwhelming proof of the second part of that statement, the Court need not spend its time considering the first. If the Court wishes to nonetheless consider the issue at this time, it is not appropriate for disposition at the summary judgment stage of this case. The defendant bears the burden of demonstrating that the plaintiff is a limited purpose public figure. See Lerman v. Flynt Distrib. Co., 745 F.2d 123, 136-37 (2d Cir. 1984). Defendant correctly articulates the legal test for a finding that a plaintiff is a limited purpose public figure, but glosses over the fact that all prongs of the test must be met in order for a court to make that finding. See, e.g., Contemporary Mission, Inc. v. N.Y. Times Co., 842 F.2d 612, 617 (2d Cir. 1988) (“[T]his court set forth a four part test for determining whether someone is a limited purpose public figure” (emphasis added)); Herbert v. Lando, 596 F. Supp. 1178, 1186 (S.D.N.Y. 1984) (“The Second Circuit recently summarized the criteria” (emphasis added)), aff'd in part, rev'd in part, 781 F.2d 298 (2d Cir. 1986); cf: Nehls v. Hillsdale Coll., 178 F. Supp. 2d 771, 778 (E.D. Mich. 2001) (finding plaintiff Sl

Case 18-2868, Document 280, 08/09/2019, 2628232, Page60 of 74 was not a limited public figure for failing one element of the Lerman test and thus denying defendant’s motion for summary judgment) (“The defendant has proven all of the elements but the third ...”), aff'd, 65 F. App’x 984 (6th Cir. 2003). Of course, proof that Ms. Giuffre (or anyone else) is a limited purpose public figure requires proof of a set of facts from which Ms. Giuffre believes Defendant has not shown in satisfaction of the four-part test. Significantly this Court should pause here to note that the details of Jane Doe 3’s sexual exploitation and abuse, as anonymously set forth in her CVRA joinder motion, caused the Defendant to identify, with certainty, Jane Doe 3 as Ms. Giuffre. Yet, at her deposition, Defendant claimed to “barely remember her at all.”*” Defendant’s ability to immediately and positively identify the anonymous individual making claims of sexual abuse, if anything, shows that Defendant was intimately aware of Ms. Giuffre’s sexual exploitation. And, to be sure, Ms. Giuffre never asked to be sexually abused or trafficked by Defendant or convicted pedophile Jeffrey Epstein when she was a child — legally, she did not even have the capacity to consent. Defendant cannot recruit a minor child for sexual exploitation and then, afterwards, argue that her victim injected herself into the public controversy when coming forward about the abuse she suffered. Moreover, Defendant has not made a sufficient showing that Ms. Giuffre has “regular” and “continuing” access to the news media. The policy rationale behind this prong is that public figures generally enjoy significant access to the media. One reporter wrote some articles on Ms. Giuffre in 2011. Thereafter, it was not until 2015, that Ms. Giuffre spoke to someone in the news media about these issues, and that interview was granted after Defendant’s defamatory remarks. Such limited contacts precludes a finding that Ms. Giuffre is a limited public figure. See *” See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 44:23-45:4 (July 22, 2016) (“Q. You do remember Virginia, about that time back in the 2000s, giving Mr. Epstein massages? A. I barely remember her at all.”). 52

Case 18-2868, Document 280, 08/09/2019, 2628232, Page61 of 74 Hutchinson v. Proxmire, 443 U.S. 111, 99 S. Ct. 2675, 61 L.Ed.2d 411 (1979) (finding plaintiff maintained no regular and continuing access to the media and thus was not a public figure). It is also unclear how Defendant plans to show that Ms. Giuffre “successfully invited public attention to her views.” To be sure, Ms. Giuffre decided to start “Victims Refuse Silence,” a not-for-profit organization whose mission is “to change the landscape of the war on sexual abuse and human trafficking. Our goal is to undertake an instrumental role in helping survivors break the silence associated with sexual abuse. To fulfill this mission, we aim to enhance the lives of women who have been victimized.”** The website lists the National Trafficking Hotline, and provides a state-by-state resources for local organizations where victims can seek help. Unsurprisingly, Defendant cites no cases that hold that maintaining a website makes one a public figure. See Mitre Sports Int'l Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240, 252 (S.D.N.Y. 2014) (finding plaintiff was not a limited public figure and denying defendant’s motion for summary judgment) (“corporate policy denouncing child labor on its website ... do[es] not show that Mitre ... aimed to influence the public’s views on the controversy”). More important, Defendant does not explain how Ms. Giuffre was using the website to influence public views on whether she had been abused by Defendant — the subject at issue in this lawsuit. Interestingly, Defendant has spent $ 17,875“ on an expert witness to tell the Court and the jury that hardly anyone searches on the internet using search terms such as “victims refuse silence sex slave.” One of Defendant’s six briefs raising Daubert issues specifically argues that Dr. Anderson’s estimates on the cost of remediating Ms. Giuffre’s online reputation are improper because Dr. Anderson included nearly unused search phrases when evaluating internet content. Kent’s rebuttal report states: “. . . there seems no reason to believe that such a person would use “Shttp://www.victimsrefusesilence.org/our-mission. *® See McCawley Dec. at Exhibit 9, Kent Dep. Tr. at 25:16-26:6. 53

Case 18-2868, Document 280, 08/09/2019, 2628232, Page62 of 74 this term . . . Indeed, these are terms unlikely to be used by anyone unfamiliar with this litigation. . .. Why, for instance, would it be necessary to push down offending Web pages in the results that the search engines provide for the term victim’s refuse silence sex slave, when this term is likely never used . . .” See McCawley Dec. at Exhibit 25, Kent Report at 10, 33. Defendant cannot argue to the Court that Ms. Giuffre has “successfully” invited public attention to her views through her VRS website while simultaneously filing a Daubert motion that argues that search terms such as “victims refuse silence sex slave” are “likely never used,” thus making the website unsuccessful in inviting public attention. In any event, Defendant has failed to set forth with precision the allegedly undisputed fact — and supporting evidence — she uses to support her argument. Moreover, “[i]t is preferable to reduce the public figure question to a more meaningful context by looking to the nature and extent of an individual’s participation in the particular controversy giving rise to the defamation.” Greenberg v. CBS Inc., 69 A.D.2d 693, 704, 419 N.Y.S.2d 988, 995 (1979) (emphasis added), citing Gertz v. Robert Welch, Inc., 418 U.S. 323, 345, 352, 94 S. Ct. 2997, 41 L.Ed.2d 789. The context here is highly significant. Ms. Giuffre never chose to participate in Defendant and Epstein’s underage sex ring, a “controversy” that gave rise to Defendant’s defamation. In arguing that Ms. Giuffre thrust herself into the public spotlight, Defendant conveniently leaves out the fact that it is by her doing that Ms. Giuffre is in this controversy in the first place. No minor child willingly becomes a participant in sexual abuse, and it is perverse for the abuser to argue that her victim deliberately became a subject of public attention when speaking out about that abuse for the purpose of advancing justice and helping other victims. 54

Case 18-2868, Document 280, 08/09/2019, 2628232, Page63 of 74 For all these reasons, the Court should simply decline to decide the public figure issue at this juncture. But if it chooses to reach the issue, it should reject Defendant’s unsupported argument. VII. THE JANUARY 2015 STATEMENT WAS NOT “SUBSTANTIALLY TRUE,” AND MS. GIUFFRE HAS PRODUCED CLEAR AND CONVINCING EVIDENCE OF ITS FALSITY As a final argument, Defendant argues that her January 2015 statement was “substantially true.” Given that the statement argues that Ms. Giuffre lied when she said she was sexually trafficked by Defendant, the reader of Defendant’s motion might reasonably expect to see some evidence presented showing that Defendant was not a sex trafficker. Instead, the reader is treated to technical quibbles. For example, the lead argument to show the “substantial” truth of Defendant’s statement is the argument that Ms. Giuffre was not fifteen years old, but all of sixteen or seventeen years old when she was trafficked. As the Court knows (and can take judicial notice of), Florida law makes age eighteen the age of consent. Accordingly, it is no moment that Ms. Giuffre may have been mistaken about the exact year the sex trafficking started. Call this the “yes-I’m-a-sex-trafficker-but-only-of-sixteen-year-old-girls” defense. To even describe the defense is to show how meritless it is. More broadly, at issue are the statements Ms. Giuffre made regarding Defendant’s involvement in, and knowledge of, the sexual abuse and sex trafficking of Ms. Giuffre (and other minor girls) through a recruitment scheme executed by Defendant and Jeffrey Epstein. In response to those various statements, Defendant publicly claimed that, “the allegations made by (Ms. Giuffre) against Ghislaine Maxwell are untrue.” Defendant continued that Ms. Giuffre’s “claims are obvious lies and should be treated as such....” Defendant, through her statement 55

Case 18-2868, Document 280, 08/09/2019, 2628232, Page64 of 74 intended to convey that Ms. Giuffre was lying about everything she had said against Defendant — “the allegations.” In sum and essence, those statements made by Ms. Giuffre about which Defendant released a public statement to exclaim were “untrue” and “obvious lies” were: qd) Q) @) (4) (5) (6) op) (8) (9) That Defendant approached Ms. Giuffre while Ms. Giuffre was an underage minor working at the Mar-a-Lago Country Club, and recruited the then-minor Ms. Giuffre to go to the house of Jeffrey Epstein under the pretense of providing massage to Jeffrey Epstein for money; 2 That Ms. Giuffre followed Defendant’s instructions, and was driven to Jeffrey Epstein’s house, where she was greeted by Defendant and later introduced to Jeffrey Epstein; That Ms. Giuffre was lead upstairs to be introduced to Jeffrey Epstein in his bedroom, and that while there Defendant demonstrated how Ms. Giuffre should provide a massage to Jeffrey Epstein; That Defendant and Epstein converted the massage into a sexual experience, requesting that Ms. Giuffre remove her clothing, after which time a sexual encounter was had; That Defendant and Epstein expressed approval for Ms. Giuffre, and offered her money in exchange for this erotic massage turned full sexual encounter; That Defendant and Epstein offered Ms. Giuffre the promise of money and a better life in exchange for Ms. Giuffre acting sexually compliant and subservient to their demands; 4 at Ms. Giuffre, after that first encounter, was repeatedly requested to service pstein and/or Defendant sexually and/or others; les] That Ms. Giuffre was taken on Epstein’s private planes on numerous occasions and trafficked nationally and internationally for the purpose of servicing Epstein and others, including Defendant, sexually; That Defendant was Epstein’s primary manager of the recruitment and training of females who Epstein paid for sexual purposes; (10) That Defendant participated in sexual encounters with females, including Ms. Giuffre; and (11) That Ms. Giuffre and other recruited females were encouraged by Defendant and Epstein to bring other young females to Epstein for the purpose of servicing him sexually. 56

Case 18-2868, Document 280, 08/09/2019, 2628232, Page65 of 74 Defendant, by way of her January 2015 statement, declared that Ms. Giuffre lied about each and every one of these allegations regarding Defendant. In fact, Defendant clarified further this position in her deposition when she said repeatedly that everything Ms. Giuffre said about Defendant was totally false.*° The clarification in her deposition is identical in intention to the reasonable interpretation of her statement that Defendant made publicly, which has formed the basis of this defamation action—that Ms. Giuffre was lying about everything she said about Defendant, and that Defendant was not at all involved in the activity she was accused of engaging in. While her public statement could not have been more clear, as her deposition testimony further underscored, Defendant intended the world to believe that nothing Ms. Giuffre said about Defendant was true, and that Defendant was not at all involved with any of the things she was accused of, Defendant has decided in this motion to minutely dissect the nuance of Ms. Giuffre’s various statements to cause the Court to reach a far-fetched conclusion that Defendant’s insidiously false statement was somehow “substantially true.” Ironically, this repositioning amounts to nothing more than an admission by Defendant of the defamatory nature of her statement. A. When Ms. Giuffre Initially Described Her Encounters With Defendant and Epstein, She Mistakenly Believed the First Encounter Occurred During the Year 1999, Discovery has resulted in the production of records, including Ms. Giuffre’s employment records from Mar-a-Lago, which she did not possess at the time she was recounting her interactions with Defendant. Those records establish that the initial encounter wherein Defendant recruited Ms. Giuffre occurred during the year 2000 and not during 1999. Ms. Giuffre was * See McCawley Dec. at Exhibit 11, Maxwell 4-22-2016 Dep. Tr. at 135:3-4; 178:15-178:24; 179:20-180:7; 228:7229:10. s7

Case 18-2868, Document 280, 08/09/2019, 2628232, Page66 of 74 sixteen years old before August 9, 2000, and turned seventeen on that date. It is unclear from the limited records available whether Defendant approached and recruited Ms. Giuffre before or just after Ms. Giuffre’s 17th birthday. However, what has now been established through numerous witnesses is that Defendant approached and recruited a minor child for the purposes of enticing that minor over to the house of Jeffrey Epstein, a currently-registered sex offender.*! The exact lure of Ms. Giuffre by Defendant - enticement of being paid money to give a billionaire a massage at his mansion - was used by Epstein and his many associates and employees to recruit dozens and dozens of other underage girls. There is no doubt that the crux of Ms. Giuffre’s statement on this point is that Defendant recruited her when she was only a minor child unable to consent to sex, not precisely how far under the age of consent she was. Defendant’s public claim that Ms. Giuffre’s account of this approach, and recruiting element, was “untrue” and “obvious lies” is not “substantially true,” but is itself an obvious lie — as Ms. Giuffre will prove to the jury at trial. B. Defendant’s January 2015 Statement Claiming as “Untrue” and an “Obvious Lie” the Allegation That She Regularly Participated in Epstein’s Sexual Exploitation of Minors and That the Government Knows Such Fact is Not Substantially True But Instead Completely False. Defendant next argues that she “accurately denied that [she] ‘regularly participate[d] in Epstein’s sexual exploitation on minors’ and that ‘the Government knows such fact.’”” MSJ at 58. It is not clear whether Defendant is nitpicking this statement by contesting whether she “regularly” participated in Epstein’s sexual exploitation or whether she did participate, but the Government was unaware of the extent of her involvement. Call this the “yes-I’m-a-sextrafficker-but-only-on-Tuesdays-and-Thursdays” defense — here again, to simply recount the claim is to see its absurdity. *! See McCawley Dec. at Exhibit 1, 5, Alessi Dep. Tr. at 94:24-95:2; Giuffre Dep. Tr. at 111:12-111:21; 116:19117:12. 58

Case 18-2868, Document 280, 08/09/2019, 2628232, Page67 of 74 Contrary to Defendant’s misleading, cherry-picked fragments of information she has chosen to use to support her point, there is an abundance of evidence clearly linking Defendant to Epstein’s sexual exploitation of minors. As the Court is aware, numerous message pads were recovered from Epstein’s home indicating Defendant’s involvement in and knowledge of Epstein’s illegal exploitation. oe Additionally, numerous employees and others have testified about Defendant’s high-ranking position in the hierarchal structure of the sexual exploitation scheme. ™ In fact, multiple individuals, in addition to the Ms. Giuffre, have testified about Maxwell’s involvement in the exploitation of minors, including Ms. Giuffre.** Defendant also argues that one government investigator, Palm Beach, Florida, Detective Recarey, may not have been aware of her involvement in the sex trafficking. Defendant fails to cite another passage in Detective Recarey’s deposition, where he noted that he was aware of Defendant’s involvement with Epstein and the sexual exploitation of children.** But even assuming Recarey was unaware (which Ms. Giuffre strongly disputes), Defendant would have, at most, a “‘yes-I’m-a-sex-trafficker-but-I-successfully-hid-it-from-one-of-the-cops” defense — again, not a likely claim. More broadly, Ms. Giuffre’s statement about what the “Government” knew about sex trafficking was made in pleadings filed in a federal Court case attacking the decision of the U.S. Attorney’s Office for the Southern District of Florida to offer Jeffrey Epstein immunity from prosecution for federal sex trafficking crimes. Accordingly, to present an even arguable claim for summary judgment, Defendant would have to show that the U.S. Attorney’s Office (and its See, e.g., McCawley Dec at Exhibit 28 (message pad excerpts), GIUFFRE 001412, 001418, 001435, 001446, 001449, 001453, 001454. See McCawley Dec. at Exhibit 21, 1, Rodriguez Dep. Tr. at 169:1-169:4; Alessi Dep. Tr. at 23:11-23:20; 34:1935:3; 98:5-98:12; 104:15-104:23. » See McCawley Dec. at Exhibit 16, 4, Sjoberg Dep. Tr. at 13; Figueroa Dep. Tr. at 96-97; 103; 200:6-18; 228:2329:21. %§ See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 29:16-29:20; 45:13-25; 83:3-83:15. 59

Case 18-2868, Document 280, 08/09/2019, 2628232, Page68 of 74 investigators from the FBI) did not know about Defendant’s sex trafficking. This proof would need to include, for example, evidence that the FBI did not learn about Defendant’s sex trafficking when (among other things) Ms. Giuffre told FBI agents about it when she met with them in Australia in 2011. Here again, Defendant has no evidence to even begin making such a showing. c Defendant’s January 2015 Statement Claiming as “Untrue” or an “Obvious Lie” That Maxwell and Epstein Converted Ms. Giuffre Into a Sexual Slave is Not Substantially True. Defendant next argues that she accurately disputed Ms. Giuffre’s statement that Defendant held her as a “sex slave.” Relying on dictionary definitions of “slave” that define the term to refer to a “confined” person who is the “legal property” of another (MSJ at 59, citing Merriam-Webster, etc.), Defendant claims Ms. Giuffre was not confined or the property of Defendant. Call this the “yes-I’m-a-sex-trafficker-but-I-didn’t-use-chains” defense. And, once again, to even describe the defense is to refute it. Defendant does not explain why the jury would be required to use the held-in-chains definition of “slave” in evaluating her statement. Merriam-Webster (11" ed. 2006) also defines “slave” as “one that is completely subservient to a dominating influence” — a definition that fits Ms. Giuffre’s circumstances to a tee. As Ms. Giuffre has explained in detail, she was recruited as a minor child by Defendant, who then dominated her and used for sexual purposes. That testimony alone creates a genuine issue of fact on this point. From the context of all of Ms. Giuffre’s statements about Defendant, Ms. Giuffre has never said or implied that she was physically placed in a cage. Instead, she has described the vast disparity of power and the influence of Defendant and Epstein, the fear of disobedience, the typical locations of the abuse being in a private plane, in huge mansion manned with Epstein employed servants, a private island, or some inescapable place abroad in the presence of 60

Case 18-2868, Document 280, 08/09/2019, 2628232, Page69 of 74 Defendant, in addition to the continued — and fraudulent — promise of a better future, as those things that kept her retained in a situation of sexual servitude. While not physical chained, Ms. Giuffre was groomed as minor and trained, and these factors became her invisible chains. Indeed, as Ms. Giuffre’s expert on sex trafficking, Professor Coonan, has explained: Popular understandings of the term “sex slave” might still connote images of violent pimps, white slavery, or of victims chained to a bed in a brothel in the minds of some people. To call Ms. Giuffre a victim of sex trafficking would however very accurately convey the reality that she along with a great many other victims of contemporary forms of slavery are often exploited by the “invisible chains” of fraud and psychological coercion. See McCawley Dec. at Exhibit 23, Coonan Expert Report at 20. If the Court takes as true, which it must for the purpose of this motion, that Ms. Giuffre was trafficked and used exclusively for sexual purposes by Defendant and Epstein, then the Court must also reach the conclusion at this stage that Maxwell’s assertion — that Ms. Giuffre’s description of being a sex slave is “untrue” or “obvious lies” — is not substantially true. There undoubtedly remains a genuine issue of material fact on this point, and in fact, Defendant’s position taken in this motion is tantamount to an admission of the truth of Plaintiff's statement about Defendant on this point. D. Any Statement of Misdirection Regarding Professor Alan Dershowitz is Nothing More Than an Irrelevant Distraction to The Facts of This Case and Matters Not on the Defense of Whether Defendant’s Statement Was Substantially True. Defendant next contends that she accurately recounted that Alan Dershowitz had denied having sex with Ms. Giuffre. MSJ at 60. Call this the “yes-I’m-a-sex-trafficker-but-she-was-nottrafficked-to-the-professor” defense. While it is accurate that Ms. Giuffre made allegations against Professor Dershowitz, those allegations are not at issue in this case. Defendant, in her defamatory statement, claimed that “the allegations made by [Ms. Giuffre] against Ghislaine Maxwell are untrue.” See McCawley Dec. at Exhibit 26, GM_00068. In her deposition, 61

Case 18-2868, Document 280, 08/09/2019, 2628232, Page70 of 74 Defendant maintained the position that she “cannot speculate on what anybody else did or didn’t do.” See McCawley Dec. at Exhibit 11, Maxwell 4-22-2016 Dep. Tr. at 180:3-180:4. In fact, regarding Ms. Giuffre’s claims about others, Defendant unequivocally stated, “I can only testify to what she said about me, which was 1000 percent false.” See McCawley Dec. at Exhibit 11, Maxwell 4-22-2016 Dep. Tr. at 228:10-228:12. Defendant Maxwell makes additional misstatements about Dershowitz’s production in a defamation action filed against him in her desperate attempt to have Dershowitz to jump aboard and help bail out her sinking canoe. While Ms. Giuffre can — and, if necessary, will — refute Dershowitz’s claim he was not a beneficiary of Epstein and Defendant’s sex trafficking, that is not relevant at this stage. Whatever may or may not have happened with Dershowitz (and Ms. Giuffre’s sworn statements that he sexually abused her is alone enough to create disputed facts on the issue of whether Defendant’s statements about him were “substantially true”) has no bearing whatsoever on the truth or falsity of the statements Ms. Giuffre made about Defendant. This case is not about whether Ms. Giuffre has ever made untruthful allegations against anyone, which she contends she has not, but about whether her allegations about Defendant were true, or whether those specific allegations were “untrue,” “obvious lies” as Defendant publicly proclaimed. These issues are disputed and must go to the jury. E. Contrary to Defendant’s Position, There is a Genuine Issue of Material Fact as to Whether She Created or Distributed Child Pornography, or Whether the Government Was Aware of Same. Defendant next argues that she did not create child pornography and that the Government knew this. Call this the “until-you-find-the-photos-I’ m-innocent” defense. Of course, as noted earlier, Defendant’s claim requires that she show that “the Government” — in context, the FBI and the U.S. Attorney’s Office for the Southern District of Florida — “knew” that she had no 62

Case 18-2868, Document 280, 08/09/2019, 2628232, Page71 of 74 child pornography. Yet Defendant has offered no such evidence — much less evidence so powerful as to warrant summary judgment on this point. This point is disputed from the simple fact that Ms. Giuffre herself testified that Defendant took many photograph of her naked. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 232:3-9; 233:7-9. This is consistent with the Palm Beach butler’s, Alfredo Rodriguez’s, testimony that he personally saw photos of naked children on Defendant’s computer. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at 150:10-17; 306:1-306:24. Another housekeeper, Juan Alessi also saw photos of young nude females on Defendant’s computer, although he wasn’t sure whether to consider it pornography. See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 175:5-175:24. Finally, Detective Recarey found a collage of nude photos of young females in Epstein’s closet, and turned the photos over to the FBI and U.S. Attorney’s office.*° While the U.S. Attorney’s office will not share the photos obtained from Recarey’s investigation, it is thus undisputed that the government possesses photos of nude, young females confiscated from Epstein’s Palm Beach mansion. Indeed, the police video disclosed through a FOIA request shows naked images of women throughout the house, including a full nude of the Defendant.*’ At a minimum, there is a clear genuine issue of material fact in this regard. F. Defendant Did Act as a “Madame” For Epstein to Traffic Ms. Giuffre to The Rich and Famous. Defendant next argues that she did not act as a “Madame” for Epstein. MSJ at 63. The gist of the argument seems to be that Defendant believes trafficking one girl to Epstein does not a Madame make. Call this the “yes-I-was-Virginia’s-Madame-but-no-one-else’s” defense. This argument fails linguistically on the very dictionary definitions that Defendant cites elsewhere — * See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 73:19-73:24; 74:2-74:7. *” See McCawley Dec. at Exhibit 44, FOIA CD GIUFFRE 007584. 63

Case 18-2868, Document 280, 08/09/2019, 2628232, Page72 of 74 but not here. See Merriam-Webster (1 1" ed. 2006) (defining “madam” as “the female head of a house of prostitution”). Once again, Defendant conceals the relevant facts on this issue. First, multiple witnesses have testified to Defendant’s recruiting, maintaining, harboring, and trafficking girls for Epstein.** In fact, Defendant herself was unable to deny procuring Ms. Giuffre for Epstein.” While Defendant has attempted to fumble her way through explaining some plausible reason for bringing a sixteen or seventeen year old to Epstein, her explanations are, to put it blandly, unpersuasive. As with other issues, the jury will have to decide who to believe. One of the individuals Ms. Giuffre was trafficked to was Prince Andrew — trafficking that took place in Defendant’s own townhouse in London. There exist flight logs evidencing Ms. Giuffre flying to London alongside Defendant and Epstein on Epstein’s private plane, and a photo of Ms. Giuffre, Defendant, and the Prince, without Defendant ever offering a legal reasonable explanation for that photo being taken, or for traveling with a year old girl overseas. Defendant begins to meander somewhat aimlessly on this point, shifting Plaintiff's burden to substantiate Plaintiff's claim that Defendant was Epstein’s Madame, which is a point at issue, into whether or not Plaintiff has conclusively proven the identities and accurate job titles of the other men to whom Plaintiff was lent for sex by Epstein. No matter how hard Defendant tries to reframe this case, drag other people in, or split hairs, she is unable to contest the facts — facts showing she was more than a Madame but a full-fledged sex trafficker. Ms. Giuffre told the truth when she said that Defendant recruited her as a minor, under the pretense of giving a ** See McCawley Dec. at Exhibit 16, 1, 18, 2, Sjoberg Dep. Tr. at 13; Alessi Dep. Tr. at 34; GIUFFRE000105 at 5758; GIUFFRE000241-242 at p. 212-213; Austrich Dep. Tr. at 34-35, 100-101, 127-128; Alessi Dep. Tr. at 34:1935:3; 98:5-98:12; 104:15-104:23. * See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 214:14-215:3. 64

Case 18-2868, Document 280, 08/09/2019, 2628232, Page73 of 74 massage, and converted her into a traveling sex slave, consistent with Defendant and Epstein’s pattern and practice. As the Court astutely acknowledged early on, “at the center of this case is the veracity of a contextual world of facts more broad than the allegedly defamatory statements . . . either transgression occurred or it did not. Either Maxwell was involved or she was not.” If Defendant was involved, then her January 2015 statement was defamatory. Ms. Giuffre will prove to the jury, through overwhelming evidence, her prior allegations about Defendant’s involvement. The Court should give Ms. Giuffre that opportunity, and deny Defendant’s motion for summary judgment. Ix. CONCLUSION For the foregoing reasons, this Court should deny Defendant’s motion for summary judgment in all respects. Dated: January 31, 2017 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 65

Case 18-2868, Document 280, 08/09/2019, 2628232, Page74 of 74 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-5202 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 31, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10" Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmflaw.com jpagliuca@hmflaw.com /s/ Sigrid S. McCawley Sigrid S. McCawley © This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. 66

Selected docket entries for case 18-2868 Generated: 08/09/2019 09:36:40, Filed Document Description Page Docket Text 08/09/2019 |271 Petition Order FILED 2 JORDER, petition for panel rehearing, or, in the alternative, for rehearing en banc denied, FILED.[2628203] [18-2868] 08/09/2019 |272 Order FILED 3 |ORDER, dated 08/09/2019, directing the Clerk to issue the mandate forthwith, by JAC, RSP, CFD, FILED.[2628208] [18-2868] 08/09/2019 [273 SUDGMENT MANDATE, ISSUED.[2628218] [18-2868] 1273 Judgment Mandate ISSUED 5 273 Supporting Document 6 273 Supporting Document 31 08/09/2019 NOTICE, unsealed Summary Judgment Record, appendices 1 —13, docketed pursuant to the Court's decision dated July 3, 2019, see case number 18-2868, SENT .[2628222] [18-2868] 08/09/2019 |275 UNSEALED SUMMARY 32 JUNSEALED SUMMARY JUDGMENT RECORD, JUDGMENT RECORD, appendix | of 13 , pursuant to the Court's decision dated IDOCKETED July 3, 2019, DOCKETED. [2628223] [18-2868] 08/09/2019 |276 UNSEALED SUMMARY 50 [UNSEALED SUMMARY JUDGMENT RECORD, JUDGMENT RECORD, appendix 2 of 13 , pursuant to the Court's decision dated IDOCKETED July 3, 2019, DOCKETED. [2628224] [18-2868] 08/09/2019 |277 UNSEALED SUMMARY 127 JUNSEALED SUMMARY JUDGMENT RECORD, JUDGMENT RECORD, appendix 3 of 13 , pursuant to the Court's decision dated IDOCKETED July 3, 2019, DOCKETED. [2628225] [18-2868]

Case 18-2868, Document 271, 08/09/2019, 2628203, Pagel of 1 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 9" day of August, two thousand nineteen. Julie Brown, Miami Herald Media Company, Intervenors - Appellants. v. ORDER a Docket No: 18-2868 Ghislaine Maxwell, Defendant - Appellee, v. Virginia L. Giuffre, Plaintiff - Appellee. Appellee, Ghislaine Maxwell, filed a petition for panel rehearing, or, in the alternative, for rehearing en banc. The panel that determined the appeal has considered the request for panel rehearing, and the active members of the Court have considered the request for rehearing en banc. IT IS HEREBY ORDERED that the petition is denied. FOR THE COURT: Catherine O'Hagan Wolfe, Clerk

Case 18-2868, Document 272, 08/09/2019, 2628208, Pagel of 2 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT At a Stated Term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 9" day of August, two thousand nineteen. Before: José A. Cabranes, Rosemary S. Pooler, Christopher F. Droney, Circuit Judges. Julie Brown, Miami Herald Media Company, ORDER Intervenors - Appellants, Vv. 18-2868 Ghislaine Maxwell, Defendant - Appellee, v. Virginia L. Giuffre, Plaintiff - Appellee. Alan M. Dershowitz, Michael Cernovich, DBA Cernovich Media, 16-3945(L) 17-1625(Con) Intervenors - Appellants, 17-1722(Con) v. Virginia L. Giuffre, Plaintiff - Appellee, v. Ghislaine Maxwell, Defendant-Appellee.

Case 18-2868, Document 272, 08/09/2019, 2628208, Page2 of 2 IT IS HEREBY ORDERED that the Clerk is directed to issue the mandate forthwith. For the Court: Catherine O’Hagan Wolfe, Clerk of Court

Case 18-2868, Document 273-1, 08/09/2019, 2628218, Page1 of 1 UNITED STATES COURT OF APPEALS FOR THE CIRCUIT AWIBtd Unifed Stites Court of Appeals for the Second Circuit, held at the Th od Mar: nifed Stas CBurth| (0 Foley Square, in the City of New York, on the 3™ day of July, two thousand and nineteen. Before: José A. Cabranes, Rosemary S. Pooler, Christopher F. Droney, Circuit Judges. Julie Brown, Miami Herald Media Company, JUDGMENT Intervenors - Appellants. Docket Nos. 18-2868 v. Ghislaine Maxwell, Defendant - Appellee, v. Virginia L. Giuffre, Plaintiff - Appellee. The appeal in the above captioned case from a judgment of the United States District Court for the Southern District of New York was argued on the district court’s record and the parties’ briefs. Upon consideration thereof, IT IS HEREBY ORDERED, ADJUDGED and DECREED that the orders of the District Court entered on November 2, 2016, May 3, 2017, and August 27, 2018 are VACATED. The Court further ORDERS the unsealing of the summary judgment record as described in its opinion. The case is REMANDED to the District Court for a particularized review of the remaining materials. For the Court: Catherine O’Hagan Wolfe, Clerk of Court A True Copy

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page1 of 25 18-2868; 16-3945-cv(L) Brown v. Maxwell; Dershowitz v. Giuffre In the Gnited States Court of Appeals for the Second Circuit AUGUST TERM 2018 No. 18-2868-cv JULIE BROWN, MIAMI HERALD COMPANY, Intervenors-Appellants, GHISLAINE MAXWELL, Defendant-Appellee, VIRGINIA L. GIUFFRE, Plaintiff-Appellee. No. 16-3945-cv(L) No. 17-1625 (CON) No. 17-1722(CON) ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA, Intervenors-Appellants,

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page2 of 25 Vv. VIRGINIA L. GIUFFRE, Plaintiff-Appellee, GHISLAINE MAXWELL, Defendant-Appellee.” On Appeal from the United States District Court for the Southern District of New York ARGUED: MARCH 6, 2019 DECIDED: JULY 3, 2019 Before: CABRANES, POOLER, and DRONEY, Circuit Judges. Intervenors-Appellants Alan Dershowitz, Michael Cernovich, and the Miami Herald Company (with reporter Julie Brown) appeal from certain orders of the United States District Court for the Southern District of New York (Robert W. Sweet, Judge) denying their respective motions to unseal filings in a defamation suit. We conclude that the * The Clerk of Court is directed to amend the captions as set out above.

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page3 of 25 District Court failed to conduct the requisite particularized review when ordering the sealing of the materials at issue. At the same time, we recognize the potential damage to privacy and reputation that may accompany public disclosure of hard-fought, sensitive litigation. We therefore clarify the legal tools that district courts should use in safeguarding the integrity of their dockets. Accordingly, we VACATE the District Court’s orders entered on November 2, 2016, May 3, 2017, and August 27, 2018, ORDER the unsealing of the summary judgment record as described further herein, and REMAND the cause to the District Court for particularized review of the remaining sealed materials. Judge Pooler concurs in this opinion except insofar as it orders the immediate unsealing of the summary judgment record without a remand. SANFORD L. BOHRER (Christine N. Walz, Madelaine J. Harrington, New York, NY, on the brief), Holland & Knight LLP, Miami, FL, for Intervenors-Appellants Julie Brown and Miami Herald. Ty GEE (Adam Mueller, on the brief), Haddon, Morgan and Foreman, P.C., Denver, CO, for Defendant-Appellee Ghislaine Maxwell.

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page4 of 25 PAUL G. CASSELL (Sigrid S. McCawley, Boies Schiller Flexner LLP, Ft. Lauderdale, FL, on the brief), S.J Quinney College of Law, University of Utah, Salt Lake City, UT, for Plaintiff-Appellee Virginia L. Giuffre. ANDREW G. CELLI JR. (David A. Lebowitz, on the brief), Emery, Celli, Brinckerhoff & Abady LLP, New York, NY, for IntervenorAppellant Alan M. Dershowitz. MARC RANDAZZA (Jay Marshall Wolman, Las Vegas, NV, on the brief), Randazza Legal Group, PLLC, Hartford, CT, for IntervenorAppellant Michael Cernovich. JOSE A. CABRANES, Circuit Judge: Intervenors-Appellants Alan M. Dershowitz (“Dershowitz”), Michael Cernovich (“Cernovich”), and the Miami Herald Company (with reporter Julie Brown, jointly the “Herald’’) appeal from certain orders of the United States District Court for the Southern District of New York (Robert W. Sweet, Judge) denying their respective motions to unseal filings in a defamation suit. We conclude that the District Court failed to conduct the requisite particularized review when ordering the sealing of the materials at issue. At the same time, we

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page5 of 25 recognize the potential damage to privacy and reputation that may accompany public disclosure of hard-fought, sensitive litigation. We therefore clarify the legal tools that district courts should use in safeguarding the integrity of their dockets. Accordingly, we VACATE the District Court’s orders entered on November 2, 2016, May 3, 2017, and August 27, 2018, ORDER the unsealing of the summary judgment record as described further herein, and REMAND the cause to the District Court for particularized review of the remaining sealed materials. L BACKGROUND A. Jeffrey Epstein’s Conviction and the CVRA Suit The origins of this case lie in a decade-old criminal proceeding against financier Jeffrey Epstein (“Epstein”). On June 30, 2008, Epstein pleaded guilty to Florida state charges of soliciting, and procuring a person under the age of eighteen for, prostitution. The charges stemmed from sexual activity with privately hired “masseuses,” some of whom were under eighteen, Florida’s age of consent. Pursuant to an agreement with state and federal prosecutors, Epstein pleaded to the state charges. He received limited jail-time, registered as a sex offender, and agreed to pay compensation to his victims. In return, prosecutors declined to bring federal charges. Shortly after Epstein entered his plea, two of his victims, proceeding as “Jane Doe 1” and “Jane Doe 2,” filed suit against the Government in the Southern District of Florida under the Crime Victims’ Rights Act (“CVRA”). The victims sought to nullify the plea

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page6 of 25 agreement, alleging that the Government failed to fulfill its legal obligations to inform and consult with them in the process leading up to Epstein’s plea deal.! On December 30, 2014, two additional unnamed victims—one of whom has now self-identified as Plaintiff-Appellee Virginia Giuffre (“Giuffre”)— petitioned to join in the CVRA case. These petitioners included in their filings not only descriptions of sexual abuse by Epstein, but also new allegations of sexual abuse by several other prominent individuals, “including numerous prominent American politicians, powerful business executives, foreign presidents, a wellknown Prime Minister, and other world leaders,” as well as Dershowitz (a long-time member of the Harvard Law School faculty who had worked on Epstein’s legal defense) and Defendant-Appellee Ghislaine Maxwell (“Maxwell”).? Dershowitz moved to intervene, seeking to “strike the outrageous and impertinent allegations made against him and to request a show cause order to the attorneys that have made them.” Exercising its authority to “strike from a pleading an insufficient ! On February 21, 2019, the Florida District Court ruled that federal prosecutors had violated the CVRA by failing to adequately notify the two victimsplaintiffs of the plea deal. The District Court has not yet determined the appropriate remedy. See Doe 1 v. United States, 359 F. Supp. 3d 1201, 1204-17 (S.D. Fla. 2019). 2 Doe 1 v. United States, No. 08-CV-80736-KAM, 2015 WL 11254692, at *2 (S.D. Fla. Apr. 7, 2015) (internal quotation marks omitted). 3 Id. (internal quotation marks and brackets omitted).

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page7 of 25 defense or any redundant, immaterial, impertinent, or scandalous matter... on its own,” the Florida District Court (Kenneth A. Marra, Judge) sua sponte struck all allegations against additional parties from the pleadings, including those against Dershowitz, and therefore denied Dershowitz’s motion as moot.> The stricken allegations, however, quickly found their way into the press, and several media outlets published articles repeating Giuffre’s accusations. In response to the allegations, on January 3, 2015, Maxwell’s publicist issued a press statement declaring that Giuffre’s allegations “against Ghislaine Maxwell are untrue” and that her “claims are obvious lies.’”° B. Giuffre Sues Maxwell On September 21, 2015, Giuffre filed the underlying action against Maxwell in the Southern District of New York. Giuffre alleged that Maxwell had defamed her through this and other public statements. Extensive and hard-fought discovery followed. Due to the volume of sealing requests filed during discovery, on August 9, 2016, the District Court entered a Sealing Order that effectively ceded control of the sealing process to the parties themselves. The Sealing Order disposed of the requirement that the parties file individual letter briefs to request sealing and prospectively granted all of the parties’ 4 Fed. R. Civ. P. 12(f). 5 Doe 1, 2015 WL 11254692, at *2-3. 6 See Giuffre v. Maxwell, 325 F. Supp. 3d 428, 434 (S.D.N.Y. 2018).

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Pages of 25 future sealing requests. In total, 167 documents—nearly one-fifth of the docket—were filed under seal. These sealed documents include, inter alia, motions to compel discovery, motions for sanctions and adverse inferences, motions in limine, and similar material. On January 6, 2017, Maxwell filed a motion for summary judgment. The parties submitted their memoranda of law and supporting exhibits contesting this motion under seal. On March 22, 2017, the District Court denied the motion in a heavily redacted 76page opinion. Once again, the entire summary judgment record, including the unredacted version of the District Court opinion denying summary judgment, remained under seal. On May 24, 2017, Maxwell and Giuffre executed a settlement agreement, and the case was closed the next day. C. Motions to Intervene and Unseal Over the course of the litigation before Judge Sweet, three outside parties attempted to unseal some or all of the sealed material. On August 11, 2016, Dershowitz moved to intervene, seeking to unseal three documents that, he argues, demonstrate that Giuffre invented the accusations against him. On January 19, 2017, Cernovich, an independent blogger and_ self-described “popular political journalist,”? moved to intervene, seeking to unseal the summary judgment record, and Dershowitz joined his motion. On April 6, 2018, after the case had settled, the Herald moved to intervene and unseal 7 Br. Appellant (Cernovich) 4.

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page9 of 25 the entire docket. The District Court granted each of these motions to intervene, but denied the related requests to unseal in orders entered November 2, 2016, May 3, 2017, and August 27, 2018, respectively. The Appellants timely appealed from each of the orders denying their respective motions to unseal. Although each Appellant seeks the release of a different set of documents, all argue that the District Court failed to analyze the documents individually or properly apply the presumption of public access to court documents. We therefore ordered that the appeals be heard in tandem and held argument on March 6, 2019. On March 11, 2019, we issued an order to show cause why we “should not unseal the summary judgment motion, including any materials filed in connection with this motion, and the District Court’s summary judgment decision.”® The parties timely filed their responses. II. | DISCUSSION There are two categories of sealed material at issue in these appeals: (1) the summary judgment record, which includes the parties’ summary judgment briefs, their statements of undisputed facts, and incorporated exhibits; and (2) court filings made in the course of the discovery process and with respect to motions in limine. In this Opinion, we explain that our law requires the unsealing of the 8 Giuffre v. Maxwell, No. 18-2868-cv, Docket No. 138.

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page10 of 25 summary judgment materials and individualized review of the remaining sealed materials. While the law governing public access to these materials is largely settled, we have not yet adequately addressed the potential harms that often accompany such access. These harms are apparent. Over forty years ago, the Supreme Court observed that, without vigilance, courts’ files might “become a vehicle for improper purposes.”? Our legal process is already susceptible to abuse. Unscrupulous litigants can weaponize the discovery process to humiliate and embarrass their adversaries. Shielded by the “litigation privilege,”!" bad actors can defame opponents in court pleadings or depositions without fear of lawsuit and liability. Unfortunately, the presumption of public access to court documents has the potential to exacerbate these harms to privacy and reputation by ensuring that damaging material irrevocably enters the public record. We therefore take the opportunity to describe the tools available to district courts in protecting the integrity of the judicial process, and emphasize the courts’ responsibility to exercise these powerful tools. We also caution the public to critically assess allegations contained in judicial pleadings. ° Nixon v. Warner Commce'ns, Inc., 435 U.S. 589, 598 (1978). 1 See notes 46-47 and accompanying text, post. 10

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page11 of 25 A. Standard of Review When reviewing a district court’s decision to seal a filing or maintain such a seal, “we examine the court's factual findings for clear error, its legal determinations de novo, and its ultimate decision to seal or unseal for abuse of discretion.””!! B. The Summary Judgment Materials With respect to the first category of materials, it is well-settled that “documents submitted to a court for its consideration in a summary judgment motion are—as a matter of law—judicial documents to which a strong presumption of access attaches, under both the common law and the First Amendment.”? In light of this strong First Amendment presumption, “continued sealing of the documents may be justified only with specific, on-the-record findings that sealing is necessary to preserve higher values and only if the sealing order is narrowly tailored to achieve that aim.” " Bernstein v. Bernstein Litowitz Berger & Grossmann LLP, 814 F.3d 132, 139 (2d Cir. 2016). ? Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 121 (2d Cir. 2006). We observe that our holding in Lugosch relies on the general principle that parties may “be assumed to have supported their papers with admissible evidence and nonfrivolous arguments.” Id. at 122. Insofar as a district court has, through striking a filing, specifically found that assumption inapplicable, the categorical rule in Lugosch may not apply. See notes 42-43 and accompanying text, post. 13 Id. at 124. Examples of such countervailing values may include, depending on the circumstances, preserving “the right of an accused to fundamental fairness in the jury selection process,” Press-Enter. Co. v. Superior Court 11

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page12 of 25 In this case, the District Court erred in several respects." First, it failed to give proper weight to the presumption of access that attaches to documents filed in connection with summary judgment motions. The District Court reasoned that the summary judgment materials were “entitled to a lesser presumption of access” because “summary judgment was denied by the Court.” In assigning a “lesser presumption” to such materials, the District Court relied on a single sentence of dicta from our decision in United States v. Amodeo.'* We have since clarified, however, that this sentence was based on a “quotation from a partial concurrence and partial dissent in the D.C. Circuit .. . [and] is thus not the considered decision of either this court or the D.C. Circuit.” In fact, we have expressly rejected the proposition that “different types of documents might receive different of California, Riverside Cty., 464 U.S. 501, 510 (1984); the protection of attorney-client privilege, Lugosch, 435 F.3d at 125; “the danger of impairing law enforcement or judicial efficiency,” SEC. v. TheStreet.Com, 273 F.3d 222, 232 (2d Cir. 2001); and “the privacy interest of those who resist disclosure,” id. 4 Our discussion here focuses specifically on the District Court's denial of the Herald’s motion to unseal the entire record. Because this decision grants relief to all Appellants, we need not discuss any separate, additional error in the District Court's denial of the earlier motions to unseal. 1 Giuffre, 325 F. Supp. 3d at 444. 1671 F.3d 1044, 1049 (2d Cir. 1995) (“Amodeo II’) (“One judge [in the District of Columbia Circuit] has pointed out, for example, that where a district court denied the summary judgment motion, essentially postponing a final determination of substantive legal rights, the public interest in access is not as pressing.” (internal quotation marks omitted; emphasis in original)). 7 Lugosch, 435 F.3d at 121. 12

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page13 of 25 weights of presumption based on the extent to which they were relied upon in resolving [a] motion [for summary judgment].” Second, in contravention of our precedent, the District Court failed to review the documents individually and produce “specific, onthe-record findings that sealing is necessary to preserve higher values.”!° Instead, the District Court made generalized statements about the record as a whole.” This too was legal error. Finally, upon reviewing the summary judgment materials in connection with this appeal, we find that there is no countervailing privacy interest sufficient to justify their continued sealing. Remand with respect to these documents is thus unnecessary. Accordingly, and to avoid any further delay,?' we order that the summary judgment documents (with minimal redactions) be unsealed upon issuance of our mandate.” 18 Id. at 123. 19 Id. at 124. 2 See, e.g., Giuffre, 325 F. Supp. 3d at 445 (summarily concluding that all “{t]he Summary Judgment Judicial Documents openly refer to and discuss these allegations [of sexual assault and sexual trafficking] in comprehensive detail, and that those allegations “establish{] a strong privacy interest here”). 21 Cf. Lugosch, 435 F.3d at 127 (ordering that “the mandate shall issue forthwith” to expedite the unsealing process). » Upon issuance of our mandate, a minimally redacted version of the summary judgment record will be made accessible on the Court of Appeals docket. We have implemented minimal redactions to protect personally identifying information such as personal phone numbers, contact lists, birth dates, and social 13

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page14 of 25 C. The Remaining Sealed Materials The law governing disclosure of the remaining sealed material in this case is only slightly more complex. The Supreme Court has recognized a qualified right “to inspect and copy judicial records and documents.”? In defining “judicial records and documents,” we have emphasized that “the mere filing of a paper or document with the court is insufficient to render that paper a judicial document subject to the right of public access.” Instead, “the item filed must be relevant to the performance of the judicial function and useful in the judicial process in order for it to be designated a judicial document.” As our precedent makes clear, a court “perform[s] the judicial function” not only when it rules on motions currently before it, but also when properly exercising its inherent “supervisory powers.”?6 A security numbers. We have also redacted the names of alleged minor victims of sexual abuse from deposition testimony and police reports, as well as deposition responses concerning intimate matters where the questions were likely only permitted —and the responses only compelled —because of a strong expectation of continued confidentiality. See Fed. R. Civ. P. 5.2. While we appreciate the views expressed in Judge Pooler’s separate opinion, the panel majority believes that the efforts invested by three former district judges in reviewing these materials adequately address those concerns. 23 Nixon, 435 U.S. at 597-98. 2 United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995) (“Amodeo I’). 3 Id. 26 Cf. United States v. HSBC Bank USA, N.A., 863 F.3d 125, 135 (2d Cir. 2017) (explaining that, in considering whether the report of a monitor charged with assessing compliance with a deferred prosecution agreement is a judicial 14

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page15 of 25 document is thus “relevant to the performance of the judicial function” if it would reasonably have the tendency to influence a district court’s ruling on a motion or in the exercise of its supervisory powers, without regard to which way the court ultimately rules or whether the document ultimately in fact influences the court’s decision.” Accordingly, if in applying these standards, a court determines that documents filed by a party are not relevant to the performance of a judicial function, no presumption of public access attaches.” Once an item is deemed relevant to the exercise of judicial power, “the weight to be given the presumption of access must be governed by the role of the material at issue in the exercise of Article III judicial power and the resultant value of such information to those document, “[i]f the district court’s conception of its supervisory power in this context were correct, the Monitor’s Report would quite obviously be relevant to the performance of the judicial function and useful in the judicial process” (internal quotation marks omitted)). Whether a specific judicial decision constitutes a “performance of the judicial function” is a question of law. Accordingly, we review such determinations de novo. Id. at 134. 27 Amodeo I, 44 F.3d at 145-46 (concluding that documents were relevant to the performance of a judicial function because they would have “informed” the district court’s decision whether to discharge or retain a Receiver); see also FTC. v. Standard Fin. Mgmt. Corp., 830 F.2d 404, 409 (1st Cir. 1987) (citing Federal Rule of Evidence 401’s “having any tendency” definition of relevance in determining whether documents were “judicial documents”). 2s As we explain below, there are several (often preferable) tools beyond sealing that district courts can use to protect their dockets from becoming a vehicle for irrelevant—and potentially defamatory —accusations. See Section D, post. 15

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page16 of 25 monitoring the federal courts.””? Thus, while evidence introduced at trial or in connection with summary judgment enjoys a strong presumption of public access, documents that “play only a negligible role in the performance of Article III duties” are accorded only a low presumption that “amounts to little more than a prediction of public access absent a countervailing reason.”*° Documents that are never filed with the court, but simply “passed between the parties in discovery, lie entirely beyond the presumption’s reach.”*! The remaining sealed materials at issue here include filings related to, inter alia, motions to compel testimony, to quash trial subpoenae, and to exclude certain deposition testimony. All such motions, at least on their face, call upon the court to exercise its Article III powers. Moreover, erroneous judicial decision-making with respect to such evidentiary and discovery matters can cause substantial harm. Such materials are therefore of value “to those monitoring the federal courts.”%2 Thus, all documents submitted in connection with, and relevant to, such judicial decision-making are subject to at least some presumption of public access. 29 Amodeo II, 71 F.3d at 1049. 30 Id. at 1050. Id. * Id. at 1049. % In previous decisions, we have identified an important exception to this general rule: the presumption of public access does not apply to material that is submitted to the court solely so that the court may decide whether that same 16

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page17 of 25 Although a court’s authority to oversee discovery and control the evidence introduced at trial surely constitutes an exercise of judicial power, we note that this authority is ancillary to the court’s core role in adjudicating a case. Accordingly, the presumption of public access in filings submitted in connection with discovery disputes or motions in lintine is generally somewhat lower than the presumption applied to material introduced at trial, or in connection with dispositive motions such as motions for dismissal or summary judgment.* Thus, while a court must still articulate specific and substantial reasons for sealing such material, the reasons usually need not be as compelling as those required to seal summary judgment filings. Here, the precise basis for the District Court’s decision to deny the motion to unseal these remaining materials is unclear. In the three paragraphs devoted to the issue, the District Court emphasized the potential for embarrassment “given the highly sensitive nature of the underlying allegations,” and concluded that “the documents sealed in the course of discovery were neither relied upon by [the District] Court in the rendering of an adjudication, nor necessary to or helpful in resolving a motion.”* It is therefore unclear whether the District Court held that these materials were not judicial documents (and thus are material must be disclosed in the discovery process or shielded by a Protective Order. See TheStreet.Com, 273 F.3d at 233. * Amodeo II, 71 F.3d at 1049-50. % Giuffre, 325 F. Supp. 3d. at 442 (internal quotation marks and brackets omitted). 17

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page18 of 25 not subject to a presumption of public access), or found that privacy interests outweighed a limited right of public access. On either interpretation, however, the District Court’s holding was error. Insofar as the District Court held that these materials are not judicial documents because it did not rely on them in adjudicating a motion, this was legal error. As explained above, the proper inquiry is whether the documents are relevant to the performance of the judicial function, not whether they were relied upon. Indeed, decisionmakers often find that a great deal of relevant material does not ultimately sway their decision. And insofar as the District Court held that privacy interests outweigh the presumption of public access in each of the thousands of pages at issue, that decision— which appears to have been made without particularized review—amounts to an abuse of discretion.%” In light of the District Court’s failure to conduct an individualized review of the sealed materials, it is necessary to do so now. We believe the District Court is best situated to conduct this review. The District Court can directly communicate with the parties, and can therefore more swiftly and thoroughly consider particular objections to unsealing specific materials. Relatedly, the District Court can obtain the parties’ assistance in effecting any necessary redactions, and in notifying any outside parties whose privacy interests might be % See text accompanying notes 12-18 and 26-28, ante. 37 See In re City of New York, 607 F.3d 923, 943 n.21 (2d Cir. 2010) (explaining that “abuse of discretion” is a nonpejorative, legal “term of art”). 18

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page19 of 25 implicated by the unsealing. Accordingly, we remand the cause to the District Court to conduct such a particularized review and unseal all documents for which the presumption of public access outweighs any countervailing privacy interests. D. Protecting the Integrity of Judicial Proceedings While we disagree with the District Court’s disposition of the motions to unseal, we share its concern that court files might be used to “promote scandal arising out of unproven potentially libelous statements.”°° We therefore describe certain methods courts can employ to protect the judicial process from being coopted for such purposes. The Supreme Court has explained that “[e]very court has supervisory power over its own records and files” to ensure they “are not used to gratify private spite or promote public scandal” or “serve as reservoirs of libelous statements for press consumption.”*? This supervisory function is not only within a district court’s power, but also among its responsibilities. In practice, district courts may employ several methods to fulfill this function. They may, for instance, issue protective orders forbidding dissemination of certain material “to protect a party or person from annoyance, embarrassment, oppression, or undue 38 Giuffre, 325 F. Supp. 3d at 447. % Nixon, 435 U.S. at 598 (internal quotation marks). 19

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page20 of 25 burden” and require that filings containing such material be submitted under seal.” If parties then seek to file such materials, the court may deny them leave to do so.*! District courts may also seek to counteract the effect of defamatory statements by explaining on the record that the statements appear to lack credibility. Moreover, under Federal Rule of Civil Procedure 12(f), the district court may strike such material from the filings on the grounds that it is “redundant, immaterial, impertinent, or scandalous.”*? Because such rejected or stricken material is not “relevant to the performance of the judicial function” it would not be considered a “judicial document” and would enjoy no presumption of public access.# Finally, in appropriate 40 Fed. R. Civ. P. 26(c); see also TheStreet.Com, 273 F.3d at 229-30. 4! See, e.g., S.D.N.Y. Electronic Case Filing Rules & Instructions, February 1, 2019 Edition, Rule 6.1, http://nysd.uscourts.gov/ecf/ECF%20Rules%20020119%20Final.pdf. ” Fed. R. Civ. P. 12(f). Courts may strike material from the pleadings either “on its own” or “on motion made by a party.” Id. Although motions to strike material solely “on the ground that the matter is impertinent and immaterial” are disfavored, when material is also “scandalous,” no such presumption applies. Cf. Lipsky v. Commonwealth United Corp., 551 F.2d 887, 893 (2d Cir. 1976); see also Talbot v. Robert Matthews Distrib. Co. 961 F.2d 654, 664 (7th Cir. 1992) (“Allegations may be stricken as scandalous if the matter bears no possible relation to the controversy or may cause the objecting party prejudice.”); Wine Markets Int'l, Inc. v. Bass, 177 F.R.D. 128, 133 (E.D.N.Y. 1998) (“Motions to strike are not generally favored, except in relation to scandalous matters.”); Alvarado-Morales v. Digital Equip. Corp., 843 F.2d 613, 617-18 (1st Cir. 1988) (categorizing as scandalous “matter which impugned the character of defendants”). 43 Amodeo I, 44 F.3d at 145. 20

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page21 of 25 circumstances, district courts may impose sanctions on attorneys and parties under Federal Rule of Civil Procedure 11(c).## E. A Cautionary Note We conclude with a note of caution to the public regarding the reliability of court filings such as those unsealed today. Materials submitted by parties to a court should be understood for what they are. They do not reflect the court’s own findings. Rather, they are prepared by parties seeking to advance their own interests in an adversarial process. Although affidavits and depositions are offered “under penalty of perjury,” it is in fact exceedingly rare for anyone to be prosecuted for perjury in a civil proceeding.* Similarly, “In relevant part, Rule 11 provides: By presenting to the court a pleading, written motion, or other paper... an attorney or unrepresented party certifies that . . . it is not being presented for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation . . . . [T]he court may impose an appropriate sanction on any attorney, law firm, or party that violated the tule or is responsible for the violation . . . . The sanction may include nonmonetary directives; an order to pay a penalty into court; or, if imposed on motion and warranted for effective deterrence, an order directing payment to the movant of part or all of the reasonable attorney’s fees and other expenses directly resulting from the violation. Fed. R. Civ. P. 11. See also Amodeo II, 71 F.3d at 1049 (describing sanctions available to the court). 45 Sonia Sotomayor & Nicole A. Gordon, Returning Majesty to the Law and Politics: A Modern Approach, 30 Suffolk U. L. Rev. 35, 47 n.52 (1996) (‘Perjury cases are not often pursued . .. .”). 21

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page22 of 25 pleadings, complaints, and briefs—while supposedly based on underlying evidentiary material —can be misleading. Such documents sometimes draw dubious inferences from already questionable material or present ambiguous material as definitive. Moreover, court filings are, in some respects, particularly susceptible to fraud. For while the threat of defamation actions may deter malicious falsehoods in standard publications, this threat is nonexistent with respect to certain court filings. This is so because, under New York law (which governs the underlying defamation claim here), “absolute immunity from liability for defamation exists for oral or written statements made . . . in connection with a proceeding before a court.” Thus, although the act of filing a document with a court might be thought to lend that document additional credibility, in fact, allegations appearing in such documents might be less credible than those published elsewhere.” 46 Front, Inc. v. Khalil, 24 N.Y.3d 713, 718 (2015); see also Kelly v. Albarino, 485 F.3d 664, 666 (2d Cir. 2007) (adopting the reasoning of the District Court explaining that this privilege is “the broadest of possible privileges”); Restatement (Second) of Torts § 587 (1977) (“A party to a private litigation or a private prosecutor or defendant in a criminal prosecution is absolutely privileged to publish defamatory matter concerning another in communications preliminary to a proposed judicial proceeding, or in the institution of or during the course and as a part of, a judicial proceeding in which he participates, if the matter has some relation to the proceeding.”). But see note 47, post. *” While common law courts have generally interpreted the litigation privilege broadly, they nevertheless maintain an important (if rarely implemented) limitation on its scope: to qualify for the privilege, a statement must be “material and pertinent to the questions involved.” Front, 24 N.Y.3d at 718 (quoting Youmans 22

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page23 of 25 We have long noted that the press plays a vital role in ensuring the public right of access and in enhancing “the quality and safeguards the integrity of the factfinding process.’”** When faithfully observing its best traditions, the print and electronic media “contributes to public understanding of the rule of law” and “validates [its] claim of functioning as surrogates for the public.’ At the same time, the media does the public a profound disservice when it reports on parties’ allegations uncritically. We have previously observed that courts cannot possibly “discredit every statement or document turned up in the course of litigation,” and we have criticized “the use by the media of the somewhat misleading term ‘court records’ in referring to such items.”°? Even ordinarily critical v. Smith, 153 N.Y. 214, 219-20 (1897)). It follows, then, that immaterial and impertinent statements are (at least nominally) actionable, particularly when they are “so needlessly defamatory as to warrant the inference of express malice.” Id. (same). It seems to us that when a district court strikes statements from the record pursuant to Fed. R. Civ. P. 12(f) on the ground that the matter is “impertinent” and “immaterial,” it makes the very same determination that permits a defamation action under the common law. We think the judicial system would be well served were our common law courts to revitalize this crucial qualification to the litigation privilege. 48 Westmoreland v. Columbia Broad. Sys., Inc., 752 F.2d 16, 23 (2d Cir. 1984) (quoting Globe Newspaper Co. v. Superior Court for Norfolk Cty., 457 U.S. 596, 606 (1982)). * Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 572-73 (1980) (plurality opinion) (internal quotation marks omitted). 50 Amodeo II, 71 F.3d at 1049. 23

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page24 of 25 readers may take the reference to “court papers” as some sort of marker of reliability. This would be a mistake. We therefore urge the media to exercise restraint in covering potentially defamatory allegations, and we caution the public to read such accounts with discernment. III. CONCLUSION To summarize, we hold as follows: (1) Materials submitted in connection with a motion for summary judgment are subject to a strong presumption of public access. (2) The summary judgment record at issue will be unsealed upon issuance of our mandate, subject to minimal redactions.*! (3) Materials submitted in connection with, and relevant to, discovery motions, motions in limine, and other nondispositive motions are subject to a lesser—but still substantial— presumption of public access. (4) The District Court is directed to review the remaining sealed materials individually and unseal those materials as appropriate. 51 See note 22, ante. 24

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page25 of 25 (5) District courts should exercise the full range of their substantial powers to ensure their files do not become vehicles for defamation. For the foregoing reasons, we VACATE the orders of the District Court entered on November 2, 2016, May 3, 2017, and August 27, 2018, ORDER the unsealing of the summary judgment record as described herein, and REMAND the cause to the District Court for particularized review of the remaining materials. In undertaking this task, the District Court may be well-served by ordering the parties to submit to the Court unredacted, electronic copies of the remaining sealed materials, as well as specific, proposed redactions. The District Court may also order the parties to identify and notify additional parties whose privacy interests would likely be implicated by disclosure of these materials. In the interests of judicial economy, any future appeal in this matter shall be referred to this panel. 25

Case 18-2868, Document 273-3, 08/09/2019, 2628218, Pagel of 1 POOLER, Circuit Judge, dissenting in part: Ijoin the Court’s opinion in every respect but one: the decision to unseal the summary judgment record ourselves. I agree that all or most of the material must be unsealed. Nevertheless, in my view, the district court is better suited to the task. As the Court’s opinion recognizes in connection with the remaining sealed materials, the district court is better positioned to communicate with the parties and any nonparties whose privacy interests might be affected by unsealing. On that score, it is worth clarifying here the breadth of the Court’s unsealing order: it unseals nearly 2000 pages of material. The task of identifying and making specific redactions in such a substantial volume is perilous; the consequences of even a seemingly minor error may be grave and are irrevocable. Moreover, although I share the majority’s concern about avoiding delay, I would alleviate that concern through other means—perhaps with an order directing the district court to act expeditiously and by making clear what types of limited redactions are and are not appropriate. In sum, I would unseal the district court's summary judgment decision only and leave the remainder of the materials for the district court to review, redact, and unseal on remand.

Case 18-2868, Document 275, 08/09/2019, 2628223, Pagel of 18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Se a Secs Sete Sens sentence eee xX VIRGINIA L. GIUFFRE, i Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. Saeco e 4 DEFENDANT’S STATEMENT OF MATERIAL UNDISPUTED FACTS PURSUANT TO LOCAL CIVIL RULE 56.1 Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. 150 East 10" Avenue Denver, CO 80203 303.831.7364

Case 18-2868, Document 275, 08/09/2019, 2628223, Page2 of 18 Pursuant to Rule 56.1 of the Local Civil Rules of this Court, defendant Ghislaine Maxwell submits this statement of the material facts as to which she contends there is no genuine issues to be tried. Ms. Maxwell expressly preserves all of her objections to the admissibility of the evidence cited herein and in the accompanying memoranda of law and does not waive any objections by making this submission. numbered. 1. Ms. Maxwell’s response to publications of plaintiff’s false allegations: the March 2011 statement. In early 2011 plaintiff in two British tabloid interviews made numerous false and defamatory allegations against Ms. Maxwell. In the articles, plaintiff made no direct allegations that Ms. Maxwell was involved in any improper conduct with Jeffrey Epstein, who had pleaded guilty in 2007 to procuring a minor for prostitution. Nonetheless, plaintiff suggested that Ms. Maxwell worked with Epstein and may have known about the crime for which he was convicted. 2. In the articles, plaintiff alleged she had sex with Prince Andrew, “a well-known businessman,” a “world-renowned scientist,” a “respected liberal politician,” and a “foreign head of state.” 3. In response to the allegations Ms. Maxwell’s British attorney, working with Mr. Gow, issued a statement on March 9, 2011, denying “the various allegations about [Ms. Maxwell] that have appeared recently in the media. These allegations are all entirely false.” 4. The statement read in full: Statement on Behalf of Ghislaine Maxwell By Devonshires Solicitors, PRNE Wednesday, March 9, 2011 London, March 10, 2011 - Ghislaine Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are all entirely false.

Case 18-2868, Document 275, 08/09/2019, 2628223, Page3 of 18 It is unacceptable that letters sent by Ms Maxwell’s legal representatives to certain newspapers pointing out the truth and asking for the allegations to be withdrawn have simply been ignored. In the circumstances, Ms Maxwell is now proceeding to take legal action against those newspapers. “T understand newspapers need stories to sell copies. It is well known that certain newspapers live by the adage, “why let the truth get in the way of a good story.” However, the allegations made against me are abhorrent and entirely untrue and Lask that they stop,” said Ghislaine Maxwell. “A number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name,” she said. Media contact: Ross Gow Acuity Reputation Tel: +44-203-008-7790 Mob: +44-7778-755-251 Email: ross@acuityreputation.com Media contact: Ross Gow, Acuity Reputation, Tel: +44-203008-7790, Mob: +44-7778-755-251, Email: ross at acuityreputation.com 5. Plaintiff’s gratuitous and “lurid” accusations in an unrelated action. In 2008 two alleged victims of Epstein brought an action under the Crime Victims’ Rights Act against the United States government purporting to challenge Epstein’s plea agreement. They alleged the government violated their CVRA rights by entering into the agreement. 6. Seven years later, on December 30, 2014, Ms. Giuffre moved to join the CVRA action, claiming she, too, had her CVRA rights violated by the government. On January 1, 2015, Ms. Giuffre filed a “corrected” joinder motion. 7. The issue presented in her joinder motion was narrow: whether she should be permitted to join the CVRA action as a party under Federal Rule of Civil Procedure 21, specifically, whether she was a “known victim[] of Mr. Epstein and the Government owed them CVRA duties.” Yet, “the bulk of the [motion] consists of copious factual details that [plaintiff] and [her co-movant] ‘would prove . . . if allowed to join.” Ms. Giuffre gratuitously included 2

Case 18-2868, Document 275, 08/09/2019, 2628223, Page4 of 18 provocative and “lurid details” of her alleged sexual activities as an alleged victim of sexual trafficking. 8. At the time they filed the motion, Ms. Giuffre and her lawyers knew that the media had been following the Epstein criminal case and the CVRA action. While they deliberately filed the motion without disclosing Ms. Giuffre’s name, claiming the need for privacy and secrecy, they made no attempt to file the motion under seal. Quite the contrary, they filed the motion publicly. 9. As the district court noted in ruling on the joinder motion, Ms. Giuffre “name[d] several individuals, and she offers details about the type of sex acts performed and where they took place.” The court ruled that “these lurid details are unnecessary”: “The factual details regarding whom and where the Jane Does engaged in sexual activities are immaterial and impertinent . . ., especially considering that these details involve non-parties who are not related to the respondent Government.” Accordingly, “[t]hese unnecessary details shall be stricken.” Id. The court then struck all Ms. Giuffre’s factual allegations relating to her alleged sexual activities and her allegations of misconduct by non-parties. The court said the striking of the “lurid details” was a sanction for Ms. Giuffre’s improper inclusion of them in the motion. 10. The district court found not only that the “lurid details” were unnecessary but also that the entire joinder motion was “entirely unnecessary.” Ms. Giuffre and her lawyers knew the motion with all its “lurid details” was unnecessary because the motion itself recognized that she would be able to participate as a fact witness to achieve the same result she sought as a party. The court denied plaintiff's joinder motion. 11. One of the non-parties Ms. Giuffre “named” repeatedly in the joinder motion was Ms. Maxwell. According to the “lurid details” of Ms. Giuffre included in the motion,

Case 18-2868, Document 275, 08/09/2019, 2628223, Paged of 18 Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by Epstein: Ms. Maxwell “approached” plaintiff in 1999 when plaintiff was “fifteen years old” to recruit her into the scheme. Ms. Maxwell was “one of the main women” Epstein used to “procure underaged girls for sexual activities.” Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme. She “persuaded” plaintiff to go to Epstein’s mansion “in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children.” At the mansion, when plaintiff began giving Epstein a massage, he and Ms. Maxwell “turned it into a sexual encounter.” Epstein “with the assistance of’ Ms. Maxwell “converted [plaintiff] into ...a “sex slave.’” Id. Plaintiff was a “sex slave” from “about 1999 through 2002.” Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.” Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea agreement, because the immunity protected her from prosecution “for the crimes she committed in Florida.” Ms. Maxwell “participat[ed] in the sexual abuse of [plaintiff] and others.” Ms. Maxwell “took numerous sexually explicit pictures of underage girls involved in sexual activities, including [plaintiff].” Jd. She shared the photos with Epstein. As part of her “role in Epstein’s sexual abuse ring,” Ms. Maxwell “connect[ed]” Epstein with “powerful individuals” so that Epstein could traffick plaintiff to these persons. Plaintiff was “forced to have sexual relations” with Prince Andrew in “TMs. Maxwell’s] apartment” in London. Ms. Maxwell “facilitated” plaintiff's sex with Prince Andrew “by acting as a ‘madame’ for Epstein.” Ms. Maxwell “assist[ed] in internationally trafficking” plaintiff and “numerous other young girls for sexual purposes.” Plaintiff was “forced” to watch Epstein, Ms. Maxwell and others “engage in illegal sexual acts with dozens of underage girls.”

Case 18-2868, Document 275, 08/09/2019, 2628223, Page6 of 18 12. In the joinder motion, plaintiff also alleged she was “forced” to have sex with Harvard law professor Alan Dershowitz, “model scout” Jean Luc Brunel, and “many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.” 13. Plaintiff said after serving for four years as a “sex slave,” she “managed to escape to a foreign country and hide out from Epstein and his co-conspirators for years.” 14. Plaintiff suggested the government was part of Epstein’s “conspiracy” when it “secretly” negotiated a non-prosecution agreement with Eptstein precluding federal prosecution of Epstein and his “co-conspirators.” The government’s secrecy, plaintiff alleged, was motivated by its fear that plaintiff would raise “powerful objections” to the agreement that would have “shed tremendous public light on Epstein and other powerful individuals. 15. Notably, the other “Jane Doe” who joined plaintiff's motion who alleged she was sexually abused “many occasions” by Epstein was unable to corroborate any of plaintiff's allegations. 16. Also notably, in her multiple and lengthy consensual interviews with Ms. Churcher three years earlier, plaintiff told Ms. Churcher of virtually none of the details she described in the joinder motion. 17. Ms. Maxwell’s response to plaintiff’s “lurid” accusations: the January 2015 statement. As plaintiff and her lawyers expected, before District Judge Marra in the CVRA action could strike the “lurid details” of plaintiff's allegations in the joinder motion, members of the media obtained copies of the motion. 18. At Mr. Barden’s direction, on January 3, 2015, Mr. Gow sent to numerous representatives of British media organizations an email containing “a quotable statement on

Case 18-2868, Document 275, 08/09/2019, 2628223, Page7 of 18 behalf of Ms Maxwell.” The email was sent to more than 6 and probably less than 30 media representatives. It was not sent to non-media representatives. 19. Among the media representatives were Martin Robinson of the Daily Mail; P. Peachey of The Independent; Nick Sommerlad of The Mirror; David Brown of The Times; and Nick Always and Jo-Anne Pugh of the BBC; and David Mercer of the Press Association. These representatives were selected based on their request—after the joinder motion was filed—for a response from Ms. Maxwell to plaintiff's allegations in the motion. 20. The email to the media members read: To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts—so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. 21. Mr. Barden, who prepared the January 2015 statement, did not intend it as a traditional press release solely to disseminate information to the media. So he intentionally did not pass it through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation.

Case 18-2868, Document 275, 08/09/2019, 2628223, Page8 of 18 22. The January 2015 statement served two purposes. First, Mr. Barden intended that it mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of plaintiff's false allegations. He believed these ends could be accomplished by suggesting to the media that, among other things, they should subject plaintiff's allegations to inquiry and scrutiny. For example, he noted in the statement that plaintiff's allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicised as news.” 23. Second, Mr. Barden intended the January 2015 statement to be “a shot across the bow” of the media, which he believed had been unduly eager to publish plaintiff's allegations without conducting any inquiry of their own. Accordingly, in the statement he repeatedly noted that plaintiff's allegations were “defamatory.” In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiff's obviously false allegations and the legal indefensibility of their own conduct. 24. Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms Maxwell” (emphasis supplied). The statement was intended to be a single, one-time-only, comprehensive response—quoted in full—to plaintiff's December 30, 2014, allegations that would give the media Ms. Maxwell’s response. The purpose of the prefatory statement was to inform the mediarecipients of this intent. 25. Plaintiff’s activities to bring light to the rights of victims of sexual abuse. Plaintiff has engaged in numerous activities to bring attention to herself, to the prosecution and punishment of wealthy individuals such as Epstein, and to her claimed interest of bringing light to the rights of victims of sexual abuse.

Case 18-2868, Document 275, 08/09/2019, 2628223, Page9 of 18 26. Plaintiff created an organization, Victims Refuse Silence, Inc., a Florida corporation, directly related to her alleged experience as a victim of sexual abuse. 27. The “goal” of Victims Refuse Silence “was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse.” Toward this end, plaintiff has “dedicated her professional life to helping victims of sex trafficking.” 28. Plaintiff repeatedly has sought out media organizations to discuss her alleged experience as a victim of sexual abuse. 29. On December 30, 2014, plaintiff publicly filed an “entirely unnecessary” joinder motion laden with “unnecessary,” “lurid details” about being “sexually abused” as a “minor victim[]” by wealthy and famous men and being “trafficked” all around the world as a “sex slave.” 30. The plaintiff's alleged purpose in filing the joinder motion was to “vindicate” her rights under the CVRA, expose the government’s “secretly negotiated” “non-prosecution agreement” with Epstein, “shed tremendous public light” on Epstein and “other powerful individuals” that would undermine the agreement, and support the CVRA plaintiffs’ request for documents that would show how Epstein “used his powerful political and social connections to secure a favorable plea deal” and the government’s “motive” to aid Epstein and his “coconspirators.” 31. Plaintiff has written the manuscript of a book she has been trying to publish detailing her alleged experience as a victim of sexual abuse and of sex trafficking in Epstein’s alleged “sex scheme.”

Case 18-2868, Document 275, 08/09/2019, 2628223, Page10 of 18 32. Republication alleged by plaintiff. Plaintiff was required by Interrogatory No. 6 to identify any false statements attributed to Ms. Maxwell that were “‘published globally, including within the Southern District of New York,” as plaintiff alleged in Paragraph 9 of Count I of her complaint. In response, plaintiff identified the January 2015 statement and nine instances in which various news media published portions of the January 2015 statement in news articles or broadcast stories. 33. In none of the nine instances was there any publication of the entire January 2015 statement. 34. Ms. Maxwell and her agents exercised no control or authority over any media organization, including the media identified in plaintiffs response to Interrogatory No. 6, in connection with the media’s publication of portions of the January 2015 statement. 35. Plaintiff’s defamation action against Ms. Maxwell. Eight years after Epstein’s guilty plea, plaintiff brought this action, repeating many of the allegations she made in her CVRA joinder motion. 36. The complaint alleged that the January 2015 statement “contained the following deliberate falsehoods”: (a) That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.” (b) That the allegations have been “shown to be untrue.” (c) That Giuffre’s “claims are obvious lies.” 37. Plaintiff lived independently from her parents with her fiancé long before meeting Epstein or Ms. Maxwell. After leaving the Growing Together drug rehabilitation facility in 1999, plaintiff moved in with the family of a fellow patient. There she met, and became engaged to, her friend’s brother, James Michael Austrich. She and Austrich thereafter

Case 18-2868, Document 275, 08/09/2019, 2628223, Page11 of 18 rented an apartment in the Ft. Lauderdale area with another friend and both worked at various jobs in that area. Later, they stayed briefly with plaintiff's parents in the Palm Beach/ Loxahatchee, Florida area before Austrich rented an apartment for the couple on Bent Oak Drive in Royal Palm Beach. Although plaintiff agreed to marry Austrich, she never had any intention of doing so. 38. Plaintiff re-enrolled in high school from June 21, 2000 until March 7, 2002. After finishing the 9" grade school year at Forest Hills High School on June 9, 1999, plaintiff reenrolled at Wellington Adult High School on June 21, 2000, again on August 16, 2000 and on August 14, 2001. On September 20, 2001, Plaintiff then enrolled at Royal Palm Beach High School. A few weeks later, on October 12, 2001, she matriculated at Survivors Charter School. Id. Survivor’s Charter School was an alternative school designed to assist students who had been unsuccessful at more traditional schools. Plaintiff remained enrolled at Survivor’s Charter School until March 7, 2002. She was present 56 days and absent 13 days during her time there. Id. Plaintiff never received her high school diploma or GED. Plaintiff and Figueroa went “back to school” together at Survivor’s Charter School. The school day there lasted from morning until early afternoon. 39. During the year 2000, plaintiff worked at numerous jobs. In 2000, while living with her fiancé, plaintiff held five different jobs: at Aviculture Breeding and Research Center, Southeast Employee Management Company, The Club at Mar-a-Lago, Oasis Outsourcing, and Neiman Marcus. Her taxable earnings that year totaled nearly $9,000. Plaintiff cannot now recall either the Southeast Employee Management Company or the Oasis Outsourcing jobs. 40. Plaintiff’s employment at the Mar-a-Lago spa began in fall 2000. Plaintiff's father, Sky Roberts, was hired as a maintenance worker at the The Mar-a-Lago Club in Palm

Case 18-2868, Document 275, 08/09/2019, 2628223, Page12 of 18 Beach, Florida, beginning on April 11, 2000. Mr. Roberts worked there year-round for approximately 3 years. After working there for a period of time, Mr. Roberts became acquainted with the head of the spa area and recommended plaintiff for a job there. Mar-a-Lago closes every Mother’s Day and reopens on November |. Most of employees Mar-a-Lago, including all employees of the spa area such as “spa attendants,” are “seasonal” and work only when the club is open, i.e., between November | and Mother’s Day. Plaintiff was hired as a “seasonal” spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she had turned 17. 41. Plaintiff represented herself as a masseuse for Jeffrey Epstein. While working at the Mar-a-Lago spa and reading a library book about massage, plaintiff met Ms. Maxwell. Plaintiff thereafter told her father that she got a job working for Jeffrey Epstein as a masseuse. Plaintiff's father took her to Epstein’s house on one occasion around that time, and Epstein came outside and introduced himself to Mr. Roberts. Plaintiff commenced employment as a traveling masseuse for Mr. Epstein. Plaintiff was excited about her job as a masseuse, about traveling with him and about meeting famous people. Plaintiff represented that she was employed as a masseuse beginning in January 2001. Plaintiff never mentioned Ms. Maxwell to her then-fiancé, Austrich. Plaintiff's father never met Ms. Maxwell. 42. Plaintiff resumed her relationship with convicted felon Anthony Figueroa. In spring 2001, while living with Austich, plaintiff lied to and cheated on him with her high school boyfriend, Anthony Figueroa. Plaintiff and Austrich thereafter broke up, and Figueroa moved into the Bent Oak apartment with plaintiff. When Austrich returned to the Bent Oak apartment to check on his pets and retrieve his belongings, Figueroa in Plaintiff's presence punched Austrich in the face. Figueroa and plaintiff fled the scene before police arrived. Figueroa was then a convicted felon and a drug abuser on probation for possession of a controlled substance.

Case 18-2868, Document 275, 08/09/2019, 2628223, Page13 of 18 43. Plaintiff freely and voluntarily contacted the police to come to her aid in 2001 and 2002 but never reported to them that she was Epstein’s “sex slave.” In August 2001 at age 17, while living in the same apartment, plaintiff and Figueroa hosted a party with a number of guests. During the party, according to plaintiff, someone entered plaintiff's room and stole $500 from her shirt pocket. Plaintiff contacted the police. She met and spoke with police officers regarding the incident and filed a report. She did not disclose to the officer that she was a “sex slave.” A second time, in June 2002, plaintiff contacted the police to report that her former landlord had left her belongings by the roadside and had lit her mattress on fire. Again, plaintiff met and spoke with the law enforcement officers but did not complain that she was the victim of any sexual trafficking or abuse or that she was then being held as a “‘sex slave.” 44. From August 2001 until September 2002, Epstein and Maxwell were almost entirely absent from Florida on documented travel unaccompanied by Plaintiff. Flight logs maintained by Epstein’s private pilot Dave Rodgers evidence the substantial number of trips away from Florida that Epstein and Maxwell took, unaccompanied by Plaintiff, between August 2001 and September 2002. Rodgers maintained a log of all flights on which Epstein and Maxwell traveled with him. Epstein additionally traveled with another pilot who did not keep such logs and he also occasionally traveled via commercial flights. For substantially all of thirteen months of the twenty-two months (from November 2000 until September 2002) that Plaintiff lived in Palm Beach and knew Epstein, Epstein was traveling outside of Florida unaccompanied by Plaintiff. During this same period of time, Plaintiff was employed at various jobs, enrolled in school, and living with her boyfriend. 45. Plaintiff and Figueroa shared a vehicle during 2001 and 2002. Plaintiff and Figueroa shared a ’93 white Pontiac in 2001 and 2002. Plaintiff freely traveled around the Palm

Case 18-2868, Document 275, 08/09/2019, 2628223, Page14 of 18 Beach area in that vehicle. In August 2002, Plaintiff acquired a Dodge Dakota pickup truck from her father. Figueroa used that vehicle in a series of crimes before and after Plaintiff left for Thailand. 46. Plaintiff held a number of jobs in 2001 and 2002. During 2001 and 2002, plaintiff was gainfully employed at several jobs. She worked as a waitress at Mannino’s Restaurant, at TGIFriday’s restaurant (aka CCI of Royal Palm Inc.), and at Roadhouse Grill. She also was employed at Courtyard Animal Hospital (aka Marc Pinkwasser DVM). 47. In September 2002, Plaintiff traveled to Thailand to receive massage training and while there, met her future husband and eloped with him. Plaintiff traveled to Thailand in September 2002 to receive formal training as a masseuse. Figueroa drove her to the airport. While there, she initially contacted Figueroa frequently, incurring a phone bill of $4,000. She met Robert Giuffre while in Thailand and decided to marry him. She thereafter ceased all contact with Figueroa from October 2002 until two days before Mr. Figueroa’s deposition in this matter in May 2016. 48. Detective Recarey’s investigation of Epstein failed to uncover any evidence that Ms. Maxwell was involved in sexual abuse of minors, sexual trafficking or production or possession of child pornography. Joseph Recarey served as the lead detective from the Palm Beach Police Department charged with investigating Jeffrey Epstein. That investigation commenced in 2005. Recarey worked only on the Epstein case for an entire year. He reviewed previous officers’ reports and interviews, conducted numerous interviews of witnesses and alleged victims himself, reviewed surveillance footage of the Epstein home, participated in and had knowledge of the search warrant executed on the Epstein home, and testified regarding the case before the Florida state grand jury against Epstein. Detective Recarey’s investigation

Case 18-2868, Document 275, 08/09/2019, 2628223, Page15 of 18 revealed that not one of the alleged Epstein victims ever mentioned Ms. Maxwell’s name and she was never considered a suspect by the government. None of Epstein’s alleged victims said they had seen Ms. Maxwell at Epstein’s house, nor said they had been “recruited by her,” nor paid any money by her, nor told what to wear or how to act by her. Indeed, none of Epstein’s alleged victims ever reported to the government they had met or spoken to Ms. Maxwell. Maxwell was not seen coming or going from the house during the law enforcement surveillance of Epstein’s home. The arrest warrant did not mention Ms. Maxwell and her name was never mentioned before the grand jury. No property belonging to Maxwell, including “sex toys” or “child pornography,” was seized from Epstein’s home during execution of the search warrant. Detective Recarey, when asked to describe “everything that you believe you know about Ghislaine Maxwell’s sexual trafficking conduct,” replied, “I don’t.” He confirmed he has no knowledge about Ms. Maxwell sexually trafficking anybody. Detective Recarey also has no knowledge of Plaintiffs conduct that is subject of this lawsuit. 49. No nude photograph of Plaintiff was displayed in Epstein’s home. Epstein’s housekeeper, Juan Alessi, “never saw any photographs of Virginia Roberts in Mr. Epstein’s house.” Detective Recarey entered Epstein’s home in 2002 to install security cameras to catch a thief and did not observe any “child pornography” within the home, including on Epstein’s desk in his office. 50. Plaintiff intentionally destroyed her “journal” and “dream journal” regarding her “memories” of this case in 2013 while represented by counsel. Plaintiff drafted a “journal” describing individuals to whom she claims she was sexually trafficked as well as her memories and thoughts about her experiences with Epstein. In 2013, she and her husband created a bonfire in her backyard in Florida and burned the journal together with other documents in her

Case 18-2868, Document 275, 08/09/2019, 2628223, Page16 of 18 possession. Jd. Plaintiff also kept a “dream journal” regarding her thoughts and memories that she possessed in January 2016. To date, Plaintiff cannot locate the “dream journal.” 51. Plaintiff publicly peddled her story beginning in 2011. Plaintiff granted journalist Sharon Churcher extensive interviews that resulted in seven (7) widely distributed articles from March 2011 through January 2015. Churcher regularly communicated with plaintiff and her “attorneys or other agents” from “early 2011” to “the present day.” Plaintiff received approximately $160,000 for her stories and pictures that were published by many news organizations. 52. Plaintiff drafted a 144-page purportedly autobiographical book manuscript in 2011 which she actively sought to publish. In 2011, contemporaneous with her Churcher interviews, plaintiff drafted a book manuscript which purported to document plaintiff's experiences as a teenager in Florida, including her interactions with Epstein and Maxwell. Plaintiff communicated with literary agents, ghost writers and potential independent publishers in an effort to get her book published. She generated marketing materials and circulated those along with book chapters to numerous individuals associated with publishing and the media. 53. Plaintiff’s publicly filed “lurid” CVRA pleadings initiated a media frenzy and generated highly publicized litigation between her lawyers and Alan Dershowitz. On December 30, 2014, plaintiff, through counsel, publicly filed a joinder motion that contained her “lurid allegations” about Ms. Maxwell and many others, including Alan Dershowitz, Prince Andrew, Jean-Luc Brunel. The joinder motion was followed by a “corrected” motion and two further declarations in January and February 2015, which repeated many of plaintiff's claims. These CVRA pleadings generated a media maelstrom and spawned highly publicized litigation between plaintiff's lawyers, Edwards and Cassell, and Alan Dershowitz. After plaintiff publicly

Case 18-2868, Document 275, 08/09/2019, 2628223, Page17 of 18 alleged Mr. Dershowitz of sexual misconduct, Mr. Dershowitz vigorously defended himself in the media. He called plaintiff a liar and accused her lawyers of unethical conduct. In response, attorneys Edwards and Cassell sued Dershowitz who counterclaimed. This litigation, in turn, caused additional media attention by national and international media organizations. 54. Plaintiff formed non-profit Victims Refuse Silence to attract publicity and speak out on a public controversy. In 2014, plaintiff, with the assistance of the same counsel, formed a non-profit organization, Victims Refuse Silence. According to plaintiff, the purpose of the organization is to promote plaintiff's professed cause against sex slavery. The stated goal of her organization is to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. Plaintiff attempts to promote Victims Refuse Silence at every opportunity. For example, plaintiff participated in an interview in New York with ABC to promote the charity and to get her mission out to the public. Dated: January 6, 2017 Respectfully submitted, /s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10 Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 Imenninger@hmflaw.com Attorneys for Ghislaine Maxwell

Case 18-2868, Document 275, 08/09/2019, 2628223, Page18 of 18 CERTIFICATE OF SERVICE I certify that on January 6, 2017, I electronically served this Defendant’s Statement of Material Undisputed Facts Pursuant to Local Civil Rule 56.1 via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smcecawley @bsfllp.com mschultz @bsfllp.com Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad @pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp @law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@ aol.com /s/ Nicole Simmons Nicole Simmons

Case 18-2868, Document 276, 08/09/2019, 2628224, Pagel of 77 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK a xX VIRGINIA L. GIUFFRE, i Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. ae a a A soared eas X Memorandum of Law in Support of Defendant’s Motion for Summary Judgment Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. 150 East 10" Avenue Denver, CO 80203 303.831.7364

Case 18-2868, Document 276, 08/09/2019, 2628224, Page2 of 77 TABLE OF CONENTS PRELIMINARY STATEMENT} sssssesscssssssesssonsssssssssvsesecvvonsneassensonszvousbenvensvenpsansoszassaspevvonsseaonseaveas 1 BACT sssscscsssscvassossieascecucesussvcvansosaisarussecvansisdenneasiaustasdvssenseseaseensnssanaaapsdnstunssnapnnat speaiaiiveatossndsannaaanias 1 SUMMARY JUDGMENT STANDARD 1... eceesscsssestsseseescnesessscsesssneaeseesesssescscasesnsaeeneaseeeeeees 10 PCRGUIMIE NT ss sesansts cocasts ss avae sc sas Savaca teas nanan a csdateus dasa uososcs aabanat asatinuansiateapeauslouiiaersiemni teas 12 I. Ms. Maxwell is not liable for republications of her January 2015 statement that she did not authorize or request and by entities she did not Control. 0.0... csececesesseseeeeesseseeteeeeeeneneeeeeeeee 12 A. Summary judgment is warranted to the extent plaintiff seeks to impose liability on any media’s republication of all or a portion of the January 2015 statement. ........ 12 B. Because plaintiff is a limited public figure, imposing liability upon Ms. Maxwell for republication of the January 2015 statement would violate the First Amendment. C. Plaintiff should be barred from introducing into evidence any republication of an excerpt from the January 2015 statement... cceseeeseceesesteeeeseeteseseeeeeeateeeneeeeee 17 Il. Summary judgment is warranted under the New York Constitution. 0.0.0.0... ccseeseeeeeeeeees 18 A. The January 2015 statement constitutes nonactionable opinion. ...........ceceeeeeeee 18 B. In this Rule 56 proceeding, this Court’s Rule 12(b)(6) opinion does not control the question of law whether the January 2015 statement constitutes nonactionable opinion. Ill. The pre-litigation privilege bars this action. IV. Ms. Maxwell’s January 4, 2015, statement is nonactionable. ..0........cccceeseeseseseeeeeeeeeeeeeeeeees 38 V. The defamation claim should be dismissed because the publication is substantially true. ... 39 VI. Plaintiff cannot establish actual malice by clear and convincing evidence... 40 A. Pactstan tacit eraanitanaseracdarthiviateating lite cenit oaliabeetsiesiie 40 B. Plaintiff carries the burden of proving actual malice by clear and convincing HO VUAS TICE 35a s esis ses oa peta ca cancses sss snevevissbat cvialaatststasvoss rcacsassdlstseesehs aasoasiesdutyorsi Movs 48 Gc. Plaintiff is a public figure who must prove actual malice... cece eeeeeeeee 49 Plaintiff successfully invited public attention to influence others............ 51 i

Case 18-2868, Document 276, 08/09/2019, 2628224, Page3 of 77 2: Plaintiff voluntarily injected herself into public controversies related to the Subjectiof this litigation, ss; assalesivesvicasaseunscavasntsasvivasisetGsaciateanteriviiseionnd 53 3. Plaintiff assumed a position of prominence in the public controversies. . 53 4. Plaintiff has maintained regular and continuing access to the media. ...... 54 Dz. Plaintiff must also prove actual malice to overcome the defenses of reply and preLitigation: privile mes sssssecsrecuscsvosecebvvesvcadesucedsbensvenvuvesvea sevasetvanetsbeabotovendevaseesbeoeraeetoanede 54 E. The January 2015 statement was substantially true, and plaintiff cannot produce clear and convincing evidence of its falsity. .0.....cccceeseeeseseeecsesesseseseeneneseereneereee 56 1, The January 2015 statement accurately denied that Ms. Maxwell met Plaintiff when Plaintiff was 15 years old in 1999. 2. The January 2015 statement accurately denied that Ms. Maxwell “regularly participate[d] in Epstein’s sexual exploitation of minors” and that “the Government knows” such fact. ....... 3. The January 2015 statement accurately denied that “with [Ms. Maxwell’s] assistance, [Epstein] converted [Plaintiff] into what is commonly referred HOS “SOx GAVE: ssssssstinassnctiisewsissaeitarsasgasageeaaantaaiatean wists 59 4. The January 2015 statement accurately reported that Plaintiff alleged “sexual relations” with Professor Dershowitz which he denied. .............. 60 S: The January 2015 statement accurately denied that Ms. Maxwell created and distributed child pornography and that the Government knows of and possesses such child pornography. ..........:.ccscesesessseseeeseeteseseseeeseseeneeeeee 62 6. January 2015 statement accurately denied Maxwell acted as “madame” for Epstein to traffic Plaintiff to the rich and famous (GOING ISUSTIOIN vy iisia' sacsnsessessave sas clasahani casa ives Sasetidah tiaia oteec tees Siiessaatseia tea svea teasing aa abisetvetagsane 68 CERTIFICATE OB SERV ICE cicsasissvsessnsevesarasssapattassasioderaasatacvasssuirtsenstssvasiaa aaceadisgsoneitenavapviny 70

Case 18-2868, Document 276, 08/09/2019, 2628224, Page4 of 77 TABLE OF AUTHORITIES Cases Adelson v. Harris, 973 F. Supp. 2d 467, 490 (S.D.N.Y. 2013) ..cccscecseeeeseeesssteeneeeseeee 29 Air Wisconsin Airlines Corp. v. Hoeper, 134 S. Ct. 852, 861 (2014) ..cecceceeeeeseeeseeee 48 Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 251-52 (1986). voces senses 11 Aronson v. Wiersma, 483 N.E.2d 1138, 1139 (1985) .....ceeessssceceseeeeeeteeeeerseseeeeeeetees 22,24 Bartnicki v. Vopper, 532 U.S. 514, 535 (2001) ...ceccecececeseeseseseeseeeseeeseseeneseesseseenseeeneaees 48 Biro v. Condé Nast, 883 F. Supp. 2d 441, 458 (S.D.N.Y. 2012) w..ceeccesessessseseseseeseeseesees 39 Biro v. Condé Naste, 963 F. Supp. 2d 255, 269 (S.D.N.Y. 2013)...ccecceeeeseseseseeeeeseesees 49 Black v. Green Harbour Homeowners’ Ass'n, 798 N.Y .S.2d 753 (App. Div. 2005). ...... 34 Celle v. Filipino Reporter Enters. Inc., 209 F.3d 163, 176-77 (2d Cir. 2000)........c0 51 Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986)....ssssssssssssessssscsssnssessssessessssseesesesees 12 Chambers v. Wells Fargo Bank, N.A., No. 2016 WL 3533998, at *8 (D.N.J. June 28, 2016) cssisssssssssasetssssvascsssenactashesessasessuavsanonndctistssboseesadusabassatessaaeastvasobenstousdustooneasisbeseonebsess 33 Chau v. Lewis, 935 F. Supp. 2d 644, 665 (S.D.N.Y. 2013) ..cceccesecseeeseeeeseeeseeeseesesneeees 23 Collier v. Postum Cereal Co., 134 N.Y.S. 847, 853 (1" Dep't 1912) ..ececssesssstsesstesesteeeeee 55 Contemporary Mission, Inc. v. N.Y. Times Co., 842 F.2d 612, 617 (2d Cir. 1988).. 50 Curtis Publ'g Cov: Butts, 388°'U3S,.130: (1967) wsccsiscsssasteseasiasetscesieceiessspeatarterasenaaeesteoteee 49 Davis v. Boeheim, 22 N.E.3d 999, 1006 (N.Y. 2014) ...ecceseessessesesseeseeseeseesseeseesesseeseese 22,31 Davis v. Costa-Gavras, 580 F. Supp. 1082, 1096 (S.D.N.Y. 1984) ..c.cecceceseseeeeeeeeeeeee 12 Dibella v. Hopkins, No. 01 CIV. 11779 (DC), 2002 WL 31427362, at *2 (S.D.N.Y. Oct. BO; 2002) 3... ssssssossesiesnssasasassssontsesseoasestesdsesesedétbsonsdessnvadeaseshssssenbcevaenecnspsoasoadosasst¥snbnedvenoéss 23 Don King Prods., Inc. v. Douglas, 742 F. Supp. 778, 780 (S.D.N.Y. 1990) ...cseeeeeeeneee 11 iii

Case 18-2868, Document 276, 08/09/2019, 2628224, Page5 of 77 Elias v. Rolling Stone LLC, No. 15-CV-5953 (PKC), 2016 WL 3583080, at *6 (S.D.N.Y. FUME 2B, ZOO): cicaieesscasergssascsasesseasesgencsedszsbbseserhinesnnsdsbdendbapsnsnbesbaotiesgeobsnda gebsaseesabeveseeoed 22 Enigma Sofiware Grp. USA, LLC v. Bleeping Computer LLC, No. 16 CIV. 57 (PAE), 2016 WL 3773394, at *11 (S.D.N.Y. July 8, 2016)... cc seeeeeeeeseeteseseeeseeneenees 19 Faigin v. Kelly, 978 F. Supp. 420, 426 (D. N.H. 1997... cceesseseseseeesesteeseseseseesenenenenees 50 Firestone v. Time, Inc., 271 So. 2d 745, 752 (Fla. 1972) ......cssssssecssesseseceesseserseeeeeeeseeeees 13 Fleckenstein v. Friedman, 193 N.E. 537, 538 (N.Y. 1934) v.ccccccssesesssseseseseseeeeeeeeseseeeeees 40 Flomenhaft v. Finkelstein, 8 N.Y.S.3d 161, 164 n.2 (1" Dep't 2015) ..scesseesssecseeesteeeseeenee 33 Folwell v. Miller, 145 F. 495, 497 (2d Cir. 1906)... cecsesesssssssessssessescasenceeeseeesseeeeseensaee 13 Franklin v. Daily Holdings, Inc., 21 N.Y.S.3d 6, 12 (App. Div. 2015)... Frechtman v. Gutterrnan, 979 N.Y.S. 2d 58 (App. Div. 2014) w.ccccccseeeseeseseeeeeeneenees 34 Front,-Inc..v; Khalil, 28 NE3d U5, 16:QNLY 2015) sisssscssasiccssesssessasssisnsssssvanerssteasnasrines 33 Geraci v. Probst, 938 N.E.2d 917, 921 (N.Y. 2010)... eseeteseseeeeteteeseesnenseees 13,18 Germain v. M & T Bank Corp., 111 F. Supp. 3d 506, 534 (S.D.N.Y. 2015)... 19 Gertz v. Robert Welch, Inc., 418 U.S. 323 (1974 ......escssssssssessseessesseceeeeseeseeeeeeees 16, 48, 49 Goforth v. Avemco Life Ins. Co., 368 F.2d 25, 28 n.7 (4th Cir.1966). cece 39 Goldstein v. Cogswell, No. 85 CIV. 9256 (KMW), 1992 WL 131723, at *27 n.32 (Sa. Ye Tan 1), 1992) scssci ssscesendestesigssashseddvasasovessbesesaa essasesansissuntzeadiutanaisesasascasesdsoeses 33 Gross v. New York Times, 623 N.E.2d 1163, 1169 (N.Y. 1993)... cecesesseseseseseteteeeeeeeeeee 28 Harte-Hanks Communic ‘ns, Inc. v. Connaughton, 491 U.S. 657, 666 n.7 (1989) ...... 48 Hawkins v. Harris, 661 A.2d 284, 289-91 (N.J. 1995) w.eeeceesssseeeeeseteseeeeceeeneseeeeeeeeneaeeeees 33 Horne v. Matthews, No. 97 Civ. 3605(JSM), 1997 WL 598452 (S.D.N.Y. Sept. 25, 1997) shignssssingbeasdoissnsaspsndbenbsasioehseostedsubbensseth oidesbonbseed¥obsebpeonsatingiSebsas%sensioesuasesobash vnnstojactiatbenised 23 Huggins v. Moore, 726 N.E.2d 456, 460 (N.Y. 1999) .o.cccceeeseseseseseseseetesesesesestenesenenees 48

Case 18-2868, Document 276, 08/09/2019, 2628224, Page6 of 77 Immuno AG v. Moor-Jankowski, 567 N.E.2d 1270, 1282 (N.Y. 1991) veces 11,19 Indep. Living Aids, Inc. v. Maxi-Aids, Inc., 981 F. Supp. 124, 128 (E.D.N.Y. 1997)....... 28 International Publishing Concepts, LLC v. Locatelli ..c.ceccecessesecsesesvesesescssesseseesesneseesseeees 37 James v. Gannett Co., 353 N.E.2d 834, 838 (N.Y. 1976) ....cceeseeeseteeeeeeeeseeeeeeee 14, 23, 49 Jewell v. NYP Holdings, Inc., 23 F. Supp. 2d 348, 366 (S.D.N.Y.1998) ....cceceeeeeeeeeeee 40 Kane v. Orange Cnty. Publ’ns, 649 N.Y.S.2d 23, 26 (App. Div. 1996) ......csecseeeeeeseeees 56 Karaduman v. Newsday, Inc., 416 N.E.2d 557, 560 (1980).....cccssseesesesesesseseseeseseeeeenesees 18 Kirk v. Heppt, 532 F. Supp. 2d 586, 593 (S.D.N.Y. 2008). ....scescecsecseesessesssssessessesseeseesees 33 Klein v. McGauley, 29. A.D.2d 418, 420 (on Dep't LOGS) zssaicisivatenas tiated iaaiatiates 34 Lehman Bros. Commercial Corp. v. Minmetals Int’l Non-Ferrous Metals Trading Co., No. 94 CIV. 8301(JFK), 1995 WL 380119, at *6 n.2 (S.D.N.Y. June 26, 1995)......... 21 Lerman vy. Flynt Dist. Co., Inc., 745 F.3d 123, 136 (2d Cir. 1984) ...cccseesseeeeeeeeeeesees 49 Mann vy. Abel, 885 N.E.2d 884, 885-86 (N.Y. 2008) .....ceseeseeseesseeeeeseesseseesseentsseenesseesesees 29 Martin v. City of Oceanside, 205 F. Supp. 2d 1142, 1147 (S.D. Cal. 2002), aff'd, 360 BS VOPR (Oe Car, LOOK): seats essa acess cig sied ks das caspase i ig aes 0d aaa oa Se bd Nae 22 Martiranov; Frost, 255 N.E 20693) (1969) is.scssssiecisacossecsetvasiosstascsataveca casgassateaestussadenatencss 34 Mashburn v. Collin, 355 So. 2d 879, 885 (La. 1977) ...cccscecesesesesesesesesssseseseseseseesesenenesees 30 Masson v. New Yorker Magazine, Inc., 501 U.S. 496, 510 (1991) .oecseeseseeeeeeeseesees 54 Maule v. Philadelphia Media Holdings, LLC, No. CIV.A. 08-3357, 2010 WL 914926, at *10:(E.D; Pas. Mat: 15; 2010), sccsscsssessessssessessessconseasesssnssovtssssoonseisosnseaseassasdendsnssbetivaivnse’ 22 McGill v. Parker, 582 N.Y.S.2d 91, 97 (App. Div. 1992) ......scsscesessesessesssesseseeseeseeseesees 48 Meiri v. Dacon, 759 F.2d 989, 998 (2d Cir. 1985)...cc.cccccccccseesecsecseesseesevsseusevseessevseeees ll Mencher v. Chesley, 75 N.E.2d 257, 259 (N.Y. 1947)...ccccsssesssssseseesssssssesssssesestsessesesees 14 Milkovich v. Lorain Journal Co., 497 U.S. 1 (1990) woececeescssseseeeeeceeeeeeseseseseeneeeeeeseaeneees 19

Case 18-2868, Document 276, 08/09/2019, 2628224, Page7 of 77 New York Times Co. v. Sullivan, 376 U.S. 254 (1964) ..ccccsseeceteteeeeseseneseteeeeeeees 16,48,49 People v. Kocsis, 28 N.Y.S.3d 466, 471 (App. Div. 2016). Petrus v. Smith, 91 A.D.2d 1190, 1191 (N.Y. App. App. Div. 1983)... cece 34 Philadelphia Newspapers, Inc. v. Hepps, 475 U.S. 767, 776-77 (1986)....cscceseeeseseteseee 48 In Re Philadelphia Newspapers, LLC, 690 F.3d 161, 175 (3d Cir. 2012), as corrected (Oct. 25, 2012). Rand v. New York Times Co., 430 N.Y.S.2d 271, 275 (App. Div. 1980). ...c.ccceceeeeeees 14 Ratajack v. Brewster Fire Dep’t, Inc. of the Brewster-SE Joint Fire Dist., 178 F. Supp. 3d 118): 1S8 (S-D.N IY 2016) scisscssssssvsstsssevssseasacesctessesssussvaszencassbeacessessaeatsensunssesnesobsiznasisiass 29 Rinaldi v. Viking Penguin, Inc., 420 N.E.2d 377, 382 (N.Y. 1981).. Salyer v. S. Poverty Law Ctr., Inc., 701 F. Supp. 2d 912, 916 (W.D. Ky. 2009)... 39 Sexter v. Warmflash, P.C. v. Margrabe, 828 N.Y.S. 2d 315 (App. Div. 2007)).........004 34 Shenkman v. O'Malley, 157 N.Y.S8.2d 290, 294, 297 (App. Div. 1956) ....ccceseeeeeeeeeee 54 Soley v. Wasserman, No. 8 CIV. 9262 KMW FM, 2013 WL 3185555, at *8 (S.D.N.Y. Fu’ 2, QOUS) sscssisivcssessstasscssoasasssesstosveecosssesdeaseoseussbetstosvedsostecsauavsesssvsesseaesshcesssuasaseiosons 18 Steinhilber v. Alphonse, 501 N.E.2d 550, 550 (N.Y. 1986) ..cccecseseseeseeseseseeseseeeeenesees 19 Time, Inc. v. Firestone, 424 U.S. 448, 488 1.1 (1976) ...ceeeeeseseeceeeeeeeeeeseeeseeeeeeeeeeaeeeee 13 Waldbaum v. Fairchild Publ'ns, Inc., 626 F.2d 1287, 1298 (D.C, Cir. 1980 wee Sl Rules BGA PRs CiyislPs DO cstetisic sa Sasedatstasehie <asedty acy opteael sunbaeid za telaconeisasetoleenosers asesedevahetiunecetes 11, 12 vi

Case 18-2868, Document 276, 08/09/2019, 2628224, Page8 of 77 Defendant Ghislaine Maxwell moves under Federal Rule of Civil Procedure 56 for summary judgment. PRELIMINARY STATEMENT FACTS The following facts are undisputed. Additional undisputed facts are set forth in specific argument sections. All paragraphs containing undisputed facts will be sequentially numbered. 1. Ms. Maxwell’s response to publications of plaintiff’s false allegations: the March 2011 statement. In early 2011 plaintiff in two British tabloid interviews made numerous false and defamatory allegations against Ms. Maxwell. ExuiBITs A-B.' In the articles, plaintiff made no direct allegations that Ms. Maxwell was involved in any improper conduct with Jeffrey Epstein, who had pleaded guilty in 2007 to procuring a minor for prostitution.” Nonetheless, plaintiff suggested that Ms. Maxwell worked with Epstein and may have known about the crime for which he was convicted. See generally EXHIBITS A-B. 2. In the articles, plaintiff alleged she had sex with Prince Andrew, “a well-known businessman,” a “world-renowned scientist,” a “respected liberal politician,” and a “foreign head of state.” Id. at 5. 3. In response to the allegations Ms. Maxwell’s British attorney, working with Mr. Gow, issued a statement on March 9, 2011, denying “the various allegations about [Ms. Maxwell] that have appeared recently in the media. These allegations are all entirely false.” EXHIBIT C, 4. The statement read in full: 'The articles were attached as exhibits to the author Sharon Churcher’s declaration in support of her motion to quash an SDT issued to her. See Doc.216-2 & 216-3. *Doc.1 44 11, 14.

Case 18-2868, Document 276, 08/09/2019, 2628224, Page9 of 77 Statement on Behalf of Ghislaine Maxwell By Devonshires Solicitors, PRNE Wednesday, March 9, 2011 London, March 10, 2011 - Ghislaine Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are all entirely false. It is unacceptable that letters sent by Ms Maxwell’s legal representatives to certain newspapers pointing out the truth and asking for the allegations to be withdrawn have simply been ignored. In the circumstances, Ms Maxwell is now proceeding to take legal action against those newspapers. “T understand newspapers need stories to sell copies. It is well known that certain newspapers live by the adage, “why let the truth get in the way of a good story.” However, the allegations made against me are abhorrent and entirely untrue and lask that they stop,” said Ghislaine Maxwell. “A number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name,” she said. Media contact: Ross Gow Acuity Reputation Tel: +44-203-008-7790 Mob: +44-7778-755-251 Email: ross@acuityreputation.com Media contact: Ross Gow, Acuity Reputation, Tel: +44-203008-7790, Mob: +44-7778-755-251, Email: ross at acuityreputation.com EXHIBIT C (emphasis supplied; capitalization altered). We refer to this as “the March 2011 statement.” 5. Plaintiff’s gratuitous and “lurid” accusations in an unrelated action. In 2008 two alleged victims of Epstein brought an action under the Crime Victims’ Rights Act against the United States government purporting to challenge Epstein’s plea agreement. They alleged the government violated their CVRA rights by entering into the agreement. See EXHIBIT D, at 2.

Case 18-2868, Document 276, 08/09/2019, 2628224, Page10 of 77 6. Seven years later, on December 30, 2014, Ms. Giuffre moved to join the CVRA action, claiming she, too, had her CVRA rights violated by the government. On January 1, 2015, Ms. Giuffre filed a “corrected” joinder motion. EXHIBIT D, at 1, 9. 7. The issue presented in her joinder motion was narrow: whether she should be permitted to join the CVRA action as a party under Federal Rule of Civil Procedure 21, specifically, whether she was a “known victim[] of Mr. Epstein and the Government owed them CVRA duties,” EXHIBIT E, at 5. Yet, the court noted, “the bulk of the [motion] consists of copious factual details that [plaintiff] and [her co-movant] ‘would prove . . . if allowed to join.’”” Id. (brackets omitted). Ms. Giuffre gratuitously included provocative and “lurid details” of her alleged sexual activities as an alleged victim of sexual trafficking. Id. 8. At the time they filed the motion, Ms. Giuffre and her lawyers knew that the media had been following the Epstein criminal case and the CVRA action. While they deliberately filed the motion without disclosing Ms. Giuffre’s name, claiming the need for privacy and secrecy, they made no attempt to file the motion under seal. Quite the contrary, they filed the motion publicly. ExHiBIT D, at 1 & n.1. 9. As the district court noted in ruling on the joinder motion, Ms. Giuffre “name[d] several individuals, and she offers details about the type of sex acts performed and where they took place.” EXHIBIT E, at 5. The court ruled that “these lurid details are unnecessary”: “The factual details regarding whom and where the Jane Does engaged in sexual activities are immaterial and impertinent . . ., especially considering that these details involve non-parties who are not related to the respondent Government.” Jd. Accordingly, “[t]hese unnecessary details shall be stricken.” Jd. The court then struck all Ms. Giuffre’s factual allegations relating to her alleged sexual activities and her allegations of misconduct by non-parties. /d. at 5-6. The court

Case 18-2868, Document 276, 08/09/2019, 2628224, Page11 of 77 said the striking of the “lurid details” was a sanction for Ms. Giuffre’s improper inclusion of them in the motion. See id. at 6-7. 10. The district court found not only that the “lurid details” were unnecessary but also that the entire joinder motion was “entirely unnecessary,” id. at 7. Ms. Giuffre and her lawyers knew the motion with all its “lurid details” was unnecessary because, as the court pointed out, the motion itself recognized that she would be able to participate as a fact witness to achieve the same result she sought as a party. See id. at 7-8; see also id. at 8 (noting that in the motion, Ms. Giuffre’s lawyers said that “regardless of whether this Court grants the . .. Motion, ‘they will call [her] as a witness at any trial’”). The court denied plaintiff's joinder motion. /d. at 10. 11. One of the non-parties Ms. Giuffre “named” repeatedly in the joinder motion was Ms. Maxwell. EXHIBIT D, at 3-6. According to the “lurid details” of Ms. Giuffre included in the motion, Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by Epstein: e Ms. Maxwell “approached” plaintiff in 1999 when plaintiff was “fifteen years old” to recruit her into the scheme. /d. at 3. e = Ms. Maxwell was “one of the main women” Epstein used to “procure underaged girls for sexual activities.” Jd. e = Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme. Jd. e She “persuaded” plaintiff to go to Epstein’s mansion “in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children.” Jd. e At the mansion, when plaintiff began giving Epstein a massage, he and Ms. Maxwell “turned it into a sexual encounter.” Jd. e Epstein “with the assistance of’ Ms. Maxwell “converted [plaintiff] into... a “sex slave.’” /d. Plaintiff was a “sex slave” from “about 1999 through 2002.” Jd. e Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.” /d. at 4.

Case 18-2868, Document 276, 08/09/2019, 2628224, Page12 of 77 e Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea agreement, because the immunity protected her from prosecution “for the crimes she committed in Florida.” Jd. e Ms. Maxwell “participat[ed] in the sexual abuse of [plaintiff] and others.” Jd. e = Ms. Maxwell “took numerous sexually explicit pictures of underage girls involved in sexual activities, including [plaintiff].” Jd. She shared the photos with Epstein. Jd. e As part of her “role in Epstein’s sexual abuse ring,” Ms. Maxwell “connect[ed]” Epstein with “powerful individuals” so that Epstein could traffick plaintiff to these persons. Id. e — Plaintiff was “forced to have sexual relations” with Prince Andrew in “[Ms. Maxwell's] apartment” in London. /d. Ms. Maxwell “facilitated” plaintiff's sex with Prince Andrew “by acting as a ‘madame’ for Epstein.” Jd. e Ms. Maxwell “assist[ed] in internationally trafficking” plaintiff and “numerous other young girls for sexual purposes.” Jd. e Plaintiff was “forced” to watch Epstein, Ms. Maxwell and others “engage in illegal sexual acts with dozens of underage girls.” Jd. 12. In the joinder motion, plaintiff also alleged she was “forced” to have sex with Harvard law professor Alan Dershowitz, “model scout” Jean Luc Brunel, and “many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.” Jd. at 4-6. 13. Plaintiff said after serving for four years as a “sex slave,” she “managed to escape to a foreign country and hide out from Epstein and his co-conspirators for years.” Id. at 3. 14. Plaintiff suggested the government was part of Epstein’s “conspiracy” when it “secretly” negotiated a non-prosecution agreement with Epstein precluding federal prosecution of Epstein and his “co-conspirators.” /d. at 6. The government’s secrecy, plaintiff alleged, was motivated by its fear that plaintiff would raise “powerful objections” to the agreement that would have “shed tremendous public light on Epstein and other powerful individuals. /d. at 6-7.

Case 18-2868, Document 276, 08/09/2019, 2628224, Page13 of 77 15. Notably, the other “Jane Doe” who joined plaintiff's motion who alleged she was sexually abused “many occasions” by Epstein was unable to corroborate any of plaintiffs allegations. See id. at 7-8. 16. Also notably, in her multiple and lengthy consensual interviews with Ms. Churcher three years earlier, plaintiff told Ms. Churcher virtually none of the details she described in the joinder motion. See EXHIBIT A-B. 17. Ms. Maxwell’s response to plaintiff’s “lurid” accusations: the January 2015 statement. As plaintiff and her lawyers expected, before District Judge Marra in the CVRA action could strike the “lurid details” of plaintiff's allegations in the joinder motion, members of the media obtained copies of the motion. See EXHIBIT G, at 31:2-36:4 & Depo.Exs.3-4. 18. At Mr. Barden’s direction, on January 2, 2015, Mr. Gow sent to numerous representatives of British media organizations an email containing ‘‘a quotable statement on behalf of Ms Maxwell.” EXHIBIT F; EXHIBIT G, at 33:8-23. The email was sent to more than 6 and probably less than 30 media representatives. See EXHIBIT G, at 33:8-34:3. It was not sent to non-media representatives. See id. at 31:2-35:21. 19. Among the media representatives were Martin Robinson of the Daily Mail; P. Peachey of The Independent; Nick Sommerlad of The Mirror; David Brown of The Times; and Nick Always and Jo-Anne Pugh of the BBC; and David Mercer of the Press Association. See, e.g., EXHIBIT F. These representatives were selected based on their request—after the joinder motion was filed—for a response from Ms. Maxwell to plaintiff’s allegations in the motion. See, e.g., EXHIBIT G, at 30:23-35:21 & Depo.Ex.3. 20. The email to the media members read: To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell.

Case 18-2868, Document 276, 08/09/2019, 2628224, Page14 of 77 No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts—so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. EXHIBIT F (emphasis supplied). We refer to this email as “the January 2015 statement.” 21. Mr. Barden, who prepared the January 2015 statement, did not intend it as a traditional press release solely to disseminate information to the media. So he intentionally did engage a public relations firm, such as Mr. Gow’s firm Acuity Reputation, to prepare the statement. See EXHIBIT K ff 10,15. 22. The January 2015 statement served two purposes. First, Mr. Barden intended that it mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of plaintiff's false allegations. He believed this could be accomplished by suggesting to the media that, among other things, they should subject plaintiff's allegations to inquiry and scrutiny. For example, he noted in the statement that plaintiff's allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicised as news.” Jd. § 11.

Case 18-2868, Document 276, 08/09/2019, 2628224, Page15 of 77 23. Second, Mr. Barden intended the January 2015 statement to be “a shot across the bow” of the media, which he believed had been unduly eager to publish plaintiff's allegations without conducting any inquiry of their own. Accordingly, in the statement he repeatedly noted that plaintiff's allegations were “defamatory.” In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiff's obviously false allegations and the legal indefensibility of their own conduct. Jd. § 17. 24. Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms Maxwell” (emphasis supplied). The statement was intended to be a single, one-time-only, comprehensive response—quoted in full—to plaintiff’s December 30, 2014, allegations that would give the media Ms. Maxwell’s response. Jd. § 19. The purpose of the prefatory statement was to inform the media-recipients of this intent. Jd. 25. Plaintiff’s activities to bring light to the rights of victims of sexual abuse. Plaintiff has engaged in numerous activities to bring attention to herself, to the prosecution and punishment of wealthy individuals such as Epstein, and to her claimed interest of bringing light to the rights of victims of sexual abuse. 26. Plaintiff created an organization, Victims Refuse Silence, Inc., a Florida corporation, directly related to her alleged experience as a victim of sexual abuse. Doc.1 §] 24-25. 27. The “goal” of Victims Refuse Silence “was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse.” Id. § 25. Toward this end, plaintiff has “dedicated her professional life to helping victims of sex trafficking.” Jd.

Case 18-2868, Document 276, 08/09/2019, 2628224, Page16 of 77 28. Plaintiff repeatedly has sought out media organizations to discuss her alleged experience as a victim of sexual abuse. See This Motion at §§ 51-54. 29. As discussed above, on December 30, 2014, plaintiff publicly filed an “entirely unnecessary” joinder motion laden with what Judge Marra described as “unnecessary,” “lurid details”? about being “sexually abused” as a “minor victim[]” by wealthy and famous men and being “trafficked” all around the world as a “sex slave.” EXHIBIT D, at | n.1, 3-6. 30. The plaintiff's alleged purpose in filing the joinder motion was to “vindicate” her rights under the CVRA, expose the government’s “secretly negotiated” “non-prosecution agreement” with Epstein, “shed tremendous public light” on Epstein and “other powerful individuals” that would undermine the agreement, and support the CVRA plaintiffs’ request for documents that would show how Epstein “used his powerful political and social connections to secure a favorable plea deal” and the government’s “motive” to aid Epstein and his “coconspirators.” See EXHIBIT D, at 1, 6-7, 10 (emphasis supplied). 31. Plaintiff has written the manuscript of a book she has been trying to publish detailing her alleged experience as a victim of sexual abuse and of sex trafficking in Epstein’s alleged “sex scheme.” EXHIBIT KK. 32. Republication alleged by plaintiff. Plaintiff® was required by Interrogatory No. 6 to identify any false statements attributed to Ms. Maxwell that were “‘published globally, including SExuIBIT E, at 7. 4Id. at 5. °Id. °The undisputed facts relevant to this Motion are contained in the Facts section, above, and within each argument as appropriate. The undisputed facts will be sequentially numbered throughout this Motion.

Case 18-2868, Document 276, 08/09/2019, 2628224, Page17 of 77 within the Southern District of New York,”” as plaintiff alleged in Paragraph 9 of Count I of her complaint. In response, plaintiff identified the January 2015 statement and nine instances in which various news media published portions of the January 2015 statement in news articles or broadcast stories. EXHIBIT H, at 7-8; EXHIBIT I, at 4. 33. Innone of the nine instances was there any publication of the entire January 2015 statement. See EXHIBIT H, at 7-8; EXHIBIT I, at 4. 34. Ms. Maxwell and her agents exercised no control or authority over any media organization, including the media identified in plaintiff's response to Interrogatory No. 6, in connection with the media’s publication of portions of the January 2015 statement. EXHIBIT J 4 24; EXHIBIT K §§ 2-3.. 35. Plaintiff’s defamation action against Ms. Maxwell. Eight years after Epstein’s guilty plea, plaintiff brought this action, repeating many of the allegations she made in her CVRA joinder motion. See Doc.1 § 9. 36. The complaint alleged that the January 2015 statement “contained the following deliberate falsehoods”: (a) That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.” (b) That the allegations have been “shown to be untrue.” (c) That Giuffre’s “claims are obvious lies.” Doc.1 § 30 (boldface and underscoring omitted). SUMMARY JUDGMENT STANDARD “[C]ourts should not be reluctant to grant summary judgment in appropriate cases. ‘One of the principal purposes of the summary judgment rule is to isolate and dispose of factually insupportable claims,’ thereby permitting courts to avoid ‘protracted, expensive and harassing trials.” Don King Prods., Inc. v. Douglas, 742 F. Supp. 778, 780 (S.D.N.Y. 1990) (quoting 10

Case 18-2868, Document 276, 08/09/2019, 2628224, Page18 of 77 Celotex Corp. v. Catrett, 477 U.S. 317, 323-24 (1986), and Meiri v. Dacon, 759 F.2d 989, 998 (2d Cir. 1985)). Where summary judgment is sought under Article I, Section 8, of the New York Constitution, the New York Court of Appeals has declared, “we reaffirm our regard for the particular value of summary judgment, where appropriate, in libel cases,” Jmmuno AG y. MoorJankowski, 567 N.E.2d 1270, 1282 (N.Y. 1991), particularly when as here a defendant is challenging a defamation claim under the “independent State law approach” articulated in Immuno AG that might make summary disposition more likely than under a federal approach, see id. Summary judgment is appropriate where “there is no genuine issue as to any material fact and... the moving party is entitled to a judgment as a matter of law.” Fed. R. Civ. P. 56(c). The relevant inquiry on application for summary judgment is “whether the evidence presents a sufficient disagreement to require submission to a jury or whether it is so one-sided that one party must prevail as a matter of law.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 251-52 (1986). “(T]he mere existence of some alleged factual dispute between the parties will not defeat an otherwise properly supported motion for summary judgment; the requirement is that there be no genuine issue of material fact.” Id. at 247-48. The substantive law determines what facts are material. /d. at 248. “Only disputes over facts that might affect the outcome of the suit under the governing law will properly preclude the entry of summary judgment. Factual disputes that are irrelevant or unnecessary will not be counted.” /d. A dispute about a material fact is “genuine” if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Jd. In the face of a properly supported summary judgment motion, the plaintiff may not “rest on [the] allegations” in her complaint. Jd. at 249. The trial court’s function is to determine

Case 18-2868, Document 276, 08/09/2019, 2628224, Page19 of 77 whether there is a genuine issue for trial, and “there is no issue for trial unless there is sufficient evidence favoring the nonmoving party for a jury to return a verdict for that party.” Jd. “(T]he plain language of Rule 56(c) mandates the entry of summary judgment . . . against a party who fails to make a showing sufficient to establish the existence of an element essential to that party’s case, and on which that party will bear the burden of proof at trial.” Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986). In such a situation, “there can be ‘no genuine issue as to any material fact,’ since a complete failure of proof concerning an essential element of the nonmoving party’s case necessarily renders all other facts immaterial. The moving party is ‘entitled to a judgment as a matter of law’ because the nonmoving party has failed to make a sufficient showing on an essential element of her case with respect to which she has the burden of proof.” Jd. at 323; see Fed. R. Civ. P. 56 advisory committee’s notes (2010 amendments) (restoration of “shall grant summary judgment” was intended to “express the direction to grant summary judgment, and “avoids the unintended consequences of any other word”). ARGUMENT I. Ms. Maxwell is not liable for republications of her January 2015 statement that she did not authorize or request and by entities she did not control. A. Summary judgment is warranted to the extent plaintiff seeks to impose liability on any media’s republication of all or a portion of the January 2015 statement. Messrs. Barden and Gow, acting on behalf of Ms. Maxwell, caused the January 2015 statement to be transmitted—published—to various individuals employed by media organizations. The question presented in this Argument I is whether Ms. Maxwell is liable for any republication of all or a portion of the January 2015 statement by the media. Under New York law, the answer is no. Liability for a republication “must be based on real authority to influence the final product.” Davis v. Costa-Gavras, 580 F. Supp. 1082, 1096 (S.D.N.Y. 1984) (emphasis supplied). 12

Case 18-2868, Document 276, 08/09/2019, 2628224, Page20 of 77 “[W here a defendant ‘had no actual part in composing or publishing,’ he cannot be held liable ‘without disregarding the settled rule of law that no man is bound for the tortious act of another over whom he has not a master’s power of control.” /d. (quoting Folwell v. Miller, 145 F. 495, 497 (2d Cir. 1906)); see Geraci v. Probst, 938 N.E.2d 917, 921 (N.Y. 2010) (holding that defendant was not liable for republication, in part because “there is no indication that Probst had any control over whether or not Newsday published the article”). “Conclusive evidence of lack of actual authority [is] sufficiently dispositive that the [trial court] ‘ha[s] no option but to dismiss the case... .’” Jd. (quoting Rinaldi v. Viking Penguin, Inc., 420 N.E.2d 377, 382 (N.Y. 1981)). As the New York Court of Appeals held in Geraci: It is too well settled to be now questioned that one who . . . prints and publishes a libel[] is not responsible for its voluntary and unjustifiable repetition, without his authority or request, by others over whom he has no control and who thereby make themselves liable to the person injured, and that such repetition cannot be considered in law a necessary, natural and probable consequence of the original slander or libel. 938 N.E.2d at 921 (internal quotations and citation omitted). The rationale behind this rule is that “each person who repeats the defamatory statement is responsible for the resulting damages.” Id. (internal quotations omitted). With the goal of garnering maximum publicity and defaming Ms. Maxwell, Ms. Giuffre filed an “entirely unnecessary” joinder motion with “lurid details” about sexual acts for the purpose of attracting the attention of the public, which was “‘curious, titillated or intrigued’”* about alleged sexual acts and relationships among the rich and famous. In defense of Ms. Maxwell’s reputation, Messrs. Barden and Gow responded with the January 2015 statement. EXHIBIT E, at 7. ‘Time, Inc. v. Firestone, 424 U.S. 448, 488 n.1 (1976) (Marshall, J., dissenting) (quoting Firestone v. Time, Inc., 271 So. 2d 745, 752 (Fla. 1972)). 13

Case 18-2868, Document 276, 08/09/2019, 2628224, Page21 of 77 The email transmitting the statement explained it was “a quotable statement on behalf of Ms Maxwell” and “[n]Jo further communication will be provided by her on this matter.” EXHIBIT F (emphasis supplied). The media representatives were notified that if they intended to use the statement, it was to be quoted in its entirety. See This Motion § 24, at 8. Ms. Maxwell and Messrs. Barden and Gow had no ability to control whether or how the media-recipients would use the statement, and they made no effort to control whether or how they would use the statement. EXHIBIT K §§ 2-3; EXHIBIT J § 24. Ms. Maxwell is not responsible for any republication of the January 2015 statement, whether it was republished in whole or in part,’ since she had no authority or control over any media that published any portion of it. In the words of this Court, she had no “real authority to influence the final product,” Davis, 580 F. Supp. at 1096. The media’s selective, partial republication of the statement is more problematic yet. An original publisher of a statement cannot be charged with a republisher’s “editing and excerpting of her statement.” Rand v. New York Times Co., 430 N.Y.S.2d 271, 275 (App. Div. 1980). The rule applies with even greater force where as here a defamation claim is grounded on the expression of opinion: An individual “cannot be liable for the republication of a derogatory but constitutionally protected opinion when the foundation upon which that opinion is based is omitted. The defamatory remark should be ‘read against the background of its issuance.’” Jd. (quoting Mencher v. Chesley, 75 N.E.2d 257, 259 (N.Y. 1947), and citing James v. Gannett Co., 353 N.E.2d 834, 838 (N.Y. 1976)). °Plaintiff has not disclosed under Fed. R. Civ. P. 26(a)(1)(A)(ii) any republication of the entirety of the January 2015 statement. In response to our discovery requests requiring her to identify republications of all or a portion of the statement, plaintiff identified no republication of the entirety of the statement.

Case 18-2868, Document 276, 08/09/2019, 2628224, Page22 of 77 The rationale for this rule is found in the New York Court of Appeals’ explanation of how an original publisher’s allegedly defamatory statement should be interpreted: The statement complained of will be read against the background of its issuance with respect to the circumstances of its publication. It is the duty of the court, in an action for libel, to understand the publication in the same manner that others would naturally do. The construction which it behooves a court of justice to put on a publication which is alleged to be libelous is to be derived as well from the expressions used as from the whole scope and apparent object of the writer. James, 353 N.E.2d at 838 (emphasis supplied; citations and internal quotations omitted). The January 2015 statement was intended to be read by the media-recipients in its entirety. One, it was intended to be a comprehensive, one-time-only response to all of plaintiff's lurid and false allegations of sexual and other misconduct by Ms. Maxwell. See EXHIBIT J § 13. Two, the statement was complex in that it could not be quoted partially and out of context and still convey the intended meaning. Among other things, the statement was intended to show why plaintiff could not be believed—why her allegations are “obvious lies”—by pointing out how her story changed each time she retold the story. As Mr. Barden explains: Selective and partial quotation and use of the statement would disserve my purposes. It was intended to address Plaintiff's behavior and allegations against Ms. Maxwell on a broad scale, that is to say, Plaintiff's history of making false allegations and innuendo to the media against Ms. Maxwell. This is why the statement references Plaintiff’s “original allegations” and points out that her story “changes” —i.e. is embellished—over time including the allegations “now” that Professor Dershowitz allegedly had sexual relations with her. This is why I distinguished in the statement between Plaintiff's “original” allegations and her “new,” joinder-motion allegations, which differed substantially from the original allegations. And this is why I wrote, “Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by [Plaintiff] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies.” (Emphasis supplied.) Having established the dramatic difference between Plaintiff's two sets of allegations, which suggested she was fabricating more and more-salacious allegations as she had more time to manufacture them, I added the third paragraph: “[Ms. Giuffre’s] claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory.” (Emphasis supplied.) I believed then, and believe now, that it was and remains a fair inference and conclusion that her claims were and are “obvious 15

Case 18-2868, Document 276, 08/09/2019, 2628224, Page23 of 77 lies.” As noted, her claims not to have slept with Prince Andrew and to have slept with Prince Andrew are a classic example of an obvious lie. One or other account is on the face of it a lie. EXHIBIT J ¥ 20. That Mr. Barden on behalf of Ms. Maxwell was expressing his opinion—in the form of a legal argument—as a lawyer would be lost if words and phrases are extracted from and used outside the context of the January 2015 statement. Yet, this is precisely what the media did in their articles on the statement and what plaintiff did in her complaint (see Doc.1 § 30). Finally, the statement was intended to be a “shot across the bow” of the media-recipients so that they understood the seriousness with which Ms. Maxwell considered the publication of plaintiff's obviously false allegations and the legal indefensibility of their own conduct. See id. 4 17. Selectively excerpting from the statement would seriously undermine this purpose by changing the force of the message to the media-recipients. Under these circumstances, selective, partial and out-of-context republication of Mr. Barden’s deliberate and carefully crafted message to the media-representatives, as a matter of law, cannot result in defamation liability for Ms. Maxwell. Accordingly, the Court should enter partial summary judgment. B. Because plaintiff is a limited public figure, imposing liability upon Ms. Maxwell for republication of the January 2015 statement would violate the First Amendment. As this Court recognized in Davis, New York Times y. Sullivan'® and its progeny “preclude states from imposing liability without fault in actions for defamation, especially by public figures.” 580 F. Supp. at 1097 (citing, inter alia, Gertz v. Robert Welch, Inc., 418 U.S. 323 (1974)). This principle precludes the imposition of liability for republication of an allegedly 10376 U.S. 254 (1964).

Case 18-2868, Document 276, 08/09/2019, 2628224, Page24 of 77 defamatory statement on a party who had no “actual . . . responsibility for the decision to republish” the statement. Jd. A public figure includes a person who “voluntarily injects himself or is drawn into a particular public controversy and thereby becomes a public figure for a limited range of issues.” Gertz, 418 U.S. at 351; see, e.g., James, 353 N.E.2d at 839 (public figure includes those who have “thrust themselves to the forefront of particular public controversies in order to influence the resolution of the issues involved”). The evidence that plaintiff is a public figure is overwhelming, particularly in connection with the subject matters and issues addressed by and underlying the January 2015 statement. See This Motion §§ 51-54. In the case at bar, Ms. Maxwell and her agents had no responsibility for any media organization’s decision to republish the January 2015 statement, and they did not participate in any such decision. See EXHIBITS J § 24 & K 4 2-3. Liability for republication by media organizations of the January 2015 statement therefore is precluded under the First Amendment. C. Plaintiff should be barred from introducing into evidence any republication of an excerpt from the January 2015 statement. In Geraci, the plaintiff suggested in a letter to the Long Island fire district where defendant was a commissioner that defendant had engaged in self-dealing in the district’s purchase of fire trucks. At trial the plaintiff sought to introduce into evidence portions of a Newsday article that republished parts of the defendant’s letter. Defense counsel objected, arguing it was inflammatory and prejudicial. Plaintiff's counsel later argued the article “was not being offered as a republication, but on the issue of damages to show how far the allegations had circulated.” 938 N.E.2d at 920. Additionally, plaintiffs counsel argued that the defendant “should have reasonably anticipated” that his letter to the fire district “would be newsworthy.” Id. The trial court admitted the article, and the Appellate Division affirmed. 17

Case 18-2868, Document 276, 08/09/2019, 2628224, Page25 of 77 The New York Court of Appeals reversed. The risk of admitting such evidence, the court held, is the jury may “charge against defendant a separate, distinct libel (not pleaded in [the] complaint) by someone else, contrary to the rule that [t]he original publisher of a libel is not responsible for its subsequent publication by others.” Geraci, 938 N.E.2d at 921. Accordingly, the court held, “‘[A]bsent a showing that [defendant] approved or participated in some other manner in the activities of the third-party republisher{,]’ there is no basis for allowing the jury to consider the article containing the republished statement as a measure of plaintiff's damages attributable to defendants.” /d. (emphasis supplied; quoting Karaduman v. Newsday, Inc., 416 N.E.2d 557, 560 (1980)). Neither Ms. Maxwell nor her agents approved or participated in any activity of any media organization in its decision to publish or not to publish any part of the January 2015 statement. EXHIBIT J § 2; K 4 2-3.. Accordingly, “there is no basis for allowing the jury to consider [any] article containing the republished statement as a measure of plaintiff's damages attributable to [Ms. Maxwell],” id. Plaintiff should be barred from introducing any evidence of any republication of the January 2015 statement by any non-party. See, e.g., Soley v. Wasserman, No. 8 CIV. 9262 KMW FM, 2013 WL 3185555, at *8 (S.D.N.Y. June 21, 2013) (precluding plaintiff from adducing evidence intended to establish claim on which court had entered partial summary judgment). Il. Summary judgment is warranted under the New York Constitution. A. The January 2015 statement constitutes nonactionable opinion. ““Whether particular words are defamatory presents a legal question to be resolved by the court in the first instance.’” Germain v. M & T Bank Corp., 111 F. Supp. 3d 506, 534 (S.D.N.Y. 2015) (brackets omitted; quoting Celle v. Filipino Reporter Enters. Inc., 209 F.3d 163,

Case 18-2868, Document 276, 08/09/2019, 2628224, Page26 of 77 177 (2d Cir. 2000)); accord, e.g., Aronson v. Wiersma, 483 N.E.2d 1138, 1139 (N.Y. 1985). New York defamation law applies. Doc.37 at 6 n.2. “Tt is a settled rule that expressions of an opinion false or not, libelous or not, are constitutionally protected and may not be the subject of private damage actions.” Steinhilber v. Alphonse, 501 N.E.2d 550, 550 (N.Y. 1986) (internal quotations omitted). Whether a challenged statement is fact or opinion is a question of law to be decided by the Court. Enigma Software Grp. USA, LLC y. Bleeping Computer LLC, No. 16 CIV. 57 (PAE), 2016 WL 3773394, at *11 (S.D.N.Y. July 8, 2016); accord, e.g., Steinhilber, 501 N.E.2d at 553. In Immuno AG y. Moor-Jankowski,'' the New York Court of Appeals declared that the New York Constitution provides greater protection to opinion than the First Amendment of the United States Constitution. The court recognized that in Milkovich v. Lorain Journal Co., 497 U.S. 1 (1990), the United States Supreme Court reversed a state court decision dismissing a complaint on the ground that the allegedly defamatory statement was nonactionable opinion. The Supreme Court held there is no “wholesale defamation exemption” protecting opinion. The First Amendment analysis under Milkovich, the New York court observed, was one-dimensional: the trial court should look first to the allegedly defamatory statement’s specific words as commonly understood and then determine whether the statements were “verifiable”; if the statements were verifiable, then they were actionable statements of fact. See Immuno AG, 567 N.E.2d at 1274-75. The Supreme Court’s holding made it clear that it would not consider as part of the First Amendment analysis “the full context of the article in which the challenged statements appear, and the broader social context or setting surrounding the communication.” Jd. at 1274. "567 N.E.2d 1270 (N.Y. 1991).

Case 18-2868, Document 276, 08/09/2019, 2628224, Page27 of 77 The Immuno AG Court of Appeals held that Article I, Section 8, of the New York Constitution required a multidimensional approach to the determination whether an allegedly defamatory statement constitutes constitutionally protected opinion. The court gave numerous reasons. New York’s “expansive” constitutional guarantee of speech was formulated and adopted before the application of the First Amendment to the states; “[i]t has long been our standard in defamation actions” to consider factors beyond whether facts are “verifiable”; and the court was concerned that if “‘type of speech’ is to be construed narrowly[,] . . . insufficient protection may be accorded to central values protected by the law of this State.” /d. at 1277-78. The Immuno AG court reaffirmed that where a defendant alleges that the subject statement is opinion, Steinhilber supplies the analytical framework. /d. at 1280. Steinhilber held that whether an allegedly defamatory statement is fact or nonactionable opinion should be decided based on four factors: (1) an assessment of whether the specific language in issue has a precise meaning which is readily understood or whether it is indefinite and ambiguous; (2) a determination of whether the statement is capable of being objectively characterized as true or false; (3) an examination of the full context of the communication in which the statement appears; and (4) a consideration of the broader social context or setting surrounding the communication including the existence of any applicable customs or conventions which might signal to readers or listeners that what is being read or heard is likely to be opinion, not fact. 501 N.E.2d at 554. Application of these factors to the January 2015 statement compels the conclusion that the allegedly defamatory words, phrases and clauses are nonactionable opinion. Whether the specific language in issue has a precise meaning which is readily understood or whether it is indefinite and ambiguous. The three sentences plaintiff alleges are 20

Case 18-2868, Document 276, 08/09/2019, 2628224, Page28 of 77 defamatory are indefinite and ambiguous. The first says plaintiffs “allegations” against Ms. Maxwell are “untrue.” But plaintiff has made many dozens of allegations against Ms. Maxwell, and some are provably false. See This Motion, at {J 37-50. The statement does not specify which of the allegations are untrue. The second statement is that the “original allegations” have been “shown to be untrue.” The “original allegations” were first revealed in the 2011 Churcher articles. Plaintiff made many dozens of allegations “originally.” The statement does not specify which of the “original” allegations were shown to be untrue. Some have been shown to be untrue. See This Motion, at 53-65. The third statement is that plaintiff's “claims” are “obvious lies.” This too is indefinite and ambiguous. Plaintiff has made many dozens of claims. The statement does not specify which ones are being referenced. More importantly, it does not say how or why some of the claims are “obvious” lies. Regardless, some of plaintiff's claims are “obvious lies.” See This Motion, at 53-65. Whether the three sentences in the January 2015 statement are capable of being objectively characterized as true or false. Can the three sentences be characterized as true or false? They cannot, because the statement does not specify which of the many dozens of allegations plaintiff has made are “untrue” and “shown to be untrue,” and which of plaintiff's many dozens of “claims” are “obvious lies.” It is axiomatic that the plural form of a word, e.g., “allegations” and “claims,” universally denotes—only—‘‘more than one,” People v. Kocsis, 28 N.Y.S.3d 466, 471 (App. Div. 2016) (emphasis supplied). See, e.g., Lehman Bros. Commercial Corp. v. Minmetals Int’l Non-Ferrous Metals Trading Co., No. 94 CIV. 8301(JFK), 1995 WL 380119, at *6 n.2 (S.D.N.Y. June 26, 1995). So for Steinhilber purposes it is dispositive of the fact versus opinion question if we can 21

Case 18-2868, Document 276, 08/09/2019, 2628224, Page29 of 77 identify wo instances in which plaintiff's allegations or claims! are incapable of being proved true or false. Such examples abound. It cannot be proven true or false whether Ms. Maxwell “appreciated the immunity granted”! under the Epstein plea agreement or whether she “act[ed] as a ‘madame’ for Epstein.”'* That is because these are plaintiffs counsel’s arguments or opinions. The January 2015 statement asserts that these allegations/claims are “false” or “obvious lies.” That assertion cannot be proven true or false under Steinhilber. The full context of the communication in which the statement appears. This factor “is often the key consideration in categorizing a statement as fact or opinion.” Davis v. Boeheim, 22 N.E.3d 999, 1006 (N.Y. 2014) (internal quotations omitted). In deciding whether a statement is defamatory, “[t]he words must be construed in the context of the entire statement or publication as a whole, tested against the understanding of the average reader.” Aronson v. Wiersma, 483 N.E.2d 1138, 1139 (1985); accord Elias v. Rolling Stone LLC, No. 15-CV-5953 (PKC), 2016 WL 3583080, at *6 (S.D.N.Y. June 28, 2016). “It is the duty of the court, in an action for libel, to understand the publication in the same manner that others would naturally do. The construction which it behooves a court of justice to put on a publication which is alleged to be libelous is to be derived as well from the expressions used as "In the context of the January 2015 statement, an “allegation” is synonymous with a “claim.” See, e.g., Maule v. Philadelphia Media Holdings, LLC, No. CIV.A. 08-3357, 2010 WL 914926, at *10 (E.D. Pa. Mar. 15, 2010); see generally Black’s Law Dictionary 68 (5" ed. 1979) (defining “allegation” as “[t]he assertion, claim, declaration, or statement of a party to an action, made in a pleading, setting out what he expects to prove”), quoted with approval in Martin v. City of Oceanside, 205 F. Supp. 2d 1142, 1147 (S.D. Cal. 2002), aff’d, 360 F.3d 1078 (om Cir. 2004). SExuisit D, at 4. "Wd. 22

Case 18-2868, Document 276, 08/09/2019, 2628224, Page30 of 77 from the whole scope and apparent object of the writer.” James v. Gannett Co., 353 N.E.2d 834, 838 (N.Y. 1976); accord, e.g., Chau v. Lewis, 935 F. Supp. 2d 644, 665 (S.D.N.Y. 2013). In general the trial court should view allegedly defamatory statements from the perspective of the average member of the public. Statements directed to a specific audience, however, are considered from the viewpoint of that audience. Instructive is this Court’s analysis of the perspective from which it should assess an allegedly defamatory article on boxing published to sports readers: The issue of how the “average reader” would construe the statements is certainly a fair one, for the question of whether statements are defamatory turns on how the audience to whom the statements are addressed would interpret them. .. . As the New York State Court of Appeals has explained in [a] boxingdefamation case[]: . . . . “The words are to be construed not with the close precision expected from lawyers and judges but as they would be read and understood by the public to which they are addressed... .” Here, the statements in question were addressed to readers of an Internet boxing website and the sports pages of daily newspapers. The statements must be considered from their viewpoint. As Judge Martin . . . held [in Horne v. Matthews, No. 97 Civ. 3605(JSM), 1997 WL 598452 (S.D.N.Y. Sept. 25, 1997)]: “An article on the sports page of a newspaper should be viewed from the perspective of the audience to whom it is addressed, i.e., the understanding of “a sophisticated and sports-conscious reader.” Dibella v. Hopkins, No. 01 CIV. 11779 (DC), 2002 WL 31427362, at *2 (S.D.N.Y. Oct. 30, 2002) (emphasis supplied; citation omitted). The entirety of the email containing the January 2015 statement from Mr. Gow sent to various media representatives reads: To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation 23

Case 18-2868, Document 276, 08/09/2019, 2628224, Page31 of 77 Jane Doe 3 is Virginia Roberts—so not a new individual. The allegations made by Victoria Roberts [sic] against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. EXHIBIT F (italics and underscoring supplied). Plaintiff listed the underscored clauses/phrases in the Complaint as the “deliberate falsehoods,” Doc.1 4] 30, and “false and defamatory statements,” id. 32, plaintiff is suing on.'* As discussed above, it is improper to remove from their context and isolate allegedly defamatory words, phrases and clauses of sentences from an allegedly defamatory publication. Instead, the allegedly defamatory words, phrases and clauses must be (a) “construed in the context of the entire statement or publication as a whole”;'® (b) considered “from the whole scope and apparent object of the writer”;!’ and (c) “viewed from the perspective of the audience to whom it is addressed.”'® The statement was directed at a discrete number of —some 30—members of the media in reply to their request for a response from Ms. Maxwell to Ms. Giuffre’s CVRA joinder motion. 'SPlaintiff also alleges that Ms. Maxwell slandered her on January 4, 2015, when responding to a question posed to her while she was on a Manhattan street. Doc.1 § 37. This allegedly defamatory statement is addressed in Argument IV, below. ‘© Aronson, 483 N.E.2d at 1139. "James, 353 N.E.2d at 838. 'SDibella, 2002 WL 31427362, at *2. 24

Case 18-2868, Document 276, 08/09/2019, 2628224, Page32 of 77 Mr. Barden, who prepared the January 2015 statement, did not intend the January 2015 statement to be a traditional press release solely to disseminate information to the media. EXHIBIT K § 15. So he did not request that Mr. Gow or any other public relations specialist prepare the statement. Id. Instead, Mr. Gow served only as Mr. Barden’s conduit to the media representatives who had requested a response to the joinder motion allegations and who Mr. Barden believed might republish those allegations. Jd. Mr. Barden intended the statement to mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of plaintiff's false allegations. Jd. § 16. He believed this could be accomplished by suggesting to the media that, among other things, they should subject plaintiff's allegations to inquiry and scrutiny. /d. For example, he noted that plaintiff's allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicised as news.” Jd. Mr. Barden also intended the January 2015 statement to be “‘a shot across the bow” of the media, which he believed had been unduly eager to publish plaintiff's allegations without conducting any inquiry of their own. /d. § 17. So Mr. Barden stated repeatedly that plaintiff's allegations were “defamatory.” Jd. In this sense, the statement was very much intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiffs obviously false allegations and the legal indefensibility of their own conduct. Id. Consistent with Mr. Barden’s purposes for the statement, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms Maxwell” (emphasis supplied). /d. §j 19. The statement was intended to be a single, onetime-only, comprehensive response—quoted in full—to plaintiff's December 30, 2014, 25

Case 18-2868, Document 276, 08/09/2019, 2628224, Page33 of 77 allegations that would give the media Ms. Maxwell’s response. Jd. The purpose of the prefatory statement was to inform the media-recipients of this intent. Jd. We note that plaintiff in her Complaint makes the same mistake as the Steinhilber plaintiff—extracting words and phrases from their opinion context so that she can claim the assertion of a “defamatory” fact. See Doc.1 § 30. That is not permissible. See Steinhilber, 501 N.E.2d at 555 (“The sentence which plaintiff selects from the message and claims is “factually laden”—impugning her as lacking in “talent, ambition, and initiative’*—is preceded and followed by statements which are clearly part of the attempt at humor prevailing throughout... .”). The broader social context or setting surrounding the communication, including the existence of any applicable customs or conventions which might signal to readers that what is being read is likely to be opinion, not fact. This factor is concerned with “the factual background” leading up to the preparation of the statement. It is a critical factor here. In December 2014, plaintiff and her lawyers had timed for maximum effect—during the slow news cycle between Christmas and New Year’s Day—the public filing of a superfluous motion filled with salacious and provocative allegations of “sexual abuse” and “sexual trafficking” involving wealthy and prominent Americans. Plaintiff deliberately placed Ms. Maxwell in the middle of the abuse and trafficking, alleging that she recruited plaintiff into the sexual abuse/trafficking scheme and engaged in numerous criminal acts. Importantly, three years earlier when plaintiff was interviewed extensively by Churcher for two lengthy articles published in March 2011, plaintiff's allegations concerning Ms. Maxwell were very much different. In the articles discussing plaintiff's “shocking account”'’ of being ‘EXHIBIT A, at 2. 26

Case 18-2868, Document 276, 08/09/2019, 2628224, Page34 of 77 9920 sexually exploited by Epstein, Prince Andrew and Epstein’s “male peers,” plaintiff made virtually none of what Judge Marra found were “unnecessary”! and “lurid details””? about how Ms. Maxwell allegedly had subjected her to sexual abuse and trafficking. After plaintiff filed the CVRA motion, some thirty reporters contacted Ms. Maxwell’s press representative, Mr. Gow, for Ms. Maxwell’s response. As Ms. Maxwell’s lawyer, Mr. Barden undertook that task. Relying on his knowledge of the 2011 articles publishing plaintiff's allegations and drawing on his experience and training as a lawyer, Mr. Barden crafted a response with the goal of discrediting plaintiff and what the statement called plaintiff's “new” allegations. To that end Mr. Barden contrasted plaintiff's “old” allegations from 2011 with the “new” 2014 allegations. The second paragraph of the statement is indicative of this strategy: “Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by [Ms. Giuffre] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies.” EXHIBIT F (emphasis supplied). Having established the dramatic difference between these sets of allegations suggesting plaintiff was fabricating more and more-salacious allegations as she had more time to manufacture them, Mr. Barden added the third paragraph: “[Ms. Giuffre’s] claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory.” /d. (emphasis supplied). Mr. Barden’s arguments constitute “pure opinion,” Steinhilber, 501 N.E.2d at 552. They take established and revealed facts—plaintiff’s modest 2011 allegations to a newspaper reporter and plaintiff's expansive, unnecessary and lurid 2014 allegations in a motion to open the door to Td. 1EXHIBIT E, at 5. 1d. 27

Case 18-2868, Document 276, 08/09/2019, 2628224, Page35 of 77 criminal prosecutions of (and civil lawsuits against) wealthy and prominent men around the world—to draw an obvious inference that plaintiff was (more) truthful in the 2011 articles and engaged in massive manufacturing of fiction in the 2014 joinder motion. There is no limit to the subject matters on which pure opinions may be expressed with constitutional immunity, including whether a person believes another is “lying” or is a “liar.” See, e.g., Indep. Living Aids, Inc. v. Maxi-Aids, Inc., 981 F. Supp. 124, 128 (E.D.N.Y. 1997) (granting summary judgment: “Read in the context of the entire article, Zaretsky’s remarks, calling Sandler and others ‘liars,’ can only be understood as a denial of their accusations. . .. Even the most careless reader must have perceived that the words were no more than rhetorical hyperbole, a vigorous epithet used by Zaretsky who considered himself unfairly treated and sought to bring what he alleged were the true facts to the readers. The epithet ‘liar’ in this context, standing by itself, merely expressed the opinion that anyone who persisted in accusing Zaretsky of improper business practices could not be telling the truth. Since the basis for this opinion was fully set forth, the communication of Zaretsky’s views cannot be libelous.”’) (citations, ellipsis, brackets and internal quotations omitted); see Gross v. New York Times, 623 N.E.2d 1163, 1169 (N.Y. 1993) (“[E]ven when uttered or published in a. . . serious tone, accusations of criminality could be regarded as mere hypothesis and therefore not actionable if the facts on which they are based are fully and accurately set forth and it is clear to the reasonable reader . . . that the accusation is merely a personal surmise built upon those facts. In all cases, whether the challenged remark concerns criminality or some other defamatory category, the courts are obliged to consider the communication as a whole, as well as its immediate and broader social contexts, to determine whether the reasonable listener . . . is likely to understand the remark as an assertion of provable fact.”). 28

Case 18-2868, Document 276, 08/09/2019, 2628224, Page36 of 77 Mr. Barden’s inference from disclosed facts qualifies as “pure opinion,” Steinhilber, 501 N.E.2d at 552. Accordingly, that Mr. Barden characterized plaintiff's 2014 allegations harshly as “obvious lies” as opposed to “untruths” or some softer term is of no moment. “[U]nder New York law, pure opinion . . . is not actionable because expressions of opinion, as opposed to assertions of fact, are deemed privileged and, no matter how offensive, cannot be the subject of an action for defamation.” Ratajack v. Brewster Fire Dep't, Inc. of the Brewster-SE Joint Fire Dist., 178 F. Supp. 3d 118, 158 (S.D.N.Y. 2016) (internal quotations and ellipsis omitted; brackets altered); accord, e.g., Mann v. Abel, 885 N.E.2d 884, 885-86 (N.Y. 2008). The drawing of such inferences would be constitutionally protected even under the standards of the First Amendment that are less protective of opinion than is Article I, Section 8, of the New York Constitution. See Adelson v. Harris, 973 F. Supp. 2d 467, 490 (S.D.N.Y. 2013) (“In determining whether a statement constitutes constitutionally protected opinion, courts also look to the specific context of the statement. When looking at a statement’s specific context, of particular importance is the principle that when an author outlines the facts available to him, thus making it clear that the challenged statements represent his own interpretation of those facts and leaving the reader free to draw his own conclusions, those statements are generally protected by the First Amendment.”) (internal quotations and brackets omitted). The application of the four Steinhilber factors confirms that the three phrases and/or clauses plaintiff alleges are defamatory are in fact part of a statement that taken as a whole constitutes nonactionable opinion. The premise of plaintiff's Complaint is that once she is able to identify references in the January 2015 statement to any assertion of fact that potentially is subject to proof, e.g., the truth or falsity of her many dozens of allegations old and new, then she has a viable defamation claim. That ignores the teaching of Steinhilber and Immuno AG. As the 29

Case 18-2868, Document 276, 08/09/2019, 2628224, Page37 of 77 Steinhilber court held, “even apparent statements of fact may assume the character of statements of opinion, and thus be privileged, when made in public debate, heated labor dispute, or other circumstances in which an audience may anticipate the use of epithets, fiery rhetoric or hyperbole.” /d. (internal quotations and brackets omitted); see Gross, 623 N.E.2d at 1169 (“we stress once again our commitment to avoiding the ‘hypertechnical parsing’ of written and spoken words for the purpose of identifying ‘possible “fact[s]’” that might form the basis of sustainable libel action’’) (quoting Immuno AG, 567 N.E.2d at 1282). To the same effect is this Court’s citation to a Louisiana Supreme Court decision for the proposition that “‘[w]ords which, taken by themselves, would appear to be a positive allegation of fact, may be shown by the context to be a mere expression of opinion or argumentative influence.’” Adelson, 973 F. Supp. 2d at 488 (emphasis supplied; quoting Mashburn v. Collin, 355 So. 2d 879, 885 (La. 1977)). It also is important to take into account, as Steinhilber requires, that Mr. Barden was directing the January 2015 statement to a discrete number of media representatives who were aware of plaintiff’s “original” and “new,” joinder-motion allegations and who were requesting a response from Ms. Maxwell to the “new” allegations. These newspaper reporters and other media representatives would have the point Mr. Barden was making—the opinion he was expressing—namely, that there was good reason to believe plaintiff was fabricating allegations for her purposes. In the context of the media circus that ensued the public filing of the joinder motion and the media’s repeated and insistent requests for an immediate response from Ms. Maxwell, it is highly unlikely any media-recipients of the January 2015 statement expected anything other than a statement equivalent to the March 2011 statement condemning the allegations; and it is highly likely all the media-recipients understood the statement to be a 30

Case 18-2868, Document 276, 08/09/2019, 2628224, Page38 of 77 forceful argument that plaintiffs shifting and inconsistent stories about what allegedly happened rendered her inherently unbelievable and proved her increasingly provocative and lurid allegations were “obvious lies.” These are precisely the messages Mr. Barden sent to them. The general nature of Mr. Barden’s assertions (“allegations,” “original allegations,” “claims”), the distinction between plaintiff's “original” and “new” allegations, and the inferences he drew from comparing the “original” and “new” allegations—together—powerfully demonstrate that the January 2015 statement was nothing more than opinion. B. In this Rule 56 proceeding, this Court’s Rule 12(b)(6) opinion does not control the question of law whether the January 2015 statement constitutes nonactionable opinion. In its Rule 12(b)(6) opinion the Court, relying on Davis v. Boeheim, 22 N.E.3d 999 (2014), ruled that the three allegedly defamatory statements in the January 2015 statement (see Doc.1 § 30(a)-(c)) have a specific and readily understood factual meaning, are capable of being proven true or false, and “clearly constitute fact to the reader.” Doc.37 at 9. We respectfully suggest the Court’s Rule 12(b)(6) decision does not control in this Rule 56 proceeding. To begin with, the standards for deciding a Rule 12(b)(6) motion are substantially different from the standards for deciding a Rule 56 motion. As the Court noted, in deciding a 12(b)(6) motion the court must accept as true the factual allegations and draw all inferences in the plaintiff's favor; a plaintiff need only state a claim that is “plausible on its face.” Jd. at 3 (internal quotations omitted). In contrast, in deciding a Rule 56 motion the plaintiff defending the motion may not “rest on [the] allegations” in her complaint. Anderson, 477 U.S. at 249. The difference in the standards is crucial here. As this Court recognized, “‘[t]he dispositive inquiry’” for purposes of deciding whether an allegedly defamatory statement is fact or nonactionable opinion is whether “‘a reasonable reader could have concluded that the statements were conveying facts about the plaintiff.” 31

Case 18-2868, Document 276, 08/09/2019, 2628224, Page39 of 77 Doc.37 at 7 (quoting Davis, 22 N.E.3d at 1005). To answer that inquiry, the Court applied the three factors enumerated in Davis. See id. These three factors are the same as the four factors in Immuno AG; the difference is that the Davis court collapsed the Immuno AG’s third and fourth factors into one. See Davis, 22 N.E.3d at 1005. As framed by the Davis court, the third factor is “whether either the fill context of the communication in which the statement appears or the broader social context and surrounding circumstances are such as to signal . . . readers or listeners that what is being read or heard is likely to be opinion, not fact.” /d. (internal quotations omitted; emphasis supplied), quoted in Doc.37 at 7. Although this Court did not note this in its opinion, this third factor “is often the key consideration in categorizing a statement as fact or opinion.” /d. at 1006 (emphasis supplied). As in Davis, which also was decided on a Rule 12(b)(6) motion,” this Court when considering the third factor did not have the benefit of any of the evidence presented in this motion. That is to say, the Court did not have the “full context of the” July 2015 statement or the “broader social context and surrounding circumstances” of the statement, since none of the evidence presented in this Motion was pleaded in the Complaint. Nor, in the context of the 12(b)(6) motion, did the Court consider that the relevant “readers” of the July 2015 statement were not the “average reader” in the general public, but a “cynical””’ and “sophisticated””° group of about 30 reporters and journalists who were knowledgeable about plaintiff's allegations of being the victim of sexual abuse and sexual Davis, 22 N.E.3d at 1001. *4 Aronson, 483 N.E.2d at 1139. Steven Shiffrin, The Politics of the Mass Media and the Free Speech Principle, 69 Ind. L.J. 689, 702 (1994). *6Dibella, 2002 WL 31427362, at *2. 32

Case 18-2868, Document 276, 08/09/2019, 2628224, Page40 of 77 trafficking. Viewing the July 2015 statement from the perspective of these reporters and journalists—the only persons who received the July 2015 statement—presents a different landscape in the “fact versus opinion” analysis. Applying the third factor with the benefit of the Rule 56 records compels a conclusion different from the one this Court reached on the barren Rule 12(b)(6) record. For example, this Court did not consider that the media-recipients of the July 2015 statement would have understood the statement in precisely the way Mr. Barden intended: Based on a comparison of dramatic differences between her “original” and “new” allegations, Ms. Giuffre is a teller of falsehoods—is a liar—and cannot be trusted, and her new CVRA joint-motion allegations, which deviated so substantially from her originally allegations, are falsehoods—proven false by her increasingly provocative and lurid versions of her story of “victimhood.” See generally Exhibit J. Ill. The pre-litigation privilege bars this action. Statements pertinent to a good faith anticipated litigation made by attorneys (or their agents under their direction’) before the commencement of litigation are privileged and “no cause of action for defamation can be based on those statements,” Front, Inc. v. Khalil, 28 N.E.3d 15, 16 (N.Y. 2015). So long as there was “a good faith basis to anticipate litigation,” a statement concerning either “actual litigation or prelitigation matters” is subject to an “absolute privilege.” Flomenhaft v. Finkelstein, 8 N.Y.S.3d 161, 164 n.2 (App. Div. 2015) (emphasis supplied); accord Kirk v. Heppt, 532 F. Supp. 2d 586, 593 (S.D.N.Y. 2008). The privilege covers statements made in connection with “pending or “contemplated litigation.” Goldstein v. Cogswell, No. 85 CIV. 9256 (KMW), 1992 WL 131723, at *27 n.32 (S.D.N.Y. June 1, 1992) It covers statements made outside court, including in written 7See Chambers v. Wells Fargo Bank, N.A., No. 2016 WL 3533998, at *8 (D.N.J. June 28, 2016); see generally Hawkins v. Harris, 661 A.2d 284, 289-91 (N.J. 1995). 33

Case 18-2868, Document 276, 08/09/2019, 2628224, Page41 of 77 communications “between litigating parties or their attorneys.” Klein v. McGauley, 29. A.D.2d 418, 420 (N.Y. App. Div. 1968), cited with approval in Petrus v. Smith, 91 A.D.2d 1190, 1191 (N.Y. App. App. Div. 1983). It covers “cease and desist letters.” Khalil, 28 N.E.3d at 19. And it covers “all pertinent communications among the parties, counsel, witnesses and the court,” regardless “[w]hether a statement was made in or out of court, was on or off the record, or was made orally or in writing.” Frechtman v. Gutterrnan, 979 N.Y.S. 2d 58 (App. Div. 2014) (quoting Sexter v. Warmflash, P.C. v. Margrabe, 828 N.Y.S. 2d 315 (App. Div. 2007)). When the pre-litigation privilege is invoked in connection with an allegedly defamatory statement made during pending or contemplated litigation, “any doubts are to be resolved in favor of pertinence.” Flomenhaji, 8 N.Y.S.3d at 164. “[T]he test to determine whether a statement is pertinent to litigation is “extremely liberal,” such that the offending statement, to be actionable, must have been ‘outrageously out of context.” Id. at 164-65 (emphasis supplied; quoting Black v. Green Harbour Homeowners’ Ass'n, 798 N.Y.S.2d 753 (App. Div. 2005), and Martirano vy. Frost, 255 N.E.2d 693 (1969)); Kirk, 532 F. Supp. 2d at 593. In denying Ms. Maxwell’s motion to dismiss the Complaint based on the pre-litigation privilege, this Court limited its analysis of the privilege to whether under the Rule 12(b)(6) standard plaintiff had sufficiently pleaded that the January 2 and 4 statements were made with actual malice. Doc.37 at 18-19. The Court’s Rule 12(b)(6) analysis does not bear on the question presented here, for two reasons. 2: Under the “substantive law””* actual malice is not relevant to the pre-litigation defense. The New York Court of Appeals in Khalil held that to prevail on the pre-litigation privilege the defendant need only establish one element: the allegedly defamatory statement at issue was °8 Anderson, 477 U.S. at 248. 34

Case 18-2868, Document 276, 08/09/2019, 2628224, Page42 of 77 “pertinent to a good faith anticipated litigation.” 28 N.E.3d at 16. Upon establishing that element, summary judgment for the defendant is required. See id. Additionally, this is a summary judgment proceeding. Plaintiff cannot rely on the allegations of her Complaint. Evidence is required. The following evidence is not in dispute. By January 2015 Ms. Maxwell had retained British Solicitor Philip Barden to represent and advise her in connection with plaintiff's publication in the British press of salacious, defamatory allegations of criminal sexual abuse during the period 1999-2002. EXHIBIT K §f 8-10. Mr. Barden in turn engaged UK press agent Ross Gow. /d. § 9. Mr. Barden prepared the January 2015 statement and instructed Mr. Gow to transmit it via email to members of the UK media who had made inquiry about the allegations in the joinder motion. Jd. J 10. Mr. Barden did not intend the January 2015 statement as a traditional press release solely to disseminate information to the media. /d. J 15. This is why he intentionally did not request that Mr. Gow or any other public relations specialist prepare the statement. /d. Instead, Mr. Gow served as his conduit to the media representatives who had requested a response to the joinder motion allegations and who Mr. Barden believed might republish those allegations. Jd. Mr. Barden had two purposes in preparing and causing the statement to be disseminated to those media representatives. First, he wanted to mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of plaintiff's false allegations. Jd. § 16. He believed these ends could be accomplished by suggesting to the media that, among other things, they should subject plaintiff’s allegations to inquiry and scrutiny. /d. For example, he noted in the January 2015 statement that plaintiff's allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicised as news.” Id. 35

Case 18-2868, Document 276, 08/09/2019, 2628224, Page43 of 77 Second, Mr. Barden intended the January 2015 statement to be “a shot across the bow” of the media, which he believed had been unduly eager to publish plaintiff's allegations without conducting any inquiry of their own. /d. § 17. This was the purpose of repeatedly stating that plaintiff’s allegations were “defamatory.” Jd. The statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiff's obviously false allegations and the legal indefensibility of their own conduct. Id. At the time Mr. Barden directed the issuance of the statement, he was contemplating litigation against the media-recipients as an additional means to mitigate and prevent harm to Ms. Maxwell. Jd. § 28. Toward this end, he prepared the statement so that it made clear Ms. Maxwell “strongly denie[d] the allegations of an unsavoury nature,” declared the republications of the allegations to be false, gave the press-recipients notice that the republications of the allegations “are defamatory,” and informed them that Ms. Maxwell was “reserv[ing] her right to seek redress.” Jd. § 30. In any such UK defamation, or other related, action Ms. Giuffre would be a defendant or a witness. Jd. § 29. The question presented is whether Mr. Barden’s statement, which he directed to be sent to various media representatives, is “pertinent to a good faith anticipated litigation,” Khalil, 28 N.E.3d at 16. The requirement of “good faith” anticipated litigation is intended to prevent attorneys (or their agents) from “bully[ing], harass[ing], or intimidat[ing] their client’s adversaries by threatening baseless litigation or by asserting unmeritorious claims, unsupported in law and fact, in violation of counsel’s ethical obligations,” id. at 19. The statement Mr. Barden prepared and caused to be issued was not intended to bully, harass or intimidate the press-recipients, i.e., the 36

Case 18-2868, Document 276, 08/09/2019, 2628224, Page44 of 77 potential defendants in an action by Ms. Maxwell for defamation. See EXHIBIT K §§ 26-30. Nothing about the statement on its face suggested bullying, harassing or intimidating the pressrecipients (or anyone else). At the time Mr. Barden directed the issuance of the statement, he had sufficient factual and legal grounds to pursue in good faith a defamation action against one or more of the press-recipients for republishing plaintiff's allegations. See generally id. §§ 8-30. That the statement was directed at the press-recipients—which had republished plaintiff's false allegations and was not directed at plaintiff—is irrelevant to the absolute privilege protecting pre-litigation communications. In /nternational Publishing Concepts, LLC v. Locatelli, \etters and emails detailing likely litigation and an intent to sue were extended the same pre-litigation privilege although sent to two non-parties who were only potentially affected by the litigation or witnesses to it. See also Kirk, 532 F. Supp. 2d at 593 (“The privilege is broad, and embraces anything that may possibly or plausibly be relevant to the litigation.”) (internal quotations omitted). The only issue remaining is whether the statement was pertinent to the contemplated litigation. Applying the “extremely liberal” test of pertinence, in which “any doubts are to be resolved in favor of pertinence,””’ the court must decide whether the allegedly defamatory statement is “outrageously out of context” in relation to the contemplated litigation. F/omenha/i, 8 N.Y.S.3d at 164-65 (internal quotations omitted). Nothing in the statement is “outrageously out of context.” Every statement was directly related to the press-recipients’ republication of plaintiff's false allegations against Ms. Maxwell. The January 4 statement also is absolutely privileged. According to plaintiff, Ms. Maxwell told a reporter on that date when asked to comment on plaintiff's joinder-motion °Flomenhaft, 8 N.Y .S.3d at 164 (internal quotations omitted). 37

Case 18-2868, Document 276, 08/09/2019, 2628224, Page45 of 77 allegations: “I am referring to the statement that was made.” Doc.1 § 32. Assuming arguendo the statement is defamatory,” it is absolutely privileged since it simply refers to an absolutely privileged statement. See, e.g., Klein, 29 A.D.2d at 420 (privilege protects communications “between litigating parties”); Frechtman, 979 N.Y.S.2d at 63 (privilege protects communications “made in or out of court, ... on or off the record, ... orally or in writing”) (internal quotations omitted). Under these circumstances the pre-litigation privilege is absolute and “no cause of action for defamation can be based on those statements,” Khalil, 28 N.E.3d at 16. The Court should enter summary judgment on plaintiff's defamation claim. IV. Ms. Maxwell’s January 4, 2015, statement is nonactionable. Plaintiff alleges that on January 4, 2015, a reporter approached Ms. Maxwell on a public street in Manhattan and “asked Maxwell about Giuffre’s allegations against Maxwell.” Doc.1 4/37. Plaintiff alleges that Ms. Maxwell responded with a single sentence: “‘I am referring to the statement that we made.”” /d. According to plaintiff, Ms. Maxwell’s statement was defamatory. See id. 4 37 & Count 14 5, at 8. Judgment should enter against plaintiff as to Ms. Maxwell’s statement. Adelson controls this portion of plaintiff's defamation claim. In Ade/son a non-profit organization during the 2012 presidential campaign published a statement on its website critical of Sheldon Adelson, a wealthy Republican donor. The statement alleged Adelson had donated “tainted” and “dirty” money to Governor Romney. Eight days later the organization withdrew the statement from its website. On the same day it issued a press release explaining that although 5As discussed in Argument IV, the January 4 statement is nonactionable. 38

Case 18-2868, Document 276, 08/09/2019, 2628224, Page46 of 77 it took down the statement, “we stand by everything we said, which was sourced from current, credible news accounts.” 973 F. Supp. 2d at 474. Adelson sued. He alleged that the statement was defamatory and that the press release constituted a republication of the defamatory statement. This court held that the statement contained only constitutionally protected opinion and was nonactionable. The court then rejected the defamation claim based on republication: “‘[A] mere reference to another writing that contains defamatory matter does not constitute an actionable repetition or republication.” Jd. (quoting Goforth v. Avemco Life Ins. Co., 368 F.2d 25, 28 n.7 (4th Cir.1966)). This is the settled rule. See In re Philadelphia Newspapers, LLC, 690 F.3d 161, 175 (3d Cir. 2012), as corrected (Oct. 25, 2012) (“under traditional principles of republication, a mere reference to an article, regardless how favorable it is as long as it does not restate the defamatory material, does not republish the material”); Salyer v. S. Poverty Law Ctr., Inc., 701 F. Supp. 2d 912, 916 (W.D. Ky. 2009) (“[T]he common thread of traditional republication is that it presents the material, in its entirety, before a new audience. A mere reference to a previously published article does not do that.”). Ms. Maxwell’s one-sentence response that merely referenced an earlier statement is nonactionable. This Court should enter partial summary judgment on the defamation claim to the extent it is based on Ms. Maxwell’s response. V. The defamation claim should be dismissed because the publication is substantially true. ““TA] statement is substantially true if the statement would not “have a different effect on the mind of the reader from that which the pleaded truth would have produced.” Franklin v. Daily Holdings, Inc., 21 N.Y.S.3d 6, 12 (App. Div. 2015) (quoting Biro v. Condé Nast, 883 F. Supp. 2d 441, 458 (S.D.N.Y. 2012) (quoting Jewell v. NYP Holdings, Inc., 23 F. Supp. 2d 348, 39

Case 18-2868, Document 276, 08/09/2019, 2628224, Page47 of 77 366 (S.D.N.Y.1998) (quoting Fleckenstein v. Friedman, 193 N.E. 537, 538 (1934)))). Indeed, it is well settled in New York “that an alleged libel is not actionable if the published statement could have produced no worse an effect on the mind of a reader than the truth pertinent to the allegation.” /d. (internal quotations omitted). “When the truth is so near to the facts as published that fine and shaded distinctions must be drawn and words pressed out of their ordinary usage to sustain a charge of libel, no legal harm has been done.” Fleckenstein, 193 N.E. at 538. For the reasons articulated in Argument VI, the January 2015 statement is substantially true as matter of law. VI. Plaintiff cannot establish actual malice by clear and convincing evidence. A. Facts. The following numbered facts are not in dispute and are sequentially numbered following the undisputed facts cited earlier. See This Motion at J 1-36. 37. Plaintiff lived independently from her parents with her fiancé long before meeting Epstein or Ms. Maxwell. After leaving the Growing Together drug rehabilitation facility in 1999, plaintiff moved in with the family of a fellow patient. EXHIBIT L at 7-8, 12-14. There she met, and became engaged to, her friend’s brother, James Michael Austrich. Jd. & at 19. She and Austrich thereafter rented an apartment in the Ft. Lauderdale area with another friend and both worked at various jobs in that area. /d. at 11, 13-17. Later, they stayed briefly with plaintiffs parents in the Palm Beach/Loxahatchee, Florida area before Austrich rented an apartment for the couple on Bent Oak Drive in Royal Palm Beach. Jd. at 17, 19, 25-27; EXHIBIT M. Although plaintiff agreed to marry Austrich, she never had any intention of doing so. EXHIBIT N at 127-128. 38. Plaintiff re-enrolled in high school from June 21, 2000 until March 7, 2002. th After finishing the 9" grade school year at Forest Hills High School on June 9, 1999, plaintiff re40

Case 18-2868, Document 276, 08/09/2019, 2628224, Page48 of 77 enrolled at Wellington Adult High School on June 21, 2000, again on August 16, 2000 and on August 14, 2001. ExHIBIT O. On September 20, 2001, Plaintiff then enrolled at Royal Palm Beach High School. /d. A few weeks later, on October 12, 2001, she matriculated at Survivors Charter School. Jd. Survivor’s Charter School was an alternative school designed to assist students who had been unsuccessful at more traditional schools. EXHIBIT P at 23-24. Plaintiff remained enrolled at Survivor’s Charter School until March 7, 2002. EXHIBIT O. She was present 56 days and absent 13 days during her time there. /d. Plaintiff never received her high school diploma or GED. EXHIBIT Q at 475, 483. Plaintiff and Figueroa went “back to school” together at Survivor’s Charter School. EXHIBIT P at 23-27. The school day there lasted from morning until early afternoon. Jd. at 23-27, 144-46. 39. During the year 2000, plaintiff worked at numerous jobs. In 2000, while living with her fiancé, plaintiff held five different jobs: at Aviculture Breeding and Research Center, Southeast Employee Management Company, The Club at Mar-a-Lago, Oasis Outsourcing, and Neiman Marcus. EXHIBIT R. Her taxable earnings that year totaled nearly $9,000. /d. Plaintiff cannot now recall either the Southeast Employee Management Company or the Oasis Outsourcing jobs. EXHIBIT Q at 470-471. 40. Plaintiff’s employment at the Mar-a-Lago spa began in fall 2000. Plaintiff's father, Sky Roberts, was hired as a maintenance worker at the The Mar-a-Lago Club in Palm Beach, Florida, beginning on April 11, 2000. ExHBiT S. Mr. Roberts worked there year-round for approximately 3 years. /d.; EXHIBIT T at 72-73. After working there for a period of time, Mr. Roberts became acquainted with the head of the spa area and recommended plaintiff for a job there. /d. at 72. Mar-a-Lago closes every Mother’s Day and reopens on November 1. EXHIBIT U at Mar-a-Lago0212. Most of employees Mar-a-Lago, including all employees of the spa area 41

Case 18-2868, Document 276, 08/09/2019, 2628224, Page49 of 77 such as “spa attendants,” are “seasonal” and work only when the club is open, i.e., between November 1| and Mother’s Day. EXHIBIT T at 72-73; EXHIBIT U at MAR-A-LAGO 0212; EXHIBIT V. Plaintiff was hired as a “seasonal” spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she had turned 17. 41. Plaintiff represented herself as a masseuse for Jeffrey Epstein. While working at the Mar-a-Lago spa and reading a library book about massage, plaintiff met Ms. Maxwell. Plaintiff thereafter told her father that she got a job working for Jeffrey Epstein as a masseuse. EXHIBIT T at 79. Plaintiff's father took her to Epstein’s house on one occasion around that time, and Epstein came outside and introduced himself to Mr. Roberts. Jd. at 82-83. Plaintiff commenced employment as a traveling masseuse for Mr. Epstein. Plaintiff was excited about her job as a masseuse, about traveling with him and about meeting famous people. EXHIBIT L at 56; EXHIBIT P at 126. Plaintiff represented that she was employed as a masseuse beginning in January 2001. EXHIBIT M; EXHIBIT N. Plaintiff never mentioned Ms. Maxwell to her thenfiancé, Austrich. EXHIBIT L at 74. Plaintiff's father never met Ms. Maxwell. EXHIBIT T at 85. 42. Plaintiff resumed her relationship with convicted felon Anthony Figueroa. In spring 2001, while living with Austich, plaintiff lied to and cheated on him with her high school boyfriend, Anthony Figueroa. EXHIBIT L at 68, 72. Plaintiff and Austrich thereafter broke up, and Figueroa moved into the Bent Oak apartment with plaintiff. EXHIBIT L at 20; EXHIBIT P at 28. When Austrich returned to the Bent Oak apartment to check on his pets and retrieve his belongings, Figueroa in Plaintiff's presence punched Austrich in the face. EXHIBIT X; EXHIBIT L at 38-45. Figueroa and plaintiff fled the scene before police arrived. EXHIBIT X. Figueroa was then a convicted felon and a drug abuser on probation for possession of a controlled substance. EXHIBIT Y. 42

Case 18-2868, Document 276, 08/09/2019, 2628224, Page5SO of 77 43. Plaintiff freely and voluntarily contacted the police to come to her aid in 2001 and 2002 but never reported to them that she was Epstein’s “sex slave.” In August 2001 at age 17, while living in the same apartment, plaintiff and Figueroa hosted a party with a number of guests. EXHIBIT Z. During the party, according to plaintiff, someone entered plaintiff's room and stole $500 from her shirt pocket. /d. Plaintiff contacted the police. She met and spoke with police officers regarding the incident and filed a report. She did not disclose to the officer that she was a “sex slave.” A second time, in June 2002, plaintiff contacted the police to report that her former landlord had left her belongings by the roadside and had lit her mattress on fire. EXHIBIT AA. Again, plaintiff met and spoke with the law enforcement officers but did not complain that she was the victim of any sexual trafficking or abuse or that she was then being held as a “sex slave.” Id. 44. From August 2001 until September 2002, Epstein and Maxwell were almost entirely absent from Florida on documented travel unaccompanied by Plaintiff. Flight logs maintained by Epstein’s private pilot Dave Rodgers evidence the substantial number of trips away from Florida that Epstein and Maxwell took, unaccompanied by Plaintiff, between August 2001 and September 2002. EXHIBIT BB. Rodgers maintained a log of all flights on which Epstein and Maxwell traveled with him. EXHIBIT CC at 6-15. Epstein additionally traveled with another pilot who did not keep such logs and he also occasionally traveled via commercial flights. Jd. at 99-100, 103. For substantially all of thirteen months of the twenty-two months (from November 2000 until September 2002) that Plaintiff lived in Palm Beach and knew Epstein, Epstein was traveling outside of Florida unaccompanied by Plaintiff. EXHIBIT BB. During this same period of time, Plaintiff was employed at various jobs, enrolled in school, and living with her boyfriend. 43

Case 18-2868, Document 276, 08/09/2019, 2628224, Page51 of 77 45. Plaintiff and Figueroa shared a vehicle during 2001 and 2002. Plaintiff and Figueroa shared a ’93 white Pontiac in 2001 and 2002. EXHIBIT P at 67; EXHIBIT EE. Plaintiff freely traveled around the Palm Beach area in that vehicle. /d. In August 2002, Plaintiff acquired a Dodge Dakota pickup truck from her father. EXHIBIT P at 67-68. Figueroa used that vehicle in a series of crimes before and after Plaintiff left for Thailand. /d.; EXHIBIT FF. 46. Plaintiff held a number of jobs in 2001 and 2002. During 2001 and 2002, plaintiff was gainfully employed at several jobs. She worked as a waitress at Mannino’s Restaurant, at TGIFriday’s restaurant (aka CCI of Royal Palm Inc.), and at Roadhouse Grill. EXHIBIT R. She also was employed at Courtyard Animal Hospital (aka Mare Pinkwasser DVM). /d.; EXHIBIT W. 47. In September 2002, Plaintiff traveled to Thailand to receive massage training and while there, met her future husband and eloped with him. Plaintiff traveled to Thailand in September 2002 to receive formal training as a masseuse. Figueroa drove her to the airport. While there, she initially contacted Figueroa frequently, incurring a phone bill of $4,000. EXHIBIT P at 35. She met Robert Giuffre while in Thailand and decided to marry him. She thereafter ceased all contact with Figueroa from October 2002 until two days before Mr. Figueroa’s deposition in this matter in May 2016. Id. at 29, 37. 48. Detective Recarey’s investigation of Epstein failed to uncover any evidence that Ms. Maxwell was involved in sexual abuse of minors, sexual trafficking or production or possession of child pornography. Joseph Recarey served as the lead detective from the Palm Beach Police Department charged with investigating Jeffrey Epstein. EXHIBIT GG at 10. That investigation commenced in 2005. Jd. Recarey worked only on the Epstein case for an entire year. Id. at 274. He reviewed previous officers’ reports and interviews, conducted numerous interviews of witnesses and alleged victims himself, reviewed surveillance footage of the Epstein 44

Case 18-2868, Document 276, 08/09/2019, 2628224, Page52 of 77 home, participated in and had knowledge of the search warrant executed on the Epstein home, and testified regarding the case before the Florida state grand jury against Epstein. /d. at 212-15. Detective Recarey’s investigation revealed that not one of the alleged Epstein victims ever mentioned Ms. Maxwell’s name and she was never considered a suspect by the government. Jd. at 10-11, 177, 180-82, 187-96, 241-42, 278. None of Epstein’s alleged victims said they had seen Ms. Maxwell at Epstein’s house, nor said they had been “recruited by her,” nor paid any money by her, nor told what to wear or how to act by her. /d. Indeed, none of Epstein’s alleged victims ever reported to the government they had met or spoken to Ms. Maxwell. Jd. Maxwell was not seen coming or going from the house during the law enforcement surveillance of Epstein’s home. /d. at 214-215. The arrest warrant did not mention Ms. Maxwell and her name was never mentioned before the grand jury. /d. at 203, 211. No property belonging to Maxwell, including “sex toys” or “child pornography,” was seized from Epstein’s home during execution of the search warrant. /d. at 257. Detective Recarey, when asked to describe “everything that you believe you know about Ghislaine Maxwell’s sexual trafficking conduct,” replied, “I don’t.” Jd. at 278. He confirmed he has no knowledge about Ms. Maxwell sexually trafficking anybody. Jd. at 278-79. Detective Recarey also has no knowledge of Plaintiff's conduct that is subject of this lawsuit. Jd. at 259-60. 49. No nude photograph of Plaintiff was displayed in Epstein’s home. Epstein’s housekeeper, Juan Alessi, “never saw any photographs of Virginia Roberts in Mr. Epstein’s house.” EXHIBIT HH at §j 17. Detective Recarey entered Epstein’s home in 2002 to install security cameras to catch a thief and did not observe any “child pornography” within the home, including on Epstein’s desk in his office. EXHIBIT GG at 289-90. 45

Case 18-2868, Document 276, 08/09/2019, 2628224, Page53 of 77 50. Plaintiff intentionally destroyed her “journal” and “dream journal” regarding her “memories” of this case in 2013 while represented by counsel. Plaintiff drafted a “journal” describing individuals to whom she claims she was sexually trafficked as well as her memories and thoughts about her experiences with Epstein. EXHIBIT II at 64-65, 194; EXHIBIT N at 205-08. In 2013, she and her husband created a bonfire in her backyard in Florida and burned the journal together with other documents in her possession. /d. Plaintiff also kept a “dream journal” regarding her thoughts and memories that she possessed in January 2016. EXHIBIT II at 194-96. To date, Plaintiff cannot locate the “dream journal.” Id?! 51. Plaintiff publicly peddled her story beginning in 2011. Plaintiff granted journalist Sharon Churcher extensive interviews that resulted in seven (7) widely distributed articles from March 2011 through January 2015. Churcher regularly communicated with plaintiff and her “attorneys or other agents” from “early 2011” to “the present day.” See Doc.216 §§ 2-11 and referenced exhibits; Doc.261-1 to 216-8, incorporated by reference. Plaintiff received approximately $160,000 for her stories and pictures that were published by many news organizations. EXHIBIT N at 247-48. 52. Plaintiff drafted a 144-page purportedly autobiographical book manuscript in 2011 which she actively sought to publish. In 2011, contemporaneous with her Churcher interviews, plaintiff drafted a book manuscript which purported to document plaintiff's experiences as a teenager in Florida, including her interactions with Epstein and Maxwell. EXHIBIT KK. Plaintiff communicated with literary agents, ghost writers and potential independent publishers in an effort to get her book published. She generated marketing materials 5! Defendant has moved for sanctions against plaintiff premised on her admitted destruction of this evidence. Doc.509-510. 46

Case 18-2868, Document 276, 08/09/2019, 2628224, Page54 of 77 and circulated those along with book chapters to numerous individuals associated with publishing and the media. 53. Plaintiff’s publicly filed “lurid” CVRA pleadings initiated a media frenzy and generated highly publicized litigation between her lawyers and Alan Dershowitz. On December 30, 2014, plaintiff, through counsel, publicly filed a joinder motion that contained her “lurid allegations” about Ms. Maxwell and many others, including Alan Dershowitz, Prince Andrew, Jean-Luc Brunel. The joinder motion was followed by a “corrected” motion (EXHIBIT D) and two further declarations in January and February 2015, which repeated many of plaintiff's claims. These CVRA pleadings generated a media maelstrom and spawned highly publicized litigation between plaintiff's lawyers, Edwards and Cassell, and Alan Dershowitz. After plaintiff publicly alleged Mr. Dershowitz of sexual misconduct, Mr. Dershowitz vigorously defended himself in the media. He called plaintiff a liar and accused her lawyers of unethical conduct. In response, attorneys Edwards and Cassell sued Dershowitz who counterclaimed. This litigation, in turn, caused additional media attention by national and international media organizations. See Doc.363 at 363-1 through 363-14. 54. Plaintiff formed non-profit Victims Refuse Silence to attract publicity and speak out on a public controversy. In 2014, plaintiff, with the assistance of the same counsel, formed a non-profit organization, Victims Refuse Silence. According to plaintiff, the purpose of the organization is to promote plaintiff's professed cause against sex slavery. The stated goal of her organization is to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. EXHIBIT LL. Plaintiff attempts to promote Victims Refuse Silence at every opportunity. EXHIBIT MM at 17-18. For example, plaintiff participated 47

Case 18-2868, Document 276, 08/09/2019, 2628224, Page55 of 77 in an interview in New York with ABC to promote the charity and to get her mission out to the public. /d. at 28. B. Plaintiff carries the burden of proving actual malice by clear and convincing evidence. In New York Times Co. v. Sullivan, 376 U.S. 254, 270 (1964), the Supreme Court recognized that our country has made a “profound national commitment to the principle that debate on public issues should be uninhibited, robust, and wide-open.” The overriding importance of that commitment led to the Court’s holding that “neither factual error nor defamatory content, nor a combination of the two, sufficed to remove the First Amendment shield,” Bartnicki v. Vopper, 532 U.S. 514, 535 (2001), from speech relating to public officials and public figures. See, e.g., Gertz v. Robert Welch, Inc., 418 U.S. 323, 345 (1974). Under the First Amendment of the Constitution and Article I, Section 8, of the New York Constitution, in defamation actions by public officials and public figures and in defamation actions concerning matters of public concern, the plaintiff must prove that the allegedly defamatory statement was made with “actual malice.” See, e.g., id.; Philadelphia Newspapers, Inc. v. Hepps, 475 U.S. 767, 776-77 (1986); Huggins v. Moore, 726 N.E.2d 456, 460 (N.Y. 1999); McGill v. Parker, 582 N.Y.S.2d 91, 97 (App. Div. 1992). As the Supreme Court has noted, the term “actual malice” can be confusing because in the First Amendment context “it has nothing to do with bad motive or ill will.” Harte-Hanks Communic’ns, Inc. v. Connaughton, 491 U.S. 657, 666 n.7 (1989). Instead proof of actual malice p32 requires evidence that the publication contains a “material’””” false statement of fact that was made “with knowledge that the statement was false or with reckless disregard as to whether or °° 4ir Wisconsin Airlines Corp. v. Hoeper, 134 8. Ct. 852, 861 (2014) (“minor inaccuracies do not amount to falsity so long as ‘the substance, the gist, the sting, of the libelous charge be justified”) (internal quotations and brackets omitted). 48

Case 18-2868, Document 276, 08/09/2019, 2628224, Page56 of 77 not it was true.” Jd. at 667 (internal quotations omitted). Reckless disregard means the defendant made the false publication “with a high degree of awareness of probable falsity” or “entertained serious doubts as to the truth of [the] publication.” /d. (internal quotations omitted). In a defamation action, a plaintiff will be required to prove actual malice in two different and independent contexts: a defamation action in which the plaintiff is a public figure, and a defamation action in which the defendant asserts the privilege of reply. The defamation plaintiff at trial and in summary judgment proceedings must prove her case by clear and convincing evidence. C. Plaintiff is a public figure who must prove actual malice. Public figures include those who have “thrust themselves to the forefront of particular public controversies in order to influence the resolution of the issues involved. . . . [T]hey invite attention and comment.” Gertz, 418 U.S. at 345. The essential element for a finding that a person is a public figure is that she has “taken an affirmative step to attract public attention,” has “strived to achieve a measure of public acclaim.” James v. Gannett Co., 353 N.E.2d 834, 876 (N.Y. 1976). In New York Times Co. v. Sullivan, 376 U.S. 254 (1964), the United States Supreme Court held that, in cases involving public officials, the interests of an individual are trumped by society's interest in promoting free press discussion of matters of general concern. Biro v. Condé Naste, 963 F. Supp. 2d 255, 269 (S.D.N.Y. 2013). Thus, the Court held that a public official alleging defamation must establish that a falsehood has been published with “actual malice.” Sullivan, 376 U.S. at 279-80; accord, Lerman v. Flynt Dist. Co., Inc., 745 F.3d 123, 136 (2d Cir. 1984); Biro, 963 F. Supp. 2d at 269. Subsequently, the Supreme Court extended this standard to all public figures, Curtis Publ'g Co. v. Butts, 388 U.S. 130 (1967), and decided in Gertz v. Robert Welch, Inc., 418 U.S. 323 (1974), that individuals that “are not public figures for all purposes 49

Case 18-2868, Document 276, 08/09/2019, 2628224, Page57 of 77 may still be public figures with respect to a particular controversy.” Contemporary Mission, Inc. v. N.Y. Times Co., 842 F.2d 612, 617 (2d Cir. 1988). As the Second Circuit has observed, the reason for distinguishing between private and public figures in defamation claims flows from the recognition of two things: First, “that private figure are more vulnerable to injury from defamation, because public figures have greater access to the media and thus are in a better position to contradict a lie or correct an error.” Contemporary Mission, Inc., 842 F.2d at 619-20. Second, “and more important, public figures generally ‘have voluntarily exposed themselves to increased risk of injury from defamatory falsehood concerning them.’” /d. at 620 (quoting N.Y. Times, 418 U.S. at 344-45) (emphasis added). In the Second Circuit, to establish that a plaintiff is a limited purpose public figure, a defendant must prove that she: 1. successfully invited public attention to [her] views in an effort to influence others prior to the incident that is the subject of litigation; 2. voluntarily injected [her]self into a public controversy related to the subject of the litigation; 3. assumed a position of prominence in the public controversy; and 4. maintained regular and continuing access to the media. Lerman, 745 F.2d at 136-37; accord, Contemporary Mission, Inc., 842 F.2d at 617; Biro, 963 F. Supp. 2d at 270. Statements regarding a limited purpose public figure are subject to enhanced protection only if relevant to the public figure's involvement in a given controversy. Biro, 963 F. Supp.2d at 270-71 (citing Faigin v. Kelly, 978 F. Supp. 420, 426 (D. N.H. 1997)). “Yet, once a plaintiff is deemed a limited purpose public figure, courts allow the heightened protections to sweep broadly, covering all statements by defendants that are not ‘wholly unrelated to the controversy.” Biro, 963 F. Supp. 2d at 271 (quoting Waldbaum v. Fairchild Publ'ns, Inc., 626 50

Case 18-2868, Document 276, 08/09/2019, 2628224, Page58 of 77 F.2d 1287, 1298 (D.C. Cir. 1980)). The law requires only that “the statement need be no more than generally related to a dispute in issue to qualify for protection.” Robert D. Sack, Sack on Defamation: Libel, Slander, and Related Problems (“SACK ON DEFAMATION”) § 5:3.3 (4th ed. 2015). The question whether a plaintiff is a public figure is a question of law for the court to decide. Celle v. Filipino Reporter Enters. Inc., 209 F.3d 163, 176-77 (2d Cir. 2000); accord Biro, 963 F. Supp. 2d at 270. 1. Plaintiff successfully invited public attention to influence others. The record amply demonstrates that plaintiff invited public attention to herself and her views regarding the Plaintiff’s alleged desire to draw attention to the issue of her purported sex slavery. Beginning in at least 2011, the Plaintiff met with Sharon Churcher to promote her cause and economic interests. According to Ms. Churcher, the Plaintiff granted Ms. Churcher extensive interviews that resulted in 7 widely distributed articles from March 2011 through January 2015. According to Ms. Churcher, she regularly communicated with the Plaintiff and her “attorneys or other agents” from “early 2011” to “the present day.” See Doc.216 §§ 2-11 and referenced exhibits; Docs.261-1 to 216-8, incorporated by reference. Plaintiff was amply compensated for this “public attention” and received approximately $160,000 for her stories. and pictures that were published by many news organizations. EXHIBIT N at 247-248. Plaintiff had a contract with the news organizations, The Mail on Sunday. Plaintiff, in addition to selling this story to the media, again thrust herself into the public’s attention when she sought to join the ongoing CVRA litigation against Jeffrey Epstein in the United States District Court in Florida. The Plaintiff, through the same lawyers in this matter, publicly filed a joinder motion that was the equivalent of a press release. The unnecessary and Sl

Case 18-2868, Document 276, 08/09/2019, 2628224, Page59 of 77 lurid allegations were ultimately stricken by the Court but accomplished the desired result for the Plaintiff, more public attention. The CVRA pleading created a media frenzy and spawned highly publicized litigation between Plaintiff's lawyers, Edwards and Cassell, and Alan Dershowitz. After the Plaintiff publicly alleged Mr. Dershowitz of sexual misconduct, Mr. Dershowitz vigorously defended himself in the media. He called the Plaintiff a liar and accused her lawyers of unethical conduct. In response, the lawyers, Edwards and Cassell, sued Dershowitz who counterclaimed. This litigation, in turn, caused additional media attention by national and international media organizations. See Doc.363 at 363-1 thorough 363-14 and accompanying exhibits. In addition, plaintiff claims to have established a non-profit organization, Victims Refuse Silence, the purpose of which was to promote plaintiffs professed cause against sex slavery. In paragraphs 23 through 26 of her complaint in this matter she makes the following admissions on this issue: e Ultimately, as a mother and one of Epstein’s many victims, Giuffre believed that she should speak out about her sexual abuse experiences in hopes of helping others who had also suffered from sexual trafficking and abuse. Jd. 23 e On December 23, 2014, Giuffre incorporated an organization called Victims Refuse Silence, Inc., a Florida not-for-profit corporation. Jd. 24 e Géiuffre intended Victims Refuse Silence to change and improve the fight against sexual abuse and human trafficking. The goal of her organization was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. Giuffre has now dedicated her professional life to helping victims of sex trafficking. Jd. 25 e On December 30, 2014, Giuffre moved to join the on-going litigation previously filed by Jane Doe | in the Southern District of Florida challenging Epstein’s nonprosecution agreement by filing her own joinder motion. Jd. 26 §2

Case 18-2868, Document 276, 08/09/2019, 2628224, Page60 of 77 In sum, the record includes ample evidence of plaintiff's efforts to garner public attention in order to influence others and the success of those efforts. 2. Plaintiff voluntarily injected herself into public controversies related to the subject of this litigation. The second prong of the Lerman test requires an examination of whether plaintiff voluntarily injected herself into a public controversy related to the subject of the litigation. The Second Circuit has held that the term should be defined broadly to mean “any topic upon which sizeable segments of society have different, strongly held views.” Lerman, 745 F.2d at 138; see also Biro, 963 F. Supp. 2d at 272 (“A public controversy is simply ‘any topic upon which sizeable segments of society have different, strongly held views,” even if the topic does ‘not involve political debate or criticism of public officials.””) (quoting Lerman, 745 F.2d at 138) (alteration omitted). The public controversy requirement, however, is not necessarily limited to what would be considered “‘a classic debate.” SACK ON DEFAMATION § 5:3.11[B]. “An investigation into alleged corruption or drug dealing, for example, could meet the test.” Jd. As demonstrated by the Declaration of Ms. Churcher, the articles attached to the declaration, and the joinder motion filed by plaintiff in the CVRA litigation and the litigation initiated by her lawyers there can be no doubt that the plaintiff's actions were voluntary and that she injected herself into this “public controversy.” Indeed, it is clear that plaintiff created this “public controversy.” 3. Plaintiff assumed a position of prominence in the public controversies. The third relevant factor focuses on whether plaintiff has voluntarily assumed a sufficient degree of prominence in the controversies at issue. Plaintiff sold and published her story. She publicly sought to join the CVRA litigation. She established a non-profit organization, the 53

Case 18-2868, Document 276, 08/09/2019, 2628224, Page61 of 77 mission of which is purportedly to “spread the word for victims of human trafficking”. EXHIBIT MM at 17; see also EXHIBIT LL. According to Brittany Henderson, the Rule 30(b)(6) designee of VRS, plaintiff has “continued to try to promote Victims Refuse Silence at every possible chance she gets ...” EXHIBIT MM at 17-18. Plaintiff participated in an interview in New York with ABC in “the beginning of 2015,” id. at 27, so that she could “promote the charity, so that she could start getting her mission out to the public.” /d. at 28. Having affirmatively injected herself into the public spotlight in connection with these issues, plaintiff cannot now be heard to argue that this Lerman factor has not been satisfied. Cf’ Contemporary Mission, 842 F.2d at 618-19 (finding the plaintiffs' assertion that they have assumed a private life was “belied by the fact that they continued to thrust themselves into the public eye” through their conduct on behalf of a non-forprofit organization). 4. Plaintiff has maintained regular and continuing access to the media. Plaintiff has had substantial access to the media. Ms. Churcher has answered every call or email sent by plaintiff. Plaintiff's lawyers have regularly communicated with the media. Plaintiff and her lawyers have been interviewed by numerous major media organizations. Accordingly, the First Amendment requires that public figures like plaintiff claiming defamation must establish actual malice—actual and material falsity or a high degree of awareness of probable falsity—by clear and convincing evidence. E.g., Masson v. New Yorker Magazine, Inc., 501 U.S. 496, 510 (1991). D. Plaintiff must also prove actual malice to overcome the defenses of reply and pre-litigation privilege. The qualified privilege of reply to a defamatory attack is a complete defense to a claim of defamation. Shenkman v. O'Malley, 157 N.Y.S.2d 290, 294, 297 (App. Div. 1956). The defense 54

Case 18-2868, Document 276, 08/09/2019, 2628224, Page62 of 77 is available to a person “who has been defamed in the first instance,” here, Ms. Maxwell, and “who, in response to the attack, responds in kind.” /d. The privilege of the initially-attacked person (Ms. Maxwell) includes in rebuttal of the initial attack the right to speak the truth, but the right to rebut is not confined to the truth or to mere denial: This defense of reply is material, of course, only where the response in kind is defamatory. The injury, if any, to plaintiff is excused, because it is the plaintiff who started the altercation. ... It is a contradiction in terms to say that the one attacked is a privileged only to speak the truth, and not to make a counter attack, or that legitimate self-defense consists only in a denial of the charge or a statement of what is claimed to be the truth respecting its subject-matter. Id. (emphasis supplied; quoting Collier v. Postum Cereal Co., 134 N.Y.S. 847, 853 (1 Dep’t 1912)); see generally Restatement of the Law of Torts (Second) § 594 cmt. k (1977) (noting that to protect her reputation from attack by another person, she is conditionally privileged to publish defamatory matter about her attacker reasonably believed necessary to defend her reputation, “including the statement that [her] accuser is an unmitigated liar”). A defendant asserting the defense of reply need only establish she has been attacked with a defamatory statement. See id. at 297. Beginning no later than 2009 plaintiff attacked Ms. Maxwell with defamatory statements. In 2014, plaintiff knew the press was giving extensive coverage to, and scrutinizing all filings in, the Crime Victim’s Rights Act case pending in the United States District Court for the Southern District of Florida and in plaintiffs 2009 civil action against Mr. Epstein. Knowing this, plaintiff repeatedly filed papers in court alleging that Ms. Maxwell participated as a “recruiter” in a “sex trafficking” scheme operated by Mr. Epstein. E.g., Exhibit D. In 2011, plaintiff granted “exclusive” interviews to the British tabloid press during which she repeated her false allegations against Ms. Maxwell and also alleged that as part of the “sex trafficking” scheme she had sex with numerous prominent public figures, including 55

Case 18-2868, Document 276, 08/09/2019, 2628224, Page63 of 77 Prince Andrew and Harvard law professor Alan Dershowitz. EXHIBIT A. The false allegations against Ms. Maxwell constituted defamation per se. A plaintiff may defeat a qualified privilege only by proving actual malice. See, e.g., Kane v. Orange Cnty. Publ’ns, 649 N.Y.S.2d 23, 26 (App. Div. 1996) (qualified privilege of reply); see generally Gertz, 418 U.S. at 323; Restatement (Second) of Torts, supra, § 594 cmt. b. E. The January 2015 statement was substantially true, and plaintiff cannot produce clear and convincing evidence of its falsity. The January 2015 statement accurately and properly denies the factual assertions regarding Ms. Maxwell contained within plaintiff's joinder motion that had been issued two days prior to which it responded. With respect to each claim in the joinder motion that concerns Ms. Maxwell, the evidence elicited through discovery undercuts any evidence — clear and convincing or otherwise — that plaintiff may proffer to buttress her false allegations. 1. The January 2015 statement accurately denied that Ms. Maxwell met Plaintiff when Plaintiff was 15 years old in 1999. Plaintiff's relative youth at the time of her initial contact with Epstein and Maxwell forms the core of Plaintiff’s story, in her joinder motion and in the press, that she was an underage victim of sexual slavery. Plaintiff has made a point of mentioning her age of 15, in the year 1999, as the starting point for her “four years” of “sex slavery” at every opportunity. The young age no doubt heightens the offensiveness of the claimed abusive conduct and also supplies enough time to allow for the “thousands” of times she was purportedly abused and the numerous opportunities for her to be trafficked to countless famous individuals. Reiterating this point in the joinder motion, plaintiff asserted again that she met Ms. Maxwell in the year 1999 when she was a mere 15 years old. EXHIBIT D at 3. As she now admits and her employment records confirm, plaintiff did not actually meet Ms. Maxwell or Epstein until the year 2000. Plaintiff acknowledges that she did not meet Ms. 56

Case 18-2868, Document 276, 08/09/2019, 2628224, Page64 of 77 Maxwell until she worked at the Mar-A-Lago as a spa attendant, and she confirms that she obtained that job with the assistance of her father who already was employed as a maintenance worker at the club. Records subpoenaed from Mar-A-Lago reflect that plaintiff's father commenced employment on April 11, 2000. ExHiBiT S. Additionally, they show that plaintiff terminated in the year 2000. /d. Finally, plaintiff's social security report confirms plaintiff's Mar-a-lago employment was confined to calendar year 2000. EXHIBIT R. Faced with overwhelming proof that her claims of meeting Ms. Maxwell at the age of 15 in the year 1999 were false, plaintiff finally conceded as much at her deposition on May 3, 2016. EXHIBIT N at 2528. She also confessed that she did not spend her “sweet 16"” birthday with Ms. Maxwell, as detailed in her book manuscript and in the press. Compare EXHIBIT N at 101-02 with EXHIBIT KK at Giuffre04173 (“I spent my sweet 16" birthday on his island in the Caribbean next to ‘St. James Isle’ he liked to call it ‘Little St. Jeff's’, his ego was as enormous as his appetite for fornicating. I was given a birthday cake and a new collection of designer make-up from London. Ghislaine made a joke after I blew out my array of candles and said, ‘I’d be soon getting too old for Jeffrey’s taste, and soon they'd have to trade me in.””); Paul Lewis, “Jeffrey Epstein: Inside the Decade of Scandal Entangling Prince Andrew,” The Guardian (Jan. 10, 2015)**. Yet, even after conceding she was off by a year, plaintiff persists in suggesting that she must have been a mere “16 year old” when she worked at Mar-a-Lago and met Ms. Maxwell. It was, she testified, a “summer job” for which she had taken a break from school, and she did not turn 17 until later that summer on August 9, 2000. EXHIBIT N at 25-28, 57,104, 113. But the Mar-a-Lago documents conclusively disprove this claim: the spa where plaintiff worked closes every year from Mother’s Day until November 1. EXHIBIT U at Mar-a-Lago0212 (“The club 33 https://www.theguardian.com/world/2015/jan/10/jeffrey-epstein-decade-scandalprince-andrew (last visited Jan. 6, 2017). S7

Case 18-2868, Document 276, 08/09/2019, 2628224, Page65 of 77 never shuts down from November | to Mother’s Day.”). Spa attendants such as plaintiff are “seasonal” employees. Jd. Indeed, the spa advertises for its new employees in local newspapers in the fall of every year. EXHIBIT V. Even plaintiff's father — a long time employee of Mar-aLago -- described the seasonal nature of the club during his deposition: “[Plaintiff’s employment] was probably for a season because Mar-a-Lago is seasonal. I mean, I was there year round but a lot of people are seasonal, you know, because it’s like snowbirds, you know, summertime comes and nobody wants to be down in south Florida....[The season is] probably from September or October to, you know, maybe May, I guess.” EXHIBIT T at 72. With the spa closed from Mother’s Day to November 1, plaintiff could not have had a “summer job” and could not have worked at Mar-a-Lago until November 2000, at the earliest, when she was over 17 years old. In sum, Plaintiff's claim in the Joinder Motion that she met Ghislaine Maxwell in 1999 when she was 15 years old is a false statement. Therefore, the January 2015 statement calls the allegations against her “untrue” was factually accurate. 2. The January 2015 statement accurately denied that Ms. Maxwell “regularly participate[d] in Epstein’s sexual exploitation of minors” and that “the Government knows” such fact. The January 2015 statement also accurately denied plaintiff's joinder motion allegation that “it became known to the government that Maxwell herself regularly participated in Epstein’s sexual exploitation of minors, including Jane Doe #3.” EXHIBIT D at 3. Ms. Maxwell did not “regularly participate in in Epstein’s sexual exploitation of minors” as confirmed by the lead Palm Beach Detective, Joseph Recarey. Det. Recarey confirmed that none of the alleged Epstein victims ever mentioned Ms. Maxwell’s name, either in reports he reviewed or in interviews he conducted. None of the alleged victims said they had been “recruited,” paid or exploited by Ms. Maxwell. EXHIBIT GG at 10-11, 177, 180-82, 187-96, 241-42, 278. He verified that the twenty58

Case 18-2868, Document 276, 08/09/2019, 2628224, Page66 of 77 two page Palm Beach Police Department affidavit does not mention Ms. Maxwell’s name once (id. at 177), and she was never considered a suspect and she was never mentioned in the grand jury testimony. /d. at 203. Ms. Maxwell was not seen coming or going from the house during any of the Palm Beach Police Department’s surveillance of Epstein’s home. Jd. at 214-15. None of her property was seized from Epstein’s home. /d. at 257. In sum, Det. Recarey denied that knowing anything “about Ghislaine Maxwell’s sexual trafficking conduct.” /d. at 278. He confirmed he has no knowledge that Ms. Maxwell sexually trafficking “anybody.” Jd. at 278-79. Likewise, he has no knowledge of Plaintiff's conduct that is subject of this lawsuit. Jd. at 259-60. Plaintiff thus has uncovered no evidence that the “government” came to “know” that Maxwell participated in sexual exploitation of Jane Doe #3, i-e., Plaintiff. Plaintiff has not and cannot present clear and convincing evidence to demonstrate the falsity of Ms. Maxwell’s denial. 3. The January 2015 statement accurately denied that “with [Ms. Maxwell’s] assistance, [Epstein] converted [Plaintiff] into what is commonly referred to as a ‘sex slave.’” Plaintiff claimed in the joinder motion that Ms. Maxwell helped Epstein transform her into a “sex slave” as that term is “commonly” used, yet the incontrovertible evidence establishes the opposite. A “slave” as defined by Merriam-Webster is a “person held in servitude as the chattel of another.” Oxford Dictionary defines “slave” as a “person who is the legal property of another and is forced to obey them.” Common definitions of “sex slave” include a person who is confined and is raped, sexually abused or prostituted. See “Sex Slave,” Free Dictionary, located at http://www.thefreedictionary.com/sex+slave (last visited Jan. 5, 2017) (underlining supplied). Plaintiff, however, was far from confined or the legal property of another. Throughout 2000, 2001 and 2002, Plaintiff enjoyed complete freedom of movement and choice. She had a car and then a pickup truck she shared with Figueroa. EXHIBIT P at 67.. She traveled freely to and from multiple jobs working as a waitress, bird aviaries, veterinarian 59

Case 18-2868, Document 276, 08/09/2019, 2628224, Page67 of 77 hospital, Neiman Marcus, Oasis Outsourcing and Southeast Employee Management Company. EXHIBIT R. Plaintiff enrolled in school in June 2000 before she met Maxwell or Epstein and continued her enrollment throughout 2000, 2001 and until March 2002. ExHiBiIT O. She worked at multiple restaurants and the animal hospital in 2002. EXHIBIT R. She came and went from her apartment, moved to a new apartment and then moved in with Figueroa’s family. She held parties at her apartment with Figueroa and other friends. EXHIBIT Z. When something did not go well, she called the police and filed police reports, without mentioning anything about captivity, confinement or forced sexual exploitation or trafficking, much less “sex slavery.” Jd. and EXHIBIT AA. She had her own money, paid her rent, and bought a vehicle. To Figueroa, she seemed “excited” about meeting famous people and discussed it so much that he tuned it out. EXHIBIT P at 125-26. By any commonly understood definition of sex slavery, Plaintiff did not match the description. Witness testimony and documentary evidence demonstrate the absence of substantial truth to Plaintiff's claim that Maxwell assisted Epstein in converting her into what is commonly referred to as a “sex slave.” The January 2015 statement’s denial of that claim cannot therefore be defamatory. 4. The January 2015 statement accurately reported that Plaintiff alleged “sexual relations” with Professor Dershowitz which he denied. The January 2015 statement accurately reports that “now it is alleged that Alan Derschowitz [sic] is involved in having sexual relations with [Plaintiff], which he denies.” The joinder motion made such a claim and Professor Dershowitz publicly and vehemently denied any such sexual contact. See, e.g., Dershowitz Denies Sex Charge, JTA (Jan. 2, 2015) (“Dershowitz 60

Case 18-2868, Document 276, 08/09/2019, 2628224, Page68 of 77 declared ‘totally, unequivocally and completely false’ allegations that he had sex with the former staffer for investor Jeffrey Epstein.”).** Professor Dershowitz has gone beyond a simple denial: he has sworn, repeatedly and in almost every conceivable forum, including the New York Times, the Wall Street Journal, and Good Morning America, that he never had any sexual contact with Plaintiff and never met her. As he set forth in this case in his Declaration in Support of Motion to Intervene, Plaintiff never mentioned his name during her weeklong 2011 interview with journalist Sharon Churcher. Doc.363. It was only after Churcher suggested to Plaintiff that she “must have” met Dershowitz because “we all know he’s a pedo, though we have no proof of that” that Plaintiff then included Dershowitz in her book manuscript, not as a perpetrator of hers, but as someone she had “met” while with Epstein. /d. The CVRA joinder motion more than three years later was the first time plaintiff publicized her remarkable claim that she had been sexually trafficked to Dershowitz on “numerous occasions” “while she was a minor,” in Florida, private planes, in New York, New Mexico, and the U.S. Virgin Islands. EXHIBIT D. Dershowitz, in his own subsequent defamation action against plaintiff's attorneys Edwards and Cassell, produced approximately 10,000 pages of documents capturing his travels during the 1999-2002 timeframe, none of which coincided with Plaintiffs story. For example, Dershowitz demonstrated that the only time he visited Epstein’s home in the U.S. Virgin Islands he was accompanied by his wife and his 12 year old daughter. Plaintiff, on the other hand, produced no records demonstrating that any portion of her allegation against him is true. For example, she claimed one sexual encounter occurred on a private plane on which she traveled “http://www jta.org/2015/01/02/news-opinion/united-states/dershowitz-denies-lawsuitssex-charges?utm_source=twitterfeed&utm_medium=twitter&utm_campaign=jtafeed (last visited Jan. 5, 2017). 61

Case 18-2868, Document 276, 08/09/2019, 2628224, Page69 of 77 with Professor Dershowitz. EXHIBIT II at 85. None of the flight logs reveal a flight with the two of them as passengers. EXHIBIT BB. Another time, plaintiff claims, she and Epstein flew together to Boston and she engaged in sexual relations with Professor Dershowitz in the backseat of a limousine between the airport and his home with another female and Epstein next to them. EXHIBIT I at 110-15. No flight logs document any trip with Epstein and plaintiff to Boston and plaintiff cannot recall the other female in the car. EXHIBIT II at 113. Professor Dershowitz has signed affidavits, provided sworn deposition testimony and sworn pleadings, offered to take a lie detector test, offered to waive the statute of limitations as to himself, and given countless broadcast and news interviews disclaiming any sexual contact with Plaintiff and calling her an outright “Liar5 The January 2015 statement recounting the allegation against him and his denial is substantially true. 5. The January 2015 statement accurately denied that Ms. Maxwell created and distributed child pornography and that the Government knows of and possesses such child pornography. Plaintiff's next assertion regarding Maxwell in the joinder motion was that “Maxwell also took numerous sexually explicit pictures of underage girls involved in sexual activities, including Jane Doe #3,” and that Maxwell “shared these photographs (which constituted child pornography under applicable federal laws) with Epstein.” EXHIBIT D at 4-5. Plaintiff continued: the “Government is apparently aware of, and in certain instances possesses some of these photographs.” /d. Yet again, the evidence demonstrates the falsity of Plaintiff's claim. Detective Recarey testified that none of Epstein’s alleged victims even mentioned Ms. Maxwell, much less claimed that she had taken naked photographs of them. EXHIBIT GG at 18082, 187-96, 241-42, 278. Recarey also denied that any evidence belonging to Ms. Maxwell was *>Perhaps most telling, Plaintiff and her phalanx of attorneys have never sued Mr. Dershowitz for his many vociferous attacks on her credibility. 62

Case 18-2868, Document 276, 08/09/2019, 2628224, Page70 of 77 seized from Epstein’s home during the execution of the search warrant, which would include any “child pornography” reportedly created by her. /d. at 257. Detective Recarey who had entered Epstein’s home in 2002 to install security cameras to catch a thief did not observe any “child pornography” within the home, including on Epstein’s desk where Plaintiff alleges he kept such a nude photograph of herself. /d. at 289-90. And Epstein’s housekeeper, Juan Alessi, swore that he “never saw any photographs of Virginia Roberts in Mr. Epstein’s house,” EXHIBIT HH at § 17, contradicting Plaintiff's claims that nude photographs of her were prominently displayed throughout all of Epstein’s homes. No sexually explicit photographs of Plaintiff were ever produced in discovery in this case or subpoenaed by Plaintiff from any governmental agency. Plaintiff has presented no evidence the government “possesses” any such photographs or indeed ever became "aware of" them. 6. January 2015 statement accurately denied Maxwell acted as “madame” for Epstein to traffic Plaintiff to the rich and famous. Finally, in the joinder motion, Plaintiff asserted that Ms. Maxwell had “facilitated” sexual abuse “by acting as a ‘madame’ for Epstein, thereby assisting in internationally trafficking Jane Doe #3 (and numerous other young girls) for sexual purposes.” Plaintiff has utterly failed to substantiate her allegation. Not a single “other young girl” made a claim that Maxwell, or even Epstein for that matter, trafficked them to a third-person for commercial sexual acts. Detective Recarey confirmed that he had no knowledge of Ghislaine Maxwell sexually trafficking anyone. EXHIBIT GG at 278-79. He also confirmed that not a single one of the alleged victims of Epstein ever claimed to have any sexual contact with any man other than Epstein, or that they were sent to another location to have sex with another man or to give a massage to another man. /d. at 30002. None of the other alleged victims of Epstein ever claimed to have gone on his plane with him 63

Case 18-2868, Document 276, 08/09/2019, 2628224, Page71 of 77 or to have had sexual acts with him on his plane. Jd. at 302-04. None claimed they had gone to New York with him and stayed in his residence. /d. at 304-05. Plaintiff, it appears, is the only alleged victim of Epstein who claims she was the subject of such trafficking, yet even she has retracted, amended, and withdrawn many of her allegations, thus rendering (by her own admission) such claim substantially untrue. Foreign Presidents. Upon questioning under oath, Plaintiff admitted that she had never even met a “foreign president,” much less ever been sexually trafficked to one or to the multiple “foreign presidents” referenced in the joinder motion. Q: The reference there to foreign presidents, do you see that? A: Yes. Q: You were sexually trafficked to foreign presidents? A: No. Q: So that’s not true, you were not sexually trafficked to foreign presidents? A: I don’t know what foreign presidents you’re talking about. Q: Have you ever been sexually trafficked to any foreign president? [Objection interposed by Ms. McCawley; Special Master overruled] A: L understand well-known prime ministers and other world leaders; as far as foreign presidents, I’m not too sure, I don’t know. Q: Have you ever met any foreign presidents? A: Foreign presidents as in overseas? Q: Sure, okay, overseas. A: No. Q: Have you ever met any foreign presidents from countries not overseas such as Canada or Mexico? A: No. Q: So you were not sexually trafficked to any foreign presidents, is that correct? A: As far as I know right now, yes. 64

Case 18-2868, Document 276, 08/09/2019, 2628224, Page72 of 77 Q: It’s correct that you were not sexually trafficked to them, right? A: You’ve asked me this three times and I’m telling you. EXHIBIT II at 10-12. Indeed, Plaintiff became frustrated by what she perceived as the third time she was asked the question, each time denying that she had met a foreign president or been sexually trafficked to one, clearly indicating that she understood the question, had answered it in the negative and did not want to be re-asked the question again.*° Notably, not a single “foreign president” is listed as a witness with knowledge of Plaintiff's claims in her Rule 26 disclosures. “Well-known prime minister.” Plaintiff also has failed to establish any evidence to support her fantastical claim that she was sexually trafficked to a “well-known prime minister.” When questioned, she refused to disclose the identity of the prime minister, even with the protection of a protective order. EXHIBIT IL at 12. She has not produced photographs of her with any well-known prime minister, nor any flight log showing a well-known prime minister on Epstein’s airplane. She has not identified herself as being in any location with a well-known prime minister, nor the date of any such encounter. The only evidence that Plaintiff has ever been even in the company of a well-known prime minister is her uncorroborated word. “World leaders.” Likewise, when asked about “world leaders” to whom she was trafficked, Plaintiff referred vaguely to someone she was introduced to as a “prince.” Q: Other world leaders, what other world leaders were you sexually trafficked to? [Objection interposed and overruled by Special Master] A: Okay. Prince Andrew for one. Q: Other than Prince Andrew? **Plaintiff and her counsel later devised a plan to just outright change these three answers through the errata sheet, claiming that Plaintiff had “misunderstood the question” and she had in fact been trafficked to such a president. EXHIBIT JJ. As her clear answers and frustration at the repeated nature of the questioning demonstrates, however, she had no trouble whatsoever understanding the question at the time. 65

Case 18-2868, Document 276, 08/09/2019, 2628224, Page73 of 77 A: There is another individual that I honestly do not know his name. Q: What country is he from? A: I’m not too sure, he spoke in a foreign—he did speak foreign tongue, he spoke English as well, but I’m not too sure where he was from? Q: How do you know he is a world leader? A: I was introduced to him as a prince. Q: Did you — where were you when you met him? A: On this occasion the South of France. Q: Where in the South of France were you? A: I don’t know. Q: Were you on a boat, were you in a house? A: We were at a like a cabana, not cabana, like a resort, but it was a big party. Q: Who was throwing the party? A: I don’t know. I was just brought there. EXHIBIT II at 15-17. Indeed, this is almost the identical answer that Plaintiff later gave when questioned about what which “powerful businessmen” she had been sent to have sex with: Q: Where were you sent to have sex with the owner of a large hotel chain by Ghislaine Maxwell? A: I believe that was one time in France. Q: I believe it was around the same time that Naomi Campbell had a birthday party. A: Where did you have sex with the owner of a large hotel chain in France around the time of Naomi Campbell’s birthday party? A: In his own cabana townhouse thing. It was part of a hotel, but I wouldn’t call it a hotel. ... 66

Case 18-2868, Document 276, 08/09/2019, 2628224, Page74 of 77 EXHIBIT N at 203. In fact, Naomi Campbell’s birthday is May 22, 1970. [WIKIPEDIA]. The flight logs do not show plaintiff traveling to France in May 2001 or May 2002. EXHIBIT BB at DR_0046, DR_0056. On May 22, 2002, for example, Epstein was in Russia. In her joinder motion, Plaintiff made the additional claim that Epstein (not Maxwell) sexually trafficked her to “model scout” Jean Luc Brunel on numerous occasions and in numerous places, including “the South of France.” EXHIBIT D at 5-6. The flight logs, however, demonstrate that Plaintiff was never in the “south of France,” much less on multiple occasions. The one and only trip reflecting travel by Plaintiff to France was a trip on March 6, 2001 from a fueling stop in Canada to Paris, followed by a departure from Paris on March 8, 2001 to Granada. EXHIBIT BB at DR_000043; EXHIBIT CC at 107. Although there are other flights in which Epstein went to Nice in the south of France, Plaintiff is not on any of them and none are near Naomi Campbell’s birthday on May 22. Plaintiff's claim in her joinder motion about having been trafficked to other “prominent American politicians” and other world leaders have gone unsubstantiated and are patently incredible. Because these men are publicized to have been in the company of Epstein on at least one occasion, such was apparently sufficient for Plaintiff to claim she had been trafficked to them. For example, Plaintiff claimed at her deposition that these powerful men to whom she was trafficked included Marvin Minsky. EXHIBIT N at 204. Dr. Minsky, a world-renowned scholar and long-time professor at MIT, passed away in January 2016 at the age of 88. *” At the time of his passing, he had been married to his wife, pediatrician Dr. Gloria Rudisch, since 1952 and had three children and four grandchildren. His name appears on one of Epstein’s flight logs as having traveled with a large group of individuals, including plaintiff, from New Jersey to Santa Fe on 57 https://www. bostonglobe.com/metro/2016/01/25/marvin-minsky-dies-mit-professorhelped-found-field-artificial-intelligence/A8y6ey8S0QAaa0463Z2000/story. html 67

Case 18-2868, Document 276, 08/09/2019, 2628224, Page75 of 77 March 29 and returning on March 31, 2001.** The other passengers included world-renowned philanthropist Dr. Henry Jarecki, now aged 83, also a long-time husband, famed academic and scholar, and famous philanthropist.” Plaintiff produced no evidence substantiating any of her fantastical claims that she had been trafficked by Epstein, or by Maxwell, to any of these men or any others. No witnesses vouched for seeing plaintiff in the company of politicians George Mitchell or Bill Richardson to whom plaintiff claims she was sent. She produced no photographs of herself with them. She had a journal where she claims she documented their names, but she claims she burned that journal in 2013. In May 2011, plaintiff inquired by email to journalist Sharon Churcher to “remind” her of the famous people to whom she was trafficked. Plaintiff has not supported her claims with clear and convincing evidence and thus, Ms. Maxwell’s denials and characterizations of these claims as “obvious lies” is not defamatory as a matter of law. CONCLUSION For the foregoing reasons, the Court should grant summary judgment in favor of Ms. Maxwell. *8 Plaintiff claims, however, that she was trafficked to Dr. Minsky in the U.S. Virgin Islands. > https://en.wikipedia.org/wiki/Henry_Jarecki 68

Case 18-2868, Document 276, 08/09/2019, 2628224, Page76 of 77 January 6, 2017. Respectfully submitted, /s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10" Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 Imenninger@hmflaw.com Attorneys for Defendant Ghislaine Maxwell 69

Case 18-2868, Document 276, 08/09/2019, 2628224, Page77 of 77 CERTIFICATE OF SERVICE I certify that on January 6, 2017, I electronically served this Memorandum in Support of Defendant's Motion for Summary Judgment via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smecawley@bsfllp.com mschultz@bsfllp.com Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com 70 Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@aol.com /s/ Nicole Simmons Nicole Simmons

Case 18-2868, Document 277, 08/09/2019, 2628225, Pagel of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK sano peeiee ereeneeaei neces x VIRGINIA L. GIUFFRE, Plaintiff, : ve : 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. dessa ei Acca eee x Declaration of Laura A. Menninger in Support of Defendant’s Motion For Summary Judgment I, Laura A. Menninger, declare as follows: 1. Lam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. lama member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of Ms. Maxwell’s Motion for Summary Judgment.! 2. Attached as Exhibit A is a true and correct copy of an article by Sharon Churcher entitled “Prince Andrew and the 17-year-old girl his sex offender flew to Britain to meet him,” DAILY MAIL, dated March 2, 2011. ' At trial, defendant intends to produce either the custodian of record relevant to any disputed document or a certification in compliance with either Fed. R. Evid. P. 803 and/or 902. See Fed. R. Civ. P. 56(c). Apart from deposition testimony, the majority of non-deposition documents herein were either produced by plaintiff or obtained with releases signed by plaintiff.

Case 18-2868, Document 277, 08/09/2019, 2628225, Page2 of 7 3. Attached as Exhibit B is a true and correct copy of an article by Sharon Churcher entitled “Teenage girl recruited by paedophile Jeffrey Epstein reveals how she twice met Bill Clinton,” DAILY MAIL, dated March 5, 2011. 4. Attached as Exhibit C is a true and correct copy of a statement on behalf of Ms. Maxwell dated March 9, 2011. 5. Attached as Exhibit D (filed under seal) is a true and correct copy of the corrected Motion for Joinder, Doe v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. Fla. Jan. 2, 2015). 6. Attached as Exhibit E is a true and correct copy of an Order Denying Motion to Join Under Rule 21, Doe v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. Fla. Apr. 7, 2016). 7. Attached as Exhibit F is a true and correct copy of a statement on behalf of Ms. Maxwell dated January 2, 2015. 8. Attached as Exhibit G (filed under seal) are true and correct copies of excerpts from the November 18, 2016 deposition of Ross Gow, designated Confidential under the Protective Order. 9. Attached as Exhibit H (filed under seal) is a true and correct copy of Plaintiff's Response to Second Request for Production and to Interrogatories and Requests for Admissions, dated July 1, 2016. 10. Attached as Exhibit I (filed under seal) is a true and correct copy of Plaintiff's Supplemental Responses to to Interrogatory Nos. 6, 12 and 13, dated August 17, 2016, designated Confidential under the Protective Order.

Case 18-2868, Document 277, 08/09/2019, 2628225, Page3 of 7 11. Attached as Exhibit J (filed under seal) is a true and correct copy of the Declaration of Ghislaine Maxwell, dated January 6, 2017. 12. Attached as Exhibit K (filed under seal) is a true and correct copy of the Declaration of Philip Barden, dated January 6, 2017. 13. Attached as Exhibit L (filed under seal) are true and correct copies of excerpts from the June 23, 2016 deposition of James Austrich, designated Confidential under the Protective Order. 14. Attached as Exhibit M (filed under seal) is a true and correct copy of Plaintiff's passport application, dated January 12, 2001, designated Confidential under the Protective Order. 15. Attached as Exhibit N (filed under seal) are true and correct copies of excerpts from the May 3, 2016 deposition of Virginia Giuffre, designated Confidential under the Protective Order. 16. Attached as Exhibit O (filed under seal) are true and correct copies of Plaintiff's school records Bates stamped GM_00888 and GIUFFREE00498 1-88 and designated Confidential under the Protective Order. 17. Attached as Exhibit P (filed under seal) are true and correct copies of excerpts from the June 24, 2016 deposition of Tony Figueroa, designated Confidential under the Protective Order. 18. Attached as Exhibit Q (filed under seal) are true and correct copies of excerpts from the November 14, 2016 deposition of Virginia Giuffre, designated Confidential under the Protective Order.

Case 18-2868, Document 277, 08/09/2019, 2628225, Page4 of 7 19. Attached as Exhibit R (filed under seal) is a true and correct copy of Plaintiff's Social Security records dated October 25, 2016, Bates stamped GIUFFRE009175, designated Confidential under the Protective Order. 20. Attached as Exhibit S (filed under seal) is a true and correct copy of Mar-A-Lago records, Bates stamped MAR-A-LAGO-0001 and MAR-A-LAGO-0161-0177. 21. Attached as Exhibit T (filed under seal) is a true and correct copies of excerpts from the May 20, 2016 deposition of Sky Roberts, designated Confidential under the Protective Order. 22. Attached as Exhibit U (filed under seal) ) is a true and correct copy of the Mar-ALago employee handbook, dated October 28, 1995, Bates stamped MAR-A-LAGO-0178-0243. 23. Attached as Exhibit V (filed under seal) is a true and correct copy of the Mar-A-Lago advertisement, Bates stamped MAR-A-LAGO-0086. 24. Attached as Exhibit W (filed under seal) is a true and correct copy of Plaintiff's Courtyard Animal Hospital employment application, Bates stamped GIUFFRE009201-11, designated Confidential under the Protective Order. 25. Attached as Exhibit X(filed under seal) is a true and correct copy of the Royal Palm Beach Police Department Offense Report date, June 10, 2001, Bates stamped GM_00780-82. 26. Attached as Exhibit Y (filed under seal) is a true and correct copy of the Royal Palm Beach Police Department Probable Cause Affidavit date, November 19, 1999, Bates stamped GM_01223-28. 27. Attached as Exhibit Z (filed under seal) is a true and correct copy of the Royal Palm Beach Police Department Offense Report date, August 3, 2001, Bates stamped GM_00777-79.

Case 18-2868, Document 277, 08/09/2019, 2628225, Paged of 7 28. Attached as Exhibit AA (filed under seal) is a true and correct copy of the Palm Beach County Sheriff's Offense Report date, June 02, 2002, Bates stamped GM_00748-79. 29. Attached as Exhibit BB (filed under seal) are true and correct copies of David Rodgers flight logs from November 1995 to May 2013, Bates stamped DR__0001-DR0107. 30. Attached as Exhibit CC (filed under seal) is a true and correct copy of excerpts from the June 3, 2016 deposition of David Rodgers, designated Confidential under the Protective Order. 31. Exhibit DD left intentionally blank. 32. Attached as Exhibit EE (filed under seal) is a true and correct copy of the Royal Palm Beach Police Citation Tracking Report date, June 19, 2002, Bates stamped GM_00776. 33. Attached as Exhibit FF (filed under seal) is a true and correct copy of the Palm Beach County Sheriff's Offense Report, Bates stamped GM_01202-28. 34. Attached as Exhibit GG (filed under seal) is a true and correct copies of excerpts from the June 21, 2016 deposition of Joseph Recarey, designated Confidential under the Protective Order. 35. Attached as Exhibit HH (filed under seal) is a true and correct copy of the Affidavit of Juan P. Alessi, dated January 13, 2016, Bates stamped GM_01197-1201. 36. Attached as Exhibit II (filed under seal) is a true and correct copy of excerpts from the Deposition of Virginia Giuffre taken in Cassell v. Dershowitz, on January 16, 2016, and designated as Confidential under the Protective Order.

Case 18-2868, Document 277, 08/09/2019, 2628225, Page6 of 7 37. Attached as Exhibit JJ (filed under seal) is a true and correct copy of Errata Sheet from the January 16, 2016 deposition of Virginia Giuffre taken in Cassell v. Dershowitz, dated February 11, 2016 and designated by Plaintiff as Confidential under the Protective Order. 38. Attached as Exhibit KK (filed under seal) is a true and correct copy of The Billionaire Playboys Club book manuscript, designated by Plaintiff as Confidential under the Protective Order. 39. Attached as Exhibit LL is a true and correct copy of the Victims Refuse Silence, Inc. Articles of Incorporation dated December 23, 2014, GIUFFRE001064-65. 40. Attached as Exhibit MM (filed under seal) is a true and correct copy of excerpts from the September 8, 2016 deposition of Brittany Henderson, designated Confidential under the Protective Order. I declare under penalty of perjury that the foregoing is true and correct. Executed on January 6, 2017. s/ Laura A. Menninger Laura A. Menninger

Case 18-2868, Document 277, 08/09/2019, 2628225, Page7 of 7 CERTIFICATE OF SERVICE I certify that on January 6, 2017, I electronically served this Declaration of Laura A. Menninger in Support of Defendant's Motion for Summary Judgment via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smecawley@bsfllp.com mschultz@bsfllp.com Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@aol.com /s/ Nicole Simmons Nicole Simmons

Selected docket entries for case 18-2868 Generated: 08/09/2019 09:37:49 Filed Document Description Page Docket Text 08/09/2019 |279 UNSEALED SUMMARY 2 /UNSEALED SUMMARY JUDGMENT RECORD, JUDGMENT RECORD, appendix 5 of 13 , pursuant to the Court's decision dated IDOCKETED July 3, 2019, DOCKETED. [2628231] [18-2868] 08/09/2019 |280 UNSEALED SUMMARY 39 JUNSEALED SUMMARY JUDGMENT RECORD, JUDGMENT RECORD, appendix 6 of 13 , pursuant to the Court's decision dated IDOCKETED July 3, 2019, DOCKETED. [2628232] [18-2868] 08/09/2019 |281 UNSEALED SUMMARY 113 JUNSEALED SUMMARY JUDGMENT RECORD, JUDGMENT RECORD, appendix 7 of 13 , pursuant to the Court's decision dated IDOCKETED July 3, 2019, DOCKETED. [2628234] [18-2868] 08/09/2019 |282 UNSEALED SUMMARY 179 UNSEALED SUMMARY JUDGMENT RECORD, JUDGMENT RECORD, appendix 8 of 13 , pursuant to the Court's decision dated IDOCKETED July 3, 2019, DOCKETED. [2628236] [18-2868]

Case 18-2868, Document 279, 08/09/2019, 2628231, Pagel of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Se a Secs Sete Sens sentence eee xX VIRGINIA L. GIUFFRE, i Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. Se ace acetate ene 4 Reply Brief in Support of Defendant’s Motion for Summary Judgment Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10" Avenue Denver, CO 80203 303.831.7364

Case 18-2868, Document 279, 08/09/2019, 2628231, Page2 of 37 TABLE OF CONTENTS PRELIMINARY STATEMENT .........cccccscssssssssssessseseeseessesesssssscssesneeseesessessesssessesseneeseeseess 1 ARGUING osc cova ntsc fenc ence cacy isa datos eras toes ae gah a aati devia neve 2 I. Ms. Maxwell is not liable for republications of the January 2015 statement. .............. 2 A. Plaintiff's argument against summary judgment is substantially groundless. 2 B. New York state and federal courts have rejected liability for republication based on “foreseeability.” Cc. Plaintiff's purported application of the Geraci rule is misleading and wrong. Sesodaascbsasbsbchaytcedacesissenbs cobaubibcnseshecvssndananssverbedrbctaeskcqsutbspetarventaasayodssedicdbaseensvoedba 6 D. Subjecting Ms. Maxwell to liability for the media’s republication of excerpts they unilaterally selected is particularly unfair. .....0...0.c cece eeeeeeeseeeeseeee 9 E. Mr. Barden’s declaration is perfectly propet............ccccccscecscseeseseesesseeteseeeenes 11 F. Plaintiff effectively has confessed Arguments I.B. and I.C. of the Memorandum.. Il. The January 2015 statement is constitutionally protected opinion. ............ccceeee 12 Ill. The pre-litigation privilege bars this action.. A. The privilege applies to the January 2015 statement. .........0.ccceee eee 20 B. Malice is irrelevant to the pre-litigation privilege... IV. Ms. Maxwell’s January 4, 2015, statement is nonactionable. ..........0.ccccceeeeees eee 25 V. Summary judgment is warranted because plaintiff cannot establish falsity or actual malice by clear and convincing eVidenCe. ........c.csee cesses cesses esestsseteseseseseseeneseneeeee 25 CONGEUSION tetesiss ots asians extarcrreaven aia asiencs tase oral ae eatin ideas 30 CERTIFICATE OF SERVICE .sssissccsssssssssesscssasassctacsnscsbeesytnacnsctiasvevarbeusestbeassvsacnssoiaeverssiee 32

Case 18-2868, Document 279, 08/09/2019, 2628231, Page3 of 37 TABLE OF AUTHORITIES Cases Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986). ...ccscseccceseteeesseseeteteeeeeeeeaeeeee 9 Blair v. Inside Ed. Prods., 7 F. Supp. 3d 348, 358 & n.6 (S.D.N.Y. 2014) woe 25 Cerasani v. Sony Corp., 991 F. Supp. 343, 351 (S.D.N.Y. 1998) ...ccccececeseseseseeeeeee 3,4 Chambers v. Wells Fargo Bank, N.A., No. CV 15-6976 (JBS/JS), 2016 WL 3533998, at #B (DING, Tune! 28) 2016) scscssscsssensscssscesses ccsscesseccvenesssyassessens cekasstoscsvaneddavasectseosvezesntoe 2, 20 China Med. Techs., Inc., 539 B.R. 643, 658 (S.D.N.Y. 2015) ..ccscecceseeeseeeseeeeeeeenees 12 Cowan v. City of Mount Vernon, 95 F. Supp. 3d 624, 645-46 (S.D.N.Y. 2015) ......... 13,25 Croy v. A.O. Fox Mem’! Hosp., 68 F. Supp. 2d 136, 144 (N.D.N.Y. 1999) wo. eeceeceeeees 3 Dalbec v. Gentleman’s Companion, Inc., 828 F.2d 921, 927 (2d Cir. 1987) woe 25 Davis v. Boeheim, 22 N.E.3d 999 (N.Y. 2014) w.ccccccsccescescsseseesesecseeeeseeseeseescseeseseeaees 14,18 Davis v. Costa-Gavras (“Davis I’), 580 F. Supp. 1082, 1096 (S.D.N.Y. 1984) ....... 2,3,4,6 Davis v. Costa-Gavras (“Davis IT”), 595 F. Supp. 982, 988 (S.D.N.Y. 1984) wee 3 Dibella v. Hopkins, No. 01 CIV. 11779 (DC), 2002 WL 31427362, at *2 (S.D.N.Y. Oct. 30; 2002) ssssscnsncasasssvarscusncssessossssantasnendtsrsevesevaessnedasensiastainardeosssnasde ndcess cbcnsespsrashetauevavesden 20 DiBella v. Hopkins, 403 F.3d 102, 111 (2d Cir.2005) ..c.cccccceseeeeeeseeeeeseeseeeeneeneeees 25 Egiazaryan v. Zalmayev (“Egiazaryan I’), No. 11 CIV. 2670 PKC, 2011 WL 6097136, at #5 (SDNY. De. 74-2011) sssssntsessscssessssescesscsensaesnentacnsnctaens cezasosoensnaysutaensnetiens cesasutocedeade 3 Egiazaryan v. Zalmayev (“Egiazaryan IT”), 880 F. Supp. 2d 494, 501 (S.D.N.Y. 2012) esata dean Dea sentedens st sav ees dea ase sseusdavcaytvcetiet Gi sides Sata ta stcicantesdns due sauna catecutcu ies odeee sess 3,4,5 Folwell v. Miller, 145 F. 495, 497 (2d Cir. 1906) ......cccccceeseceseeseeesceseeseseseseeneeeneees 24 Front, Inc. v. Khalil, 28 N.E.3d 15, 16 (N.Y. 2015) wocccccceeceeeeeeees 2, 20,21,22,24,25 Geraci v. Probst, 938 N.E.2d 917, 921 (N.Y. 2010)....cccceeeeeeeeeeeeeee 2,3,5,6,8,10,13

Case 18-2868, Document 279, 08/09/2019, 2628231, Page4 of 37 Green v. Cosby, 138 F. Supp. 3d 114 (D. Mass. 2015).....c.ccccscessesesseseseeseseeneetesseeseeseseees 14 Hawkins v. Harris, 661 A.2d 284, 289-91 (N.J. 1995)... Hickman vy. Taylor, 329 U.S. 495, 510-11 (1947) 0... sessessseceseseeseeeesseseeseceecsescsceseeeeeacecees es Hoffman v. Landers, 537 N.Y .S.2d 228, 231 (2d Dep’t 1989) ...occee cence 5 Immuno AG vy. Moor-Jankowski, 567 N.E.2d 1270, 1274 (N.Y. 1991) .eeeceeeeeeneneteeee 13 Karaduman v. Newsday, Inc., 416 N.E.2d 557, 560 (N.Y. 1980)... ceeeeeseeeteeeeeeseeeneeeeee 3 Karedes v. Ackerley Grp., Inc., 423 F.3d 107, 114 (2d Cir. 2005) ...c.cceeeseeeeeeeeneeeee 26 Law Firm of Daniel P. Foster, P.C. v. Turner Broad. Sys., 844 F.2d 955, 959 (2d Cir. LOSS sates teaser cc tata eales VANE ADEs ii Gee Sr astsccs Sas Lavoe Coes Se 15, 28, 29 Levy v. Smith, 18 N.Y.S.3d 438, 439 (2d Dep’t 2015) .....secescesseseeeseeseeseeeeseseeneeeeseeneseeee 5 Liberman v. Gelstein, 605 N.E.2d 344, 349 (N.Y. 1992).....ceccscecssesesesessseeseseseseseeeenenesees 22 National Puerto Rican Day Parade, Inc. v. Casa Pubs. (“NPR”), 914 N.Y.S.2d 120, 122DB (A Depp te 200) saat asccscscisetseacasscnniesssnincesaedssatoniducocsdsccassaiaseseadbeteaeodiessasaniostaaasasuastovesvecy 5 Oliman v. Evans, 750 F.2d 970 (D.C. Cir. 1984) ...cccccccccscessescsseecssceeseesesscseeeeseesesseneeaes 13 Phila. Newspapers v. Hepps, 475 U.S. 767, 773 (1986). .c.cccecesssssesceeseeteeseeseseeesenesees 26 Porky Prods. v. Nippon Exp. U.S.A., 1 F.Supp.2d 227, 234 (S.D.N.Y. 1997).....ceccccseeee 2 Rand v. New York Times Co., 430 N.Y.S.2d 271, 275 a* Dep’t 1980) wee 9,10 Rinaldi v. Viking Penguin, Inc., 420 N.E.2d 377, 382 (N.Y. 1981) ...cecesecseeeeeeeeeeees 2.357 Rinaldi v. Viking Penguin, Inc., 425 N.Y.S.2d 101, 104 (1" Dep’t 1980) ....eesceeseeseeseeeee 3 Rizzuto v. Nexxus Prod. Co., 641 F. Supp. 473, 481 (S.D.N.Y. 1986), aff'd, 810 F.2d LDGT (2d Cit: 1986) iicscsscistesssiacoscacbeesssbacencesssbssgbachacause hosidcoasebusbatebsnsneabessapenacbanstesbervease 16 Schoepflin v. Coffey, 56 N.E. 502 (N.Y. 1900) oo... cece eeseseesescsesesteseseseseeceneneeeeeees 3:5 Steinhilber v. Alphonse, 501 N.E.2d 550 (N.Y. 1986) .....c.ececsseceseeeeeseseseeeseseeneneee 11,13,16 iii

Case 18-2868, Document 279, 08/09/2019, 2628231, Page5 of 37 Sweeney v. Prisoners’ Legal Servs. of N.Y., 538 N.Y.S.2d 370, 371-72 (3d Dep’t 1989). iabedbasbustsebansiodedispansdqbvouesbgSbepsestodhdonsdéesesdbsos vapdegaeagagssegisasaassedusaptdobscabebadbadsapaeaneiosbetsehieniesn 19 Telephone Sys. Int'l v. Cecil, No. 02 CV 9315(GBD), 2003 WL 22232908, at *2 (S:DINGY.«: Sept:.29) 2003). cs. sscscastscatsesacscseetisssnnavscacestaevanacadatscshesnnvnectentoeaetacoeseadass 16, 30 Travelers Indem. Co. v. Northrop Grumman Corp., No. 12 CIV. 3040 KBF, 2013 WL 3055437, at #3:(S. DNV Ys Apt: 225 2013) wccssisscssscssscessonscsivstovansevasonccsssnssetbessesssivevesess 12 United States v. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985).. Rules Federal Rule of Civil Procedure 12(b)(6)... Treatises Sack on Defamation § 2.7.2, at 2-113 to -114 (4" Cd 201G) rsvecon scale are weed 4

Case 18-2868, Document 279, 08/09/2019, 2628231, Page6 of 37 PRELIMINARY STATEMENT Before the Court reaches the question whether plaintiff can prove falsity and actual malice, it should decide three questions of law, one that narrows considerably the legal issues and two that dispose of the case entirely. 1. It is undisputed Ms. Maxwell, through her agents, sent to various mediarepresentatives—and to no one else—the January 2015 statement. It is undisputed she had no control over any of the media that decided to republish excerpts from the statement. On these facts, under black letter New York law, she is not responsible for these republications. Plaintiffs contrary argument relies on a “foreseeability” doctrine the New York Court of Appeals has specifically rejected. Summary judgment should enter in favor of Ms. Maxwell as to any republication. 2. Under the New York Constitution, whether a statement is constitutionally nonactionable opinion depends upon, among other things, an examination of the full context of the communication and consideration of the setting surrounding it. The January 2015 statement, making no reference to specific allegations, explains why the author believes plaintiff's allegations are “obvious lies”: “Each time the story is re told [sic] it changes with new salacious details... .” It is an expression of a venerable opinion: when a person falsely cries wolf previously, others are free to opine she is telling falsehoods now. This is nonactionable opinion. 3. Under New York law, a statement made pertinent to good faith anticipated litigation is nonactionable. The statement was sent exclusively to the media representatives, and contained a clear message: the media should not republish plaintiff's “obvious lies,” else Ms. Maxwell would sue them. Such a statement is nonactionable. If the Court reaches the question of falsity and actual malice, the Rule 56 record establishes plaintiff cannot prove falsity and actual malice by clear and convincing evidence. 1

Case 18-2868, Document 279, 08/09/2019, 2628231, Page7 of 37 ARGUMENT I. Ms. Maxwell is not liable for republications of the January 2015 statement. Under black letter New York law, liability for republication of an allegedly defamatory statement “must be based on real authority to influence the final product.” Davis v. CostaGavras, 580 F. Supp. 1082, 1096 (S.D.N.Y. 1984). “[WJhere a defendant ‘had no actual part in composing or publishing,’ he cannot be held liable.” Jd. (citing Folwell v. Miller, 145 F. 495, 497 (2d Cir. 1906)); accord Geraci v. Probst, 938 N.E.2d 917, 921 (N.Y. 2010). “[CJonclusive evidence of lack of actual authority [is] sufficiently dispositive that the {trial court] ‘ha[s] no option but to dismiss the case... .”” Id. (emphasis supplied; quoting Rinaldi v. Viking Penguin, Inc., 420 N.E.2d 377, 382 (N.Y. 1981)). It is undisputed Ms. Maxwell and her agents had no ability to control and did not control whether or how the media-recipients would use the statement. Doc. 542-7, Ex.J {ff 2-3; id., Ex.K {| 24. Unsurprisingly, plaintiff has offered no evidence of such control. A fortiori this Court “ha[s] no option but to dismiss the case,” id. (internal quotations omitted), to the extent it is founded upon the media’s republication of the statement. A. Plaintiff’s argument against summary judgment is substantially groundless. A legal argument is frivolous if it is presented contrary to a “long line of authorities” and the “fundamental principles”! of the underlying substantive law. Plaintiff Giuffre’s argument opposing summary judgment as to republication is frivolous. The New York Court of Appeals in Geraci followed a long line of New York cases holding that a defamation defendant is not liable for republication of his allegedly defamatory statement unless he had “‘actual authority” to control the decision to republish: “Our ‘Porky Prods. v. Nippon Exp. U.S.A., | F.Supp.2d 227, 234 (S.D.N.Y. 1997), aff'd, 152 F.3d 920 (2d Cir, 1998).

Case 18-2868, Document 279, 08/09/2019, 2628231, Page8 of 37 republication liability standard has been consistent for more than one hundred years.” See Geraci, 938 N.E.2d at 921 (footnote omitted). Indeed, the Geraci court observed, the New York Court of Appeals in Schoepflin v. Coffey, a case decided in 1900, held: “Tt is too well settled to be now questioned that one who . . . prints and publishes a libel[] is not responsible for its voluntary and unjustifiable repetition, without his authority or request, by others over whom he has no control and who thereby make themselves liable to the person injured, and that such repetition cannot be considered in law a necessary, natural and probable consequence of the original slander or libel.” 938 N.E.2d at 921 (emphasis supplied; quoting Schoepflin, 56 N.E. at 504). The cases in which this Court and its sister courts in this Circuit assiduously have followed this line of New York cases are legion.’ The Second Circuit was in the vanguard.* °56 N.E. 502 (N.Y. 1900). *See Egiazaryan v. Zalmayev, 880 F. Supp. 2d 494, 501 (S.D.N.Y. 2012) (“{tJhe original publisher is not liable for republication where he had ‘nothing to do with the decision to [republish] and [he] had no control over it.’”) (quoting Rinaldi v. Viking Penguin, Inc., 425 N.Y.S.2d 101, 104 (1 Dep’t 1980), aff’d, 420 N.E.2d 377 (N.Y. 1981)); Egiazaryan v. Zalmayev, No. 11 CIV. 2670 PKC, 2011 WL 6097136, at *5 (S.D.N.Y. Dec. 7, 2011) (same); Davis v. Costa-Gavras, 595 F. Supp. 982, 988 (S.D.N.Y. 1984) (“Under New York law, liability for a subsequent republication must be based on real authority to influence the final product, not upon evidence of acquiescence or peripheral involvement in the republication process.”); Davis, 580 F. Supp. at 1094 (original publisher not liable for injuries caused by the republication “absent a showing that they approved or participated in some other manner in the activities of the third party republisher’”) (quoting Karaduman v. Newsday, Inc., 416 N.E.2d 557, 560 (N.Y. 1980)); Croy v. A.O. Fox Mem’ Hosp., 68 F. Supp. 2d 136, 144 (N.D.N.Y. 1999) (“The original author of a document may not be held personally liable for injuries arising from its subsequent republication absent a showing that the original author approved or participated in some other manner in the activities of the third-party republisher.”) (citations omitted); Cerasani v. Sony Corp., 991 F. Supp. 343, 351 (S.D.N.Y. 1998) (“a libel plaintiff must allege that the party had authority or control over, or somehow ratified or approved, the republication”). ‘See Folwell v. Miller, 145 F. 495, 497 (2d Cir. 1906) (affirming directed verdict in favor of managing editor: “when it appears affirmatively that he was not on duty [upon receipt of libelous matter and its republication], and could not have had any actual part in composing or publishing, we think he cannot be held liable without disregarding the settled rule of law by which no man is bound for the tortious act of another over whom he has not a master’s power of control”) (emphasis supplied), quoted with approval in Davis I, 580 F. Supp. at 1096; Cerasani, 991 F. Supp. at 351.

Case 18-2868, Document 279, 08/09/2019, 2628231, Page9 of 37 In the face of this uninterrupted line of New York state (and federal) cases dating back to the nineteenth century powerfully establishing a bright line rule regarding republication liability, plaintiff Giuffre manages what amounts to a—frivolous—murmur of opposition. She claims there are “[t]wo standards” in New York law: one “older,” and one “more modern.” Resp. 28. The “older” standard, plaintiff says, is represented by the legion of cases we have cited. The “more modern formulation”—where can it be found? Why, in one place: a treatise on defamation. Jd. (citing Sack on Defamation § 2.7.2, at 2-113 to -114 (4" ed. 2016). It surely is frivolous to argue that a treatise creates a republication-liability standard that is separate from, “more modern” than, and supersedes the New York Court of Appeals’ 2010 decision in Geraci and this Court’s 2012 decision in Egiazaryan. Trying to build on this start, plaintiff argues, “New York appellate courts have repeatedly held than an individual is liable for the media publishing that individual’s defamatory press release.” Resp. 28 (emphasis supplied). Even if we accept plaintiff's mischaracterization of the January 2015 statement as a “press release,” her argument still would be meritless. To begin with, when plaintiff says the New York appellate courts have “repeatedly” supported her claimed tule of law, she means . . . twice. And an examination of those two cases reveals she is quite wrong and, worse, has advanced a seriously misleading argument. Neither case involved, as here, a motion for summary judgment. In both cases, the New York appellate division affirmed the denial of a motion to dismiss under the state’s equivalent of Federal Rule of Civil Procedure 12(b)(6). See Levy v. Smith, 18 N.Y.S.3d 438, 439 (2d Dep’t 2015); National Puerto Rican Day Parade, Inc. v. Casa Pubs. (“NPR”), 914 N.Y.S.2d 120, 122-23 (1 Dep’t 2010). >As discussed in This Reply, at 16-19, the January 2015 statement would be a strange “press release,” as it threatened to sue the very press to which it was “releasing” information.

Case 18-2868, Document 279, 08/09/2019, 2628231, Page10 of 37 This argument, too, is frivolous. Despite plaintiff's baseless claim there is an “old” formulation and a “more modern” formulation of republication-liability law in New York, both cases she cites applied the same “old” standard used by the New York Court of Appeals in Geraci, by this Court in the two Egiazaryan cases, and by us in our Memorandum of Law in support of Ms. Maxwell’s motion for summary judgment. See Levy, 18 N.Y.S.3d at 439 (citing Geraci and Schoepflin); NPR, 914 N.Y.S.2d at 594-95 (citing Hoffman v. Landers, 537 N.Y.S.2d 228, 231 (2d Dep’t 1989) (citing Schoepflin)). Both the courts in Levy and NPR applied the Geraci standard and the 12(b)(6) standards, e.g., assuming the pleaded facts were true. They concluded it was possible to infer from the complaints’ allegations that the defendant caused the republications. Accordingly, they denied the motions to dismiss. See Levy, 18 N.Y.S.2d at 439; NPR, 914 N.Y.S.2d at 123. It was improper for plaintiff to cite these cases without disclosing they are 12(b)(6) cases in which the courts applied the Geraci republication rule and inferred facts from the pleaded allegations. B. New York state and federal courts have rejected liability for republication based on “foreseeability.” Plaintiff cites section 576 of the Restatement (Second) of Torts for the proposition that if republication was foreseeable, then the defendant is the cause of any special damages from the republication. This argument is frivolous. As an initial matter, plaintiff has pleaded no special damages. See Doc.1; Doc.23 at 23; Doc.37 at 17. Regardless, the New York Court of Appeals in Geraci rejected the Restatement’s foreseeability doctrine. See 938 N.E.2d at 921-22 (noting that section 576’s foreseeability standard “‘is not nearly as broad as plaintiff. . . suggest[s]” and “[t]hat we did not endorse sucha broad [Restatement] standard of foreseeability in Karaduman is evident from our decision the following year in Rinaldi’) (emphasis supplied).

Case 18-2868, Document 279, 08/09/2019, 2628231, Page11 of 37 While trying to distinguish this Court’s decision in Davis, plaintiff fails to disclose that Davis itself—decided 26 years before Geraci—also rejected plaintiff's foreseeability argument. The Davis plaintiffs, like plaintiff Giuffre here, also asserted republication liability, despite defendant’s lack of participation, on the ground “he could reasonably have foreseen that republication would occur.” 580 F.Supp. at 1096. This Court, relying on Karaduman, was unpersuaded: The New York Court of Appeals “has not applied the foreseeability standard suggested by plaintiffs in prior libel cases in which such a standard would have been relevant, if not controlling.” /d. This Court noted: The jurisdictions that have adopted a foreseeability standard “have refused to hold responsible a defendant with no control or influence over the entity that actually republished the statement.” Jd. Plaintiff's failure to disclose this Court’s holdings in Davis is a notable lapse in candor. C. Plaintiff’s purported application of the Geraci rule is misleading and wrong. Plaintiff eventually purports to apply the “old” standard, that is to say, the controlling law in the state of New York. She argues Ms. Maxwell “authorized” the January 2015 statement, “paid money to her publicist to convince media outlets to publish it,” “request[ed]” its publication, “made a deliberate decision to publish her press release,” “actively participated” in “the decision to publish her press release,” was “active” in “influencing the media to publish” the statement, and “approved of” and “pushed for” the publication of the statement. Resp. 30-31. These argument-manufactured facts have no record support. In applying the controlling law, plaintiff wittingly makes a mess of it. She disingenuously suggests any help Ms. Maxwell gave to help her lawyer prepare the January 2015 statement and her signing-off on it are the equivalent of requesting, authorizing and controlling its republication. That isn’t the law. The “authority” required for republication liability is the “actual authority . . . to decide upon or implement” the republication. 580 F.Supp. at 1095 6

Case 18-2868, Document 279, 08/09/2019, 2628231, Page12 of 37 (emphasis supplied; citing Rinaldi, 420 N.E.2d at 382). Judge Sofaer studied Rinaldi’s holding, and noted republication liability must be based on a “decision” by the defendant to republish and must focus on “real authority to influence the final product, not upon evidence of acquiescence or peripheral involvement in the republication process.” Id. at 1096 (emphasis supplied). Accordingly, Judge Sofaer held, when there is “conclusive evidence of lack of actual authority” this is “dispositive” of republication liability and the trial court “‘ha[s] no option but to dismiss the case against the [defendant].” Jd. (emphasis supplied; quoting Rinaldi, 420 N.E.2d at 382). There is no evidence Ms. Maxwell “paid money to her publicist to convince” the media to publish her statement; this is why plaintiff cites no evidence to support that assertion. See Resp. 30. Mr. Gow’s email containing the statement says nothing to “convince” the media to publish the statement. See Doc.542-6, Ex.F. There is no evidence Ms. Maxwell was “active” in “influencing the media to publish” it; nor is there any evidence she “pushed for” or “requested” its publication; this is why plaintiff cites no evidence to support these assertions. See id. 31. Indeed, plaintiff has zero evidence Ms. Maxwell or her agents ever did anything to urge or request any media to publish the statement. Mr. Gow presented the January 2015 statement via email to six to thirty media representatives; it was not sent to anyone else; in the email he told the journalists he was presenting a “quotable statement” “on behalf of’ Ms. Maxwell and “{njo further communication will be provided.” Doc.542-6, Ex.F. It is undisputed Ms. Maxwell and her agents had no control over the media that republished portions of the statement. Doc.542-7, 542-7, Ex.J Jf] 2-3; id., Ex.K 24. Plaintiff argues “a jury” should decide whether Ms. Maxwell “authorized or intended” the statement to be republished, or “approved of, and even participated, in” its republication. Resp. 30-31. All plaintiffs want to get to “a jury.” The summary-judgment question is whether they deserve to. Plaintiff has offered no evidence to put before a jury on the dispositive Geraci 7

Case 18-2868, Document 279, 08/09/2019, 2628231, Page13 of 37 question: whether Ms. Maxwell affirmatively authorized or requested a person or entity “over whom [s]he has . . . control,” 938 N.E.2d at 921. The only new argument plaintiff makes in her entreaty to see “a jury” is that she should be permitted to prove Ms. Maxwell’s “complicity.” As with her other factually bereft arguments, the complicity argument awaits plaintiff's introduction of facts to support it. Having failed to do so, plaintiff cannot avoid summary judgment. Plaintiff labors in vain to turn the Barden Declaration into “disputed issues of fact.” For there to be a disputed factual issue, plaintiff would need to introduce evidence disputing his sworn statements. She has not done so. In any event, the Barden Declaration is all but irrelevant to the central, dispositive republication question: whether Ms. Maxwell is liable for the media’s republication of her statement, where they did so without her authority or request and where she and her agents had “no control’”® over the media. On this question we cited to the Barden Declaration for one evidentiary fact: Messrs. Barden and Gow had no control over the media.’ See Doc.542-7, Ex.K J 24, cited in Memo. of Law 14.5 Plaintiff has offered no admissible evidence disputing this fact. “[T]here is no issue for trial unless there is sufficient evidence favoring the nonmoving party for a jury to return a verdict for that party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986). It is one thing to argue in conclusory fashion, as plaintiff does, that “a jury” should decide a factual question. It is quite another to identify evidence in the Rule 56 record that raises a genuine question of material fact, which plaintiff does not do. Summary judgment is warranted. °Geraci, 938 N.E.2d at 921. TAs discussed in Argument LD., below, we cited more plenarily to the Barden Declaration in connection with a different point—the particular unfairness of subjecting Ms. Maxwell to liability when the media selectively quoted portions of the January 15 statement. 5In the Memorandum, we erroneously cited to J 24 of Exhibit J; we intended to cite to q 24 of Exhibit K (Doc.542-1, Ex.K), which is Mr. Barden’s declaration.

Case 18-2868, Document 279, 08/09/2019, 2628231, Page14 of 37 D. Subjecting Ms. Maxwell to liability for the media’s republication of excerpts they unilaterally selected is particularly unfair. It is undisputed that no one ever republished in toto the January 2015 statement and that various media unilaterally selected portions of the statement to republish. We said on page 14 of our Memorandum that the media’s “selective, partial republication of the statement is more problematic yet” (emphasis altered). That is to say, as improper as it is to hold a publisher of a statement liable for republications over which she had no control, worse is it to make her liable for selective, partial republications of her statement. We relied on the holding in Rand v. New York Times Co., 430 N.Y.S.2d 271, 275 (1" Dep’t 1980), that a publisher cannot be charged with a republisher’s “editing and excerpting of her statement.” Memo. of Law 14. Plaintiff argues that our position is “absurd on its face” because “[i]t would mean ...a defamer could send to the media a long attack on a victim with one irrelevant sentence and, when the media quite predictably cut that sentence, escape liability.” Resp. 32. This argument has two erroneous assumptions. One is that the “defamer” can “escape liability.” Not true. An original publisher remains liable for her defamation. We are concerned here with republication. The second wrong assumption is that the original publisher must always remain liable for any republication. Geraci rejects that view: Under New York law “each person who repeats the defamatory statement is responsible for the resulting damages.” 938 N.E.2d at 921. The effort by plaintiff to distinguish Rand is meritless. She argues the media’s republication of the January 2015 statement actually was not a republication at all, just an original publication. Resp. 32. That argument is “absurd on its face,” id., since there is no dispute Ms. Maxwell did not control the media’s decision to republish (excerpts from) the statement. Plaintiff next argues the media did not “edit[]” or “tak[e] . . . quote[s] out of context.” Id. Plaintiff could not be more wrong. As she concedes, all republications of the statement by the

Case 18-2868, Document 279, 08/09/2019, 2628231, Page15 of 37 media were selective, partial republications of the statement. Any such selective, partial republication by definition took those excerpts “out of context.” This is so because Mr. Gow informed the media in his email that he was providing “a quotable statement,” Doc.542-6, Ex.F, not a statement “from which you, the media, are free to excerpt as you please.” More importantly, as Mr. Barden explained, selectively excerpting the statement substantially altered his message. See id., Ex.K J 20. For example, when he said in the third paragraph that plaintiff's claims are “obvious lies,” it followed two paragraphs in which he explained why it was obvious the new claims are lies. See id., Ex.K JJ 19-22. Excerpting and republishing only the “obvious lies” phrase—as plaintiff did in her complaint—certainly gives the reader a different understanding than if the media had republished the entire statement. As Rand held: A defendant cannot be liable for the republication of derogatory but constitutionally protected opinion “when the foundation upon which that opinion is based is omitted. The defamatory remark should be read against the background of its issuance.” 430 N.Y.S.2d at 275 (internal quotations omitted). Plaintiff argues: “A jury could reasonably conclude that [Ms. Maxwell’s] statement that Ms. Giuffre’s claims of child sexual abuse are ‘obvious lies’ is not a rhetorical device, nor hyperbole, but a literal and particular affirmation that [plaintiff] lied.” Resp. 33 (emphasis supplied). We italicize plaintiff's rhetorical sleight of hand. As plaintiff knows, nowhere did the January 2015 statement specify which of plaintiff's countless allegations are “obvious lies.” Indeed, this is the problem with plaintiff's case: since the statement specified no particular allegations as obvious lies, plaintiff believes she is entitled to “prove” the truth of every allegation she ever has made about her alleged experience as a “sex slave.” What Mr. Barden’s declaration makes clear is he deliberately made no reference to any specific allegation by plaintiff. He had a bigger target: plaintiff's credibility. He used the statement to show plaintiff's 10

Case 18-2868, Document 279, 08/09/2019, 2628231, Page16 of 37 behavior is that of a liar, i.e., one who increasingly embellishes her story, and her allegations become more and more outlandish, so that by January 2015 she was claiming to have had sex with a well respected Harvard law professor, Alan Dershowitz. See Doc.542-7, Ex.K J 19-22. Contrary to plaintiff's argument, “even apparent statements of fact may assume the character of statements of opinion, and thus be privileged, when made in public debate . . . or other circumstances in which an audience may anticipate the use of epithets, fiery rhetoric or hyperbole.” Steinhilber v. Alphonse, 501 N.E.2d 550, 556 (N.Y. 1986) (internal quotations and brackets omitted). That was the case here. Plaintiff falsely—and, as Judge Marra held, “unnecessar[ily]”°—alleged in lurid detail that Ms. Maxwell had sexually abused her. The six to thirty journalists would have anticipated a “fiery” denial of the allegations. Regardless, the statement overall was constitutionally protected opinion grounded on facts disclosed to the journalists: plaintiffs increasingly outlandish and inconsistent stories, her newly embellished allegations, and her increasingly lurid and salacious enhancements of her earlier allegations. E. Mr. Barden’s declaration is perfectly proper. Plaintiff makes a plethora of complaints about Mr. Barden’s declarations. None has any merit. She objects to Mr. Barden’s declaration of his intent and purposes for preparing the January 2015 statement because, she says, this implicates the attorney-client privilege. That is untrue. His intent and purposes are by definition nor attorney-client communications and do not implicate such communications; they are attorney work product,'° which he is free to disclose.'! *Doc.542-5, Ex.E, at 5. ‘Travelers Indem. Co. v. Northrop Grumman Corp., No. 12 CIV. 3040 KBF, 2013 WL 3055437, at *3 (S.D.N.Y. Apr. 22, 2013) (identifying work product as including defense counsel’s “mental impressions, thought processes and strategies connected with [the] defense”) . '\S¢e In re China Med. Techs., Inc., 539 B.R. 643, 658 (S.D.N.Y. 2015) 11

Case 18-2868, Document 279, 08/09/2019, 2628231, Page17 of 37 She objects he is “non-deposed.” But Mr. Barden was the third-listed potential witness in our Rule 26(a)(1)(A) disclosure, served on plaintiff a year ago; the disclosure said he “has knowledge concerning press statements by . .. Defendant in 2011-2015 at issue in this matter.”"” Plaintiff was free to depose him; that she chose not to was her own tactical decision. Finally, plaintiff argues “there are factual disputes” regarding the declaration. But plaintiff identified no such factual disputes relating to the declaration. A party opposing summary judgment cannot create a dispute by arguing, which is all plaintiff does. See Resp. 35-38. F. Plaintiff effectively has confessed Arguments I.B. and I.C. of the Memorandum. Argument I.B. of the Memorandum contends the First Amendment bars liability for republication by media organizations of the January 2015 statement. See Memo. of Law 16-17. Argument I.C. contends that under Geraci plaintiff is barred from introducing into evidence any of the media organizations’ republication of the January 2015 statement. See id. at 17-18. Plaintiff offers no resistance to these arguments. We respectfully request that the Court consider these arguments confessed. See, e.g., Cowan v. City of Mount Vernon, 95 F. Supp. 3d 624, 64546 (S.D.N.Y. 2015) (citing cases). II. The January 2015 statement is constitutionally protected opinion. In deciding whether a statement is opinion the New York Constitution requires application of “the widely used four-part Ollman''*! formula,” Immuno AG v. Moor-Jankowski, 567 N.E.2d 1270, 1274 (N.Y. 1991). See id. at 1274, 1277-78, 1280-82 (noting Steinhilber’s adoption of formula). We addressed each of the four Ollman factors. The plaintiff avoids this analysis, choosing merely to block-quote large portions of this Court’s Rule 12(b)(6) order. That "Menninger Decl. EXHIBIT NN, at 2. 8Oliman v. Evans, 750 F.2d 970 (D.C. Cir. 1984). 12

Case 18-2868, Document 279, 08/09/2019, 2628231, Page18 of 37 is a mistake. Jnmmuno AG is the seminal case prescribing the analysis to be used in a summaryjudgment proceeding for assessing whether under the New York Constitution a statement is absolutely protected as opinion. Instead of addressing the four factors, plaintiff simply relies on this Court’s 12(b)(6) order. The Court’s order does not control. In deciding the Rule 12(b)(6) motion, the Court assumed the complaint’s allegations were true and drew all reasonable inferences in plaintiff's favor. In this proceeding, plaintiff is not entitled either to the assumption or the inferences. The opinion-versus-fact question will be controlled by the Rule 56 record. Relying on the Court’s order, plaintiff argues that the question whether the three allegedly defamatory sentences are opinion or fact is controlled by Davis v. Boeheim, 22 N.E.3d 999 (N.Y. 2014), and Green v. Cosby, 138 F. Supp. 3d 114 (D. Mass. 2015). See Resp. 38. Davis was an appeal from a 12(b)(6) dismissal. This procedural posture was critical to its decision: [D]efendants argue that because a reader could interpret the statement as pure opinion, the statement is as a consequence, nonactionable and was properly dismissed [pursuant to a pre-answer motion]. However, on a motion to dismiss we consider whether any reading of the complaint supports the defamation claim. Thus, although it may well be that the challenged statements are subject to defendants’ interpretation, the motion to dismiss must be denied if the communication at issue, taking the words in their ordinary meaning and in context, is also susceptible to a defamatory connotation. We find this complaint to meet this minimum pleading requirement. Davis, 22 N.E.3d at 1006-07 (internal quotations, brackets, ellipsis and citations omitted). Green was a decision on the defendant’s motion to dismiss. The case was decided under California and Florida defamation law. See 138 F. Supp. 3d at 124, 130, 136-37. The court made it clear the 12(b)(6) procedural posture was critical to its decision: “At this stage of the litigation, the court’s concern is whether any fact contained in or implied by an allegedly defamatory statement is susceptible to being proved true or false; if so capable, Defendant cannot avoid application of defamation law by claiming the statement expresses only opinion.” Jd. at 130. 13

Case 18-2868, Document 279, 08/09/2019, 2628231, Page19 of 37 In the case at bar, application of the four Steinhilber factors on the Rule 56 record compels a different conclusion. The complaint alleges three sentences in the January 2015 statement are defamatory: in the first paragraph of the statement, plaintiff Giuffre’s allegations are “untrue”; in the same paragraph, the “original allegations” have been “shown to be untrue”; and in the third paragraph, plaintiff's “claims are obvious lies.”'* Doc.1 {[ 30. Factor 1: Indefiniteness and ambiguity. On the face of the complaint in a 12(b)(6) proceeding, the words “untrue” and “obvious lies” might be susceptible of “a specific and readily understood factual meaning,” Doc.37 at 9. This is especially true if it is taken out of context, e.g., extracted from the statement. But this approach is forbidden. See, e.g., Law Firm of Daniel P. Foster, P.C. v. Turner Broad. Sys., 844 F.2d 955, 959 (2d Cir. 1988). The first sentence—“[t]he allegations made by [plaintiff] against [Ms. Maxwell] are untrue”—is indefinite and ambiguous because it is wholly unclear which “allegations” are being referenced. The second sentence—‘{t]he original allegations . . . have been fully responded to and shown to be untrue”—also is indefinite and ambiguous for the same reason. Additionally, it is unclear what are the “original” allegations. It is unclear what is meant by “shown to be untrue.” What one person may believe is a fact shown to be untrue, another person may believe is a fact not (sufficiently) shown to be untrue. The existence of God, climate change and existence of widespread voter fraud in the election are examples of this. The third sentence— '4Ms. Maxwell testified in her deposition that she “know[s]” plaintiff is a “liar.” This testimony, plaintiff argues, “contradict[s]” our contention that the three allegedly defamatory sentences in the July 2015 statement are opinion. Resp. 39-40. Plaintiff's argument is a nonsequitur. Ms. Maxwell’s 2016 deposition testimony in which she disclosed all the reasons she believes plaintiff has uttered a plethora of false allegations is irrelevant to whether the three sentences in the July 2015 statement, prepared by Mr. Barden to respond to the joint-motion allegations, are opinions.

Case 18-2868, Document 279, 08/09/2019, 2628231, Page20 of 37 “{plaintiff’s] claims are obvious lies”—also is indefinite and ambiguous. An “obvious lie” to one person is not an “obvious lie” to another. Factor 2: Capable of being characterized as true or false. On the 12(b)(6) record, the Court held the three statements “are capable of being proven true or false.” Doc.37 at 9. As a general question of law, one person’s statement that another person’s allegations are “untrue” or are “obvious lies” is not necessarily capable of being proved true or false—regardless of the subject matter of the opined “untruths” or “lies.” See Rizzuto v. Nexxus Prod. Co., 641 F. Supp. 473, 481 (S.D.N.Y. 1986), aff'd, 810 F.2d 1161 (2d Cir. 1986); Telephone Sys. Int’l v. Cecil, No. 02 CV 9315(GBD), 2003 WL 22232908, at *2 (S.D.N.Y. Sept. 29, 2003); Memo. of Law 35 (citing cases). As Steinhilber observed, “even apparent statements of fact may assume the character of statements of opinion, and thus be privileged.” 501 N.E.2d at 556. At least two of plaintiff's CVRA allegations cannot be proven true or false (only two such allegations are needed in order to render the January 15 statement an opinion). We have identified two such allegations in the joinder motion: that Ms. Maxwell “appreciated the immunity granted” to Epstein, and that she “act[ed] as a ‘madame’ for Epstein.” Memo. of Law 22. Plaintiff does not dispute this. The result is that the January 15 statement’s assertion that plaintiff's “allegations” and “claims” in the joint motion are “untrue” or “obvious lies” is by definition an opinion. It cannot be proven true or false whether Ms. Maxwell “appreciated” Epstein’s immunity or whether she “acted as a madame.” Indeed, it seems quite obvious that the joinder-motion allegations about “appreciation” and “madame” are themselves opinion. In the statement, Mr. Barden on behalf of Ms. Maxwell also says plaintiff's “original allegations . . . have been fully responded to and shown to be untrue.” Doc.542-6, Ex.F. This cannot be proven true or false. The “full response” to the original allegations is a reference to the “Statement on Behalf of Ghislaine Maxwell” issued March 9, 2011, in response to plaintiff's 15

Case 18-2868, Document 279, 08/09/2019, 2628231, Page21 of 37 allegations contained in media stories, including the Churcher articles. See Doc.542-3, Ex.C. Whether the 2011 statement “fully” responded to the original allegations and whether it “showed” the original allegations to be untrue are pure (argumentative) opinion. “[O]bvious lies” on its face is an opinion. The “obviousness” of a lie simply cannot be proven true or false. Factor 3: The full context of the statement. Three contextual facts are revealed by the Rule 56 record. One, the email transmitting the statement to the media-representatives—along with the third-person references to Ms. Maxwell—told them Ms. Maxwell did not prepare the statement: “Please find attached a quotable statement on behalf of Ms. Maxwell.” Doc.542-6, Ex.F (emphasis supplied). It is undisputed that in fact Mr. Barden prepared the bulk of it and ultimately approved and adopted as his work all of it. Doc.542-7, Ex.K J 10. Two, Mr. Barden’s statement issued on behalf of his client would not be a traditional press release solely to disseminate information to the media; this is why he did not request Mr. Gow or any other public relations specialist to prepare or participate in preparing the statement. /d., Ex.K J 15. The statement was a broad-brush communique to the media about plaintiff and her new allegations; it was not to be a “point by point” rebuttal of each new allegation. Id., Ex.K J 13. The logic and approach to preparing the statement were simple: compare plaintiff’s prior allegations and conduct in telling her story with her current allegations and conduct. See generally id., Ex.K J 13. When he wrote the statement, he knew of plaintiff's 2011 allegation that she had nor had sex with Prince Andrew and he knew of her CVRA allegation that she did have sex with him. Id., Ex.K J 14. Also within his knowledge was the story she had told Churcher before March 201 1—a story that was far /ess provocative and salacious than the one she included in the joinder motion. See id., Ex.K ] 5; compare Docs.542-1 & 542-2, Exs.A & B (Churcher articles published March 2011) with Doc.542-4, Ex.D (plaintiff's joinder motion containing dramatically different and more lurid and salacious allegations). 16

Case 18-2868, Document 279, 08/09/2019, 2628231, Page22 of 37 Mr. Barden’s approach provides critical context to explaining how the statement builds a logical argument that the new allegations are false. It first notes plaintiff's “original allegations”; then it points out how the story changed and was embellished over time, “now” with allegations that plaintiff had sex with a prominent and highly respected Harvard law professor (“Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders . . . .”). The argument builds up to the opinion in the third paragraph: “[Plaintiff’s] claims are obvious lies and should be treated as such . . . .” Doc.542-6, Ex.F. See generally id., Ex.K | 13-22. This third paragraph—and the threat in the fourth paragraph to sue the media for republication of plaintiffs falsehoods—confirms what is plain from the statement itself: it was not a traditional press release. Three, the statement was intended to respond (via denial) to the media-recipients’ requests for a reply to the new CVRA joinder-motion allegations. Jd. JJ 8, 10, 16. But more than that, it was intended to be “a shot across the bow” of the media. Jd. 17. The logical argument was created to (a) persuade the media-recipients that they needed to “subject plaintiff's allegations to inquiry and scrutiny”; (b) explain to the media-recipients how it was “obvious” that plaintiff “had no credibility” because of her shifting story and increasingly lurid and salacious allegations as time went on, many of which (e.g., the allegations of sex with Prince Andrew and Professor Dershowitz) on their face appear far-fetched, '> and (c) warn the media'SSince the CVRA joinder motion, there has emerged a substantial amount of evidence— some from plaintiff's own pen—that plaintiff's allegations about having been “forced” to have sex with prominent individuals are falsehoods. A telling example is a series of emails between plaintiff and reporter Churcher when plaintiff was working on negotiating a book deal about her alleged experiences and Churcher was trying to help her. On May 10, 2011, plaintiff tells Churcher she cannot remember whom she had told Churcher she had had sex with. Churcher responds responds, “Don’t forget Alan Dershowitz,” which Churcher says is a “good name for [plaintiff's] pitch” to her literary agent. It is clear neither Churcher nor plaintiff believed plaintiff (footnote cont'd on next page) 17

Case 18-2868, Document 279, 08/09/2019, 2628231, Page23 of 37 recipients that they republished plaintiff's obvious falsehoods against Ms. Maxwell at their legal peril. See id. JJ 13, 16, 17, 20. As the New York Court of Appeals observed, the context of a statement often is the “key consideration” in fact vs. opinion cases. Davis, 22 N.E.3d at 1006. So it is here. As Davis suggested, the three challenged statements are “subject to [Ms. Maxwell’s] interpretation,” id. at 1007; accord Sweeney v. Prisoners’ Legal Servs. of N.Y., 538 N.Y.S.2d 370, 371-72 (3d Dep’t 1989). The context of the January 2015 statement makes clear that the characterization of plaintiffs allegations and claims as “untrue” or “obvious lies” are ultimate opinions— conclusions—drawn from disclosed facts. Factor 4: The broader setting surrounding the statement, including conventions that might signal to readers that the statement likely is opinion and not fact. It is undisputed that the January 2015 statement was sent exclusively to more than six and fewer than thirty media representatives, each of whom expressly had requested from Mr. Gow that he provide them with Ms. Maxwell’s reply to the new joint-motion allegations. Doc.542-7, Ex.K {J 8, 10. As was obvious from the statement, it was not a traditional press release, as such a release does not explain—lawyer-like—why new allegations when measured against previous allegations lack credibility. Nor does a traditional release threaten to sue the media to whom the release is sent. The media representatives upon receiving the January 2015 statement would have understood it was presenting an (opinionated) argument that plaintiff was not credible because of her had had sex with Professor Dershowitz, since (a) Churcher suggests that he would be a “good name” to “pitch” because of his prominence (“he [represented] Claus von Bulow and a movie was made about that case...title was Reversal of Fortune”), and (b) Churcher states, “We all suspect [Professor Dershowitz] is a pedo[phile] and tho no proof of that, you probably met him when he was hanging put w [Epstein].”” Menninger Decl., EXHIBIT.OO, at Giuffre004096-97 (emphasis supplied).

Case 18-2868, Document 279, 08/09/2019, 2628231, Page24 of 37 inconsistent and shifting sex abuse story and her increasingly lurid allegations against more and more prominent individuals. And they would have understood that these characteristics of a storyteller undermine her credibility and ergo the credibility of her new allegations. In its 12(b)(6) order the Court said the three sentences have the effect of denying plaintiff's story but “they also clearly constitute fact to the reader.” The ruling is affected in two ways by the Rule 56 record. Based on the foregoing discussion of the evidence, the three sentences clearly constitute (argumentative) opinions of Mr. Barden on behalf of Ms. Maxwell. Though the Court did not discuss who is “the reader,” this is important in Steinhilber Factor 4.” Under settled defamation-opinion law, an allegedly defamatory statement is to be viewed “from the perspective of the audience to whom it is addressed.” Dibella v. Hopkins, No. 01 CIV. 11779 (DC), 2002 WL 31427362, at *2 (S.D.N.Y. Oct. 30, 2002). Here, “the reader” is six to thirty journalists. They could not have read the July 2015 statement—or the three allegedly defamatory sentences—the same way it was read by these journalists’ audience, i.e., the general public. This is because, as plaintiff implicitly concedes, these journalists only republished excerpts—and not the entirety of the statement, which would have given context to the three sentences. It is axiomatic that an out-of-context republication of the three sentences—without the rest of the statement—would deprive the reader of the logic and reasoning behind the opinionated conclusion that plaintiff was making “untrue” allegations and telling “obvious lies.”

Case 18-2868, Document 279, 08/09/2019, 2628231, Page25 of 37 Ill. The pre-litigation privilege bars this action. A. The privilege applies to the January 2015 statement. Statements pertinent to a good faith anticipated litigation made by attorneys (or their agents under their direction!®) before the commencement of litigation are privileged and “no cause of action for defamation can be based on those statements,” Front, Inc. v. Khalil, 28 N.E.3d 15, 16 (N.Y. 2015). The facts that must be established, therefore, are (a) a statement, (b) that is pertinent to a good faith anticipated litigation, and (c) by attorneys or their agents under their direction. We did this. See Memo. of Law 6-8, 33-38; Doc.542-7, Ex.K {ff 8-30. For example, Mr. Barden (a) drafted the vast majority of the January 2015 statement and approved and adopted all of it, (b) directed Mr. Gow to send it to the media representatives who had requested Ms. Maxwell’s reply to plaintiff’s joint-motion allegations, (c) in the statement threatened legal action again these media representatives, and (d) at the time of the statement “was contemplating litigation against the press-recipients.” Jd., Ex.K Jf 10, 16-17, 28, 30. Plaintiff argues without citation to authority: Ms. Maxwell herself did not testify she intended to sue; she hasn’t offered any witnesses to testify she intended to bring a lawsuit; she didn’t in fact sue; and—this one is a non-sequitur—the statement was an “attempt[] to continue to conceal her criminal acts.” Resp. 41-42. These arguments fail. The privilege exists without regard to whether Ms. Maxwell testifies she “intended” to sue, whether she has “witnesses” to say she intended to sue, or whether she “in fact” sued. It refers to “anticipated” litigation, not “guaranteed” litigation. Indeed, the point of the pre-litigation privilege is to promote communications that avoid litigation. See Khalil, 28 N.E.3d at 19 (“When litigation is '©See Chambers v. Wells Fargo Bank, N.A., No. CV 15-6976 (JBS/JS), 2016 WL 3533998, at *8 (D.N.J. June 28, 2016); see generally Hawkins v. Harris, 661 A.2d 284, 289-91 (N.J. 1995). 20

Case 18-2868, Document 279, 08/09/2019, 2628231, Page26 of 37 anticipated, attorneys and parties should be free to communicate in order to reduce or avoid the need to actually commence litigation.”). It applies when there is a good faith basis to anticipate litigation. Mr. Barden, Ms. Maxwell’s lawyer who drafted and caused the statement to be sent out, actually was anticipating litigation. Doc.542-7, Ex.K J 28. The argument that the statement was an attempt to “conceal” Ms. Maxwell’s “criminal acts” is fatuous. It would be hard to post facto “conceal” alleged criminal acts that plaintiff luridly and salaciously described in an earlier public filing, i.e., in the CVRA case, in which the United States government was the defendant. Citing no record evidence, plaintiff argues, “The record evidence shows [Mr. Barden] did not make the [January 2015] statement.” Resp. 42. That argument is easily disposed of by Mr. Barden’s uncontested testimony. See Doc.542-7, Ex.K J 10-13, 15-17, 20, 26-28, 30. B. Malice is irrelevant to the pre-litigation privilege. Citing the New York Court of Appeals’ decision in Khalil, we pointed out that malice is not relevant to the pre-litigation privilege. Memo. of Law 34-35. To prevail on the pre-litigation privilege the defendant need only establish one element: the allegedly defamatory statement at issue was “pertinent to a good faith anticipated litigation.”” Jd. (quoting Khalil, 28 N.E.3d at 16). Plaintiff disputes this and, without discussing Khalil or citing authorities, simply argues the pre-litigation privilege is “foreclosed . . . because [Ms. Maxwell] acted with malice.” Resp. 43. As suggested by her inability to find any law to support her, plaintiff is wrong. Under general New York defamation law, “[t]he shield provided by a qualified privilege may be dissolved” if plaintiff in rebuttal can show that the defendant “spoke with ‘malice.’” Liberman v. Gelstein, 605 N.E.2d 344, 349 (N.Y. 1992); accord Khalil, 28 N.E.3d at 19. “Malice” means two things: spite or ill will, and knowledge of falsity or reckless disregard of falsity. Liberman, 605 N.E.2d at 349. Plaintiff relies on this general qualified-privilege law. 21

Case 18-2868, Document 279, 08/09/2019, 2628231, Page27 of 37 The problem for plaintiff is that in Khalil the New York Court of Appeals held this general rule does not apply to the pre-litigation privilege. Khalil worked for a company named Front. After eight years, he resigned and began working for “EOC,” one of Front’s competitors. Front’s lawyer Kimmel sent a demand letter to Khalil alleging he had committed criminal, tortious and ethical misconduct. Kimmel sent another demand letter to EOC and others stating Khalil had conspired with EOC to breach his fiduciary duty to Front. Six months later, Front sued Khalil. Khalil brought a third-party claim against Kimmel for libel per se. The trial court dismissed the lawsuit, ruling that the letters were “absolutely privileged” under the litigation privilege “and that it therefore did not need to reach the question of malice.” 28 N.E.3d at 17 (internal quotations omitted). The Appellate Division affirmed, holding that the litigation privilege absolutely protected the letter “because they were issued in the context of prospective litigation.” Zd. at 18 (internal quotations omitted). The Court of Appeals affirmed, but altered the law on the litigation privilege. It observed, “Although it is well-settled that statements made in the course of litigation are entitled to absolute privilege, this Court has not directly addressed whether statements made by an attorney on behalf of his or her client in connection with prospective litigation are privileged.” Id. (emphasis supplied). Some Appellate Division departments had held the absolute privilege applies to statements made in connection with prospective litigation, but other departments had held such statements were entitled only to a qualified privilege. Id. The answer to whether pre-litigation statements should be absolute or qualified, the Court of Appeals held, is driven by the rationale for protecting pre-litigation statements: When litigation is anticipated, attorneys and parties should be free to communicate in order to reduce or avoid the need to actually commence litigation. Attorneys often send cease and desist letters to avoid litigation. . . . Communication during this pre-litigation phase should be encouraged and not chilled by the possibility of being the basis for a defamation suit. 22

Case 18-2868, Document 279, 08/09/2019, 2628231, Page28 of 37 Id. at 19. However, the court recognized that “extending privileged status to communication made prior to anticipated litigation has the potential to be abused”; extending an absolute privilege to this context, the court said, “would be problematic and unnecessary.” Id. The court held it would recognize only a qualified privilege for pre-litigation communications. /d. Crucially to the case at bar, the court held that the traditional privilegerebuttal malice was inapplicable to the pre-litigation privilege: Rather than applying the general malice standard to this pre-litigation stage, the privilege should only be applied to statements pertinent to a good faith anticipated litigation. This requirement ensures that privilege does not protect attorneys who are seeking to bully, harass, or intimidate their client’s adversaries by threatening baseless litigation or by asserting wholly unmeritorious claims, unsupported in law and fact, in violation of counsel’s ethical obligations. Therefore, we hold that statements made prior to the commencement of an anticipated litigation are privileged, and that the privilege is lost where a defendant proves that the statements were not pertinent to a good faith anticipated litigation. Id. (emphasis supplied). Accordingly, the only question is whether the January 2015 statement Mr. Barden caused to be issued to the six to thirty journalists was “pertinent to a good faith anticipated litigation.” The undisputed evidence establishes that the answer is yes. Mr. Barden anticipated litigation.'” He “fully complied with [his] ethical obligation as a lawyer.”'* He was hardly “bully[ing], harass[ing], or intimidat[ing]” the six to thirty journalists, since he caused a press agent, Mr. See Doc.542-7, Ex.K J 28 (“At the time I directed the issuance of the statement, I was contemplating litigation against the press-recipients . . . .”); id. | 17 (statement was intended as “a shot across the bow’”; “the statement was very much intended as a cease and desist letter to the media-recipients, letting [them] understand the seriousness with which Ms. Maxwell considered the publication of plaintiff's obviously false allegations and the legal indefensibility of their own conduct”); Doc.542-6, Ex.F (“Maxwell . . . reserves her right to seek redress”). '$Doc.542-7, Ex.K J 26. 23

Case 18-2868, Document 279, 08/09/2019, 2628231, Page29 of 37 Gow, to issue the statement,’ and he believed he had an affirmative duty in representing Ms. Maxwell to prepare the statement and cause it to be delivered to the journalists.”” Plaintiff argues that when Mr. Barden issued the January 2015 statement on Ms. Maxwell’s behalf, he had only “‘wholly unmeritorious claims, unsupported in law and fact, in violation of counsel’s ethical obligations’” and did not have “‘good faith anticipated litigation.’” Resp. 46 (quoting Khalil, 28 N.E.3d at 19; italics omitted). Plaintiff’s rationale? Because she was telling the truth and so the media would only be reporting the truth. Jd. That is a nonsensical, frivolous argument. Whether Mr. Barden, who represents Ms. Maxwell, had a meritorious or good faith basis for anticipating defamation litigation has nothing to do with whether the media believed plaintiff was telling the truth, and surely not whether the plaintiff believed or said she was telling the truth. Based on his knowledge of plaintiff's history, Mr. Barden in good faith believed that plaintiff had been making false allegations for years and that the falsity of the allegations “should have been obvious to the media.” Doc.542-7, Ex.K {| 13; see id. Jl 14, 16-17, 20-23, 26-28, 30. Accordingly, at the time he caused the statement to issue, Mr. Barden had a good-faith basis to anticipate litigation against any of the media that republished plaintiff’s false allegations. It hardly matters for purposes of the pre-litigation privilege whether the media republished or did not republish plaintiff's allegations or whether Mr. Barden ultimately did or did not sue any of the media for any republication. As the Khalil court recognized, “[a]ttorneys often send cease and desist letters to avoid litigation,” 28 N.E.3d at 19, and such letters have a The Khalil court admonished attorneys to “exercise caution when corresponding with unrepresented potential parties who may be particularly susceptible to harassment and unequipped to respond properly even to appropriate communications from an attorney.” Khalil, 28 N.E.3d at 19 n.2. See Doc.542-7, Ex.K J 26. 24

Case 18-2868, Document 279, 08/09/2019, 2628231, Page30 of 37 valid purpose protected by the pre-litigation privilege. Mr. Barden testified that the January 2015 statement in fact served as a cease and desist letter. See Doc.542-7, Ex.K J 17. IV. Ms. Maxwell’s January 4, 2015, statement is nonactionable. Plaintiff did not respond to our argument that Ms. Maxwell’s January 4, 2015, statement to a reporter is nonactionable. See Memo. of Law 38-39. We respectfully submit plaintiff has confessed this point. See Cowan, 95 F. Supp. 3d at 645-46. V. Summary judgment is warranted because plaintiff cannot establish falsity or actual malice by clear and convincing evidence. Plaintiff is a public figure. See Memo. of Law 16-17, 49-54. Therefore, she must prove falsity and actual malice. Under New York law, a public-figure defamation plaintiff must go beyond the federal constitutional minimum and prove falsity by clear and convincing evidence. Blair v. Inside Ed. Prods., 7 F. Supp. 3d 348, 358 & n.6 (S.D.N.Y. 2014) (citing DiBella v. Hopkins, 403 F.3d 102, 111 (2d Cir.2005)). She must also prove actual malice by clear and convincing evidence. Karedes v. Ackerley Grp., Inc., 423 F.3d 107, 114 (2d Cir. 2005) (quoting Phila. Newspapers v. Hepps, 475 U.S. 767, 773 (1986)). Clear and convincing evidence is evidence that “produces in the mind of the trier of fact a firm belief or conviction as to the truth of the allegations sought to be established, evidence so clear, direct and weighty and convincing as to enable the factfinder to come to a clear conviction, without hesitancy, of the truth of the precise facts in issue.” Blair, 7 F. Supp. 3d. at 358 (internal quotations and brackets omitted). Plaintiff must prove by clear and convincing evidence (a) the material falsity of three sentences in the context of the January 2015 statement, and (b) Ms. Maxwell’s actual malice, i.e., knowledge of the falsity of the three sentences or reckless disregard of whether they were false. The three sentences are: in the first paragraph of the statement, plaintiff’s allegations are 25

Case 18-2868, Document 279, 08/09/2019, 2628231, Page31 of 37 “untrue”; in the same paragraph, the “original allegations” have been “shown to be untrue”; and in the third paragraph, plaintiff's “claims are obvious lies.””! Doc.1 {{ 30. Plaintiff cannot prove the falsity of the three sentences, let alone actual malice. If the Rule 56 record establishes that two of plaintiff's CVRA joinder-motion allegations are false and two of her “original” allegations are false, this defamation action collapses on itself. This is because the statement does not specify how many of plaintiffs allegations are false; it certainly does not say “all” plaintiff's allegations are false. It uses the plural of “allegation.” The plural of allegation literally means “more than one.” See Memo. of Law 21. Sentence No. 1. Since the sentence does not specify any particular allegation and since plaintiff made a plethora of allegations against Ms. Maxwell, plaintiff would be required to prove the truth of every one of the plethora of allegations and that Ms. Maxwell knew each one of the allegations was true. Conversely, if there are at least two allegations that plaintiff cannot prove to be true or if there was good reason for Ms. Maxwell to believe at least two of the allegations to be false, then summary judgment should enter against plaintiff. There are at least two allegations by plaintiff against Ms. Maxwell that are untrue. In the CVRA joinder motion, plaintiff alleged that in plaintiff's first encounter with Mr. Epstein, Ms. Maxwell took her to Mr. Epstein’s bedroom for a massage that Mr. Epstein and Ms. Maxwell “turned . . . into a sexual encounter,” Doc.542-4, Ex.D, at 3. This allegation contradicted her allegation in the Sharon Churcher article that a woman other than Ms. Maxwell 21M. Maxwell said in her deposition she “know[s]” plaintiff is a “liar.” This testimony, plaintiff argues, “contradict[s]” our contention that the three sentences in the January 2015 statement are opinion. Resp. 39-40. Plaintiff's argument is a non-sequitur. Ms. Maxwell’s 2016 deposition testimony in which she disclosed all the reasons she believes plaintiff has uttered a plethora of false allegations is wholly irrelevant to whether the three sentences in the January 2015 statement, prepared by Mr. Barden to respond to the joint-motion allegations, are opinions. 26

Case 18-2868, Document 279, 08/09/2019, 2628231, Page32 of 37 took her to Mr. Epstein’s bedroom; during the massage that woman gave instructions to plaintiff, and the massage “quickly developed into a sexual encounter.” Doc.542-1, Ex.A, at 4. A second allegation pertaining to plaintiff's entire story about Ms. Maxwell’s introduction of plaintiff to Prince Andrew is untrue. In the joinder motion, plaintiff alleged Ms. Maxwell served an “important . . . role” in “Epstein’s sexual abuse ring,” namely, connecting Mr. Epstein to “powerful individuals” who would sexually abuse plaintiff. Jd., Ex.D, at 5. Plaintiff alleged that in this role Ms. Maxwell introduced plaintiff to Prince Andrew, and she was “forced to have sexual relations with this Prince in three separate geographical locations,” including Ms. Maxwell’s London apartment. Jd., Ex.D, at 5. These allegations directly contradicted her earlier allegations in the 2011 Churcher article that (a) there never was “any sexual contact between [plaintiff] and [Prince] Andrew,” and (b) Prince Andrew did not know “Epstein paid her to have sex with [Epstein’s] friends.” Id., Ex.A, at 6. Mr. Barden on behalf of Ms. Maxwell said in the first sentence that plaintiff's “allegations” —plural—against Ms. Maxwell are “untrue.” We have just established through plaintiff's own contradictory words that it would be fair to characterize at least two of her allegations to be untrue. Having spent significant time with Ms. Churcher in 2011 and having substantial incentive to disclose all important details of her “sex abuse” story, see Menninger Decl. EXHIBIT OO, plaintiff in 2011 presented a story that exculpated Ms. Maxwell and Prince Andrew of the very misconduct that in 2015—after securing a lawyer and seeing her story as a profit vehicle—she inculpated them for. In the face of her contradictory allegations, plaintiff cannot possibly prove by clear and convincing evidence that all her joinder-motion allegations are true, or that when Ms. Maxwell said they were untrue, she knew each one of the allegations was true or that she recklessly disregarded whether each one was true. 27

Case 18-2868, Document 279, 08/09/2019, 2628231, Page33 of 37 Under New York law, a defendant’s allegedly defamatory statement is held “to a standard of substantial, not literal, accuracy.” Law Firm of Daniel P. Foster, 844 F.2d at 959. Here, Ms. Maxwell’s first sentence /iterally is true: more than one of plaintiff's allegations are “untrue.” Accordingly, there is no defamation. Sentence No. 2. The second sentence at issue in this action states, “The original allegations are not new and have been fully responded to and shown to be untrue.” Plaintiff alleges the sentence is defamatory to the extent it asserts the original allegations were “shown to be untrue.” Doc.1 § 30. Plaintiff cannot prove this statement’s falsity. It is a matter of pure opinion whether any given allegation was “shown” to be untrue. Some people require more proof than others to conclude that a fact has been “shown to be untrue.” We discussed above various examples of this, e.g., climate change. Here, Ms. Maxwell via Mr. Barden in March 2011 issued a statement denying plaintiff's Churcher-story allegations as “all entirely false.” Doc.542-3, Ex.C. Plaintiff did not respond to this statement, let alone claim it was defamatory. Her non-response reasonably could be seen as a concession that Ms. Maxwell’s denial was righteous. See Doc.542-7, Ex.K (Mr. Barden: “I would have been remiss if I had sat back and not issued a denial, and the press had published that Ms. Maxwell had not responded to enquiries and had not denied the new allegations; the public might have taken the silence as an admission there was some truth in the in allegations.”). Regardless, we easily can show two of plaintiff’s original allegations are untrue. Many of plaintiffs original allegations are contained in the two Churcher articles, Docs.542-1 & 542-2, Exs.A & B. The articles contained numerous allegations by plaintiff relating to her alleged sexual abuse. In her deposition, plaintiff was shown Deposition Exhibit 7, a collection of some of her allegations in the articles. Plaintiff placed checkmarks by those allegations she admitted— over the course of 20 pages of testimony—were not true. See Menninger Decl. EXHIBIT PP, at 28

Case 18-2868, Document 279, 08/09/2019, 2628231, Page34 of 37 435:7-455:6 & Depo. Ex.7. These include her claims that: (1) she was 17 when she flew to the Caribbean with Mr. Epstein and Ms. Maxwell “went to pick up Bill in a huge black helicopter,” referring to former President Bill Clinton; (2) her conversation with Mr. Clinton about Ms. Maxwell’s pilot skills; and (3) Donald Trump was a “good friend” of Mr. Epstein’s and “flirted with me”. Plaintiff's admissions on the falsity of her original allegations are fatal to her defamation claim as to the second sentence. The eleven admittedly false “original allegations” axiomatically would warrant the second sentence. Plaintiff has no possible way to prove the second sentence is false. Indeed, like Ms. Maxwell’s first sentence, the second sentence literally is true: more than one of plaintiff's original allegations are untrue. A statement that literally is true cannot be defamatory as a matter of law. See Law Firm of Daniel P. Foster, 844 F.2d at 959. Sentence No. 3. Defamation as to the third sentence is foreclosed. To begin with, as discussed above, whether plaintiff has uttered “obvious lies” is a matter of opinion: in the face of plaintiff's gratuitous and lurid allegations of Ms. Maxwell’s years-long participation at the center of a child sex-trafficking ring, for the journalists-recipients of the July 2015 statement the phrase was an anticipated “epithet[], fiery rhetoric or hyperbole,” Steinhilber, 501 N.E.2d at 556 (internal quotations omitted); see Tel. Sys. Int’l, 2003 WL 22232908, at *2 (observing Court’s previous holding in Rizzuto that defendants’ use of phrases “conned,” “rip off’ and “lying” in advertisements were not actionable as libel and were “rhetorical hyperbole, a vigorous epithet used by those who considered themselves unfairly treated and sought to bring what they alleged were the true facts to the readers”) (internal quotations omitted). Even if arguendo the third sentence—plaintiff’s “claims are obvious lies”—cannot be considered opinion, the Rule 56 record forecloses a defamation claim. The sentence does not Ps “ specify which of plaintiff’s “claims,” i.e., allegations, are obvious lies. It could refer to the 29

Case 18-2868, Document 279, 08/09/2019, 2628231, Page35 of 37 “original” claims; the “new,” CVRA claims; the claims against Ms. Maxwell; the claims against anyone, including Professor Dershowitz, who was mentioned in the preceding sentence; or any two or more of all the claims plaintiff ever had made about her alleged experiences as the alleged victim of a child sex-trafficking ring. Regardless of what is being referred to, there is no defamation. As demonstrated in the discussion above of the first and second sentences, the Rule 56 record establishes that at least two of plaintiff's “original” allegations are untrue, at least two of her CVRA allegations are untrue, at least two of her allegations against Ms. Maxwell are untrue, at least two of her allegations against anyone (e.g., Ms. Maxwell, Prince Andrew or Professor Dershowitz) are untrue, and at least two of her allegations about her alleged sex-trafficking experiences are untrue. Moreover, the untruthfulness—the falsity—of the allegations certainly is “obvious.” After all, plaintiff herself admitted under oath that a multitude of her original allegations are untrue, and she implicitly admitted some of her CVRA allegations are untrue because they were contradicted by her original allegations. CONCLUSION The Court should grant summary judgment in favor of Ms. Maxwell. February 10, 2017.

Case 18-2868, Document 279, 08/09/2019, 2628231, Page36 of 37 Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) Ty Gee (pro hac vice pending) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10 Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 Imenninger@hmflaw.com Attorneys for Defendant Ghislaine Maxwell

Case 18-2868, Document 279, 08/09/2019, 2628231, Page37 of 37 CERTIFICATE OF SERVICE I certify that on February 10, 2017, I electronically served this Reply Brief in Support of Defendant’s Motion for Summary Judgment via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smcecawley @bsfllp.com mschultz @bsfllp.com Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad @pathtojustice.com s/ Nicole Simmons Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp @law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@ aol.com Nicole Simmons

Case 18-2868, Document 280, 08/09/2019, 2628232, Pagel of 74 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT Sigrid McCawley BOIES, SCHILLER & FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011

Case 18-2868, Document 280, 08/09/2019, 2628232, Page2 of 74 TABLE OF CONTENTS Page I. -—- PRELIMINARY STATEMENT ......-scccossscsssssssssssseessssssnnsssssnsssssnunsssnnassssnnnssseeennssee 1 Th, AUNDISPUTEIS PACTS isi oie descscctvasitind aviciieicecsloste in ceccbevtvernciniieentees 4 A. It is an Undisputed Fact That Multiple Witnesses Deposed in This Case Have Testified That Defendant Operated as Convicted Pedophile Jeffrey Epstein’s Procuter of Undetage Girls. ssccansisccsiscctemnianvinnncciecie nin nsinsnisnsteanst 4 1; It is an undisputed fact that Joanna Sjoberg testified Defendant lured her from her school to have sex with Epstein under the guise of hiring her for a job answering phones... It is an undisputed fact that Tony Figueroa testified that Defendant would call him to bring over underage girls and that Defendant and Epstein would have threesomes with Ms. Giuffie..........ccceseeeeeeeseeeeeeeee 6 It is an undisputed fact that Rinaldo Rizzo testified that Defendant took the passport of a 15-year-old Swedish girl and threatened her when she refused to have sex with Epstein. 0.00.00... ccc 8 It is an undisputed fact that Lyn Miller testified that she believed Defendant became Ms. Giuffre’s “new mama’’.......0...ccceeceeeeeeeeeeee It is an undisputed Fact that Detective Joseph Recarey testified that he sought to investigate Defendant in relation to his investigation of Jeffrey: Epstein sssiccscsisivvestvsstaszeter cote sata usauvsacssiecsscnersseaveaaviesbiniosavtecstasnaneiie 9 It is an undisputed fact that Pilot David Rodgers testified that he flew Defendant and Ms. Giuffre at least 23 times on Epstein’s jet, the “Lolita Express” and that “GM” on the flight logs Stands for Ghislaine It is an undisputed fact that Sarah Kellen, Nadia Marcinkova, and Jeffrey Epstein invoked the fifth amendment when asked about Defendant trafficking girls for Jeffery Epstein... LO It is an undisputed fact that Juan Alessi testified that Defendant was one of the people who procured some of the over 100 girls he witnessed visit Epstein, and that he had to clean Defendant’s sex toys. ...11 It is an undisputed fact that Defendant is unable to garner a single witness throughout discovery who can testify that she did not act as the procurer of underage girls and young women for Jeffrey Epstein. ........... 12

Case 18-2868, Document 280, 08/09/2019, 2628232, Page3 of 74 B. Documentary Evidence also Shows that Defendant Trafficked Ms. Giuffre and Procured her for Sex with Convicted Pedophile Jeffrey Epstein while She Was Mn ea BC ics ctssscvevensosscacevacwsvegtanve stuns sivasadcussuvesers hems sucecsescasetgnthiunnsesibitacsteoiseigatote 12 aes The Plight Lo gS: sscciccisieinin sestvicccstecssveciantennsviconievecivin tonivan cite ccccecioneneanis 12 2. The Photographs si<iiccanunncnccnacnnaninncntacnonnndanciimanaden 13 3. The Victim Identification Letter.....0..0.ccccsceseeeesessessesteseeseeseeseeeeeeeseeseenee 15 4. New York Presbyterian Hospital Records........c..cccssseseseseeeseeseeeseeeeeeeee 15 5: Judith Lightfoot Psychological Records.........ccceeseseeseseseseeseseeeeneseseeeeeee 16 6. Message Padgissssisccvisccissvsssstssssvassssetecaiseanvestsnatenitvascsustaapnvsatbaasvvestcoceuaaenvs 17 h THe Blache Boos <csccc.sctsssssswvissassasevensessisyynsttvsnsensenceacesnasvdaviasstuaasesieeeetstennt’ 22 8. Sex Slave Amazon.com Book Receipt 9. Thailand Folder with Defendant’s Phone Numbet..............:csessesseeeee 24 10. It is undisputed fact that the FBI report and the Churcher emails reference Ms. Giuffre’s accounts of sexual activity with Prince Andrew that she made in 2011, contrary to Defendant’s argument that Ms. Giuffre never made such claims until 2014. Cc. Defendant Has Produced No Documents Whatsoever That Tend to Show That She Did Not Procure Underage Girls For Jeffrey Epstein.........cceeeeeeeeeeeees 26 Ill. LEGAL STANDARD sis casassvcsssiciitsinindssvcassvesesicielstadsesseosebacvnsics daseasasessasssuaasaadsaaiinatessose 27 Iv. LEGAL ARGUMENT siiisiniesasictcrscsraneinnecininvicnianianiveniicitnninmnina niacin 27 A. Defendant is Liable for the Publication of the Defamatory Statement and Datnages for Its Publicationy..ccasissssisesenscessscsrseniiven stesciveconciamnimnnncin Hevivecnieets 27 le Under New York Law, Defendant is liable for the media’s publication of her press release. .... 2, Defendant is liable for the media’s publication of the defamatory SEALSENGIIL sis dees secs ed Sevsse cseteventas int vct edit saat tablatacchonstsd ps tensapanelececeseaterieed So B. Material Issues of Fact Preclude Summary Judgment... cesses G4 1. The Barden Declaration presents disputed issues of fact. .........0ceeeee 34

VI. VIL. VIII. Case 18-2868, Document 280, 08/09/2019, 2628232, Page4 of 74 a. The Barden Declaration is a deceptive back-door attempt to inject Barden’s advice without providing discovery of all attorney communications. db. Defendant’s summary judgment argument requires factual findings regarding Barden’s intent, thereby precluding SUMMALY JUUQIMENL: sisi ccescccrsisressvivensvicnetecirciensavivesesisecrercemeneene 35 c. There are factual disputes regarding Barden’s Declaration........... 36 Cc. Defendant’s Defamatory Statement Was Not Opinion as a Matter of Law. ......... 38 Dz. The Pre-Litigation Privilege Does Not Apply to Defendant’s Press Release....... 40 a Defendant fails to make a showing that the pre-litigation privilege applies. 2, Defendant is foreclosed from using the pre-litigation privilege because she acted with malice 3 Defendant cannot invoke the pre-litigation privilege because she has no “meritorious claim” for “good faith” litigation. «2.0.0.0... 46 DEFENDANT HAS NOT - AND CANNOT - SHOW THAT HER DEFAMATORY STATEMENT IS SUBSTANTIALLY TRUE.........cssssssssssssssssssssssssssssosssssssscsseevesssssssoses 47 PLAINTIFF DOES NOT NEED TO ESTABLISH MALICE FOR HER DEFAMATION CLAIM, BUT IN THE EVENT THE COURT RULES OTHERWISE, THERE IS MORE THAN SUFFICIENT RECORD EVIDENCE FOR A REASONABLE JURY TO DETERMINE DEFENDANT ACTED WITH PACTUAL MALICE S csssssssststicsnssscslecsussssastvsouassasissonesoavevebnatssensencetesoncaanpanieosasasessesetatayeis 49 THE COURT NEED NOT REACH THE ISSUE, AT THIS TIME, OF WHETHER MS. GIUFFRE IS A LIMITED PURPOSE PUBLIC FIGURE............ccseseeeeeeeee DL THE JANUARY 2015 STATEMENT WAS NOT “SUBSTANTIALLY TRUE,” AND MS. GIUFFRE HAS PRODUCED CLEAR AND CONVINCING EVIDENCE TUS RAMS UY 2522 cet caved caeais ss ins tee aehasvinsatssaas tases pepesavapcanaaastsacthseendaviapaatesaisasieeate viper 55 A. When Ms. Giuffre Initially Described Her Encounters With Defendant and Epstein, She Mistakenly Believed the First Encounter Occurred During the MCAT 1909 i sassssecsteeneaeaninietanes vervstonsinee a B. Defendant’s January 2015 Statement Claiming as “Untrue” and an “Obvious Lie” the Allegation That She Regularly Participated in Epstein’s Sexual Exploitation of Minors and That the Government Knows Such Fact is Not Substantially True But Instead Completely False. . iii

Ix. Case 18-2868, Document 280, 08/09/2019, 2628232, Paged of 74 Cc. Defendant’s January 2015 Statement Claiming as “Untrue” or an “Obvious Lie” That Maxwell and Epstein Converted Ms. Giuffre Into a Sexual Slave is Not Substantially True. Dz. Any Statement of Misdirection Regarding Professor Alan Dershowitz is Nothing More Than an Irrelevant Distraction to The Facts of This Case and Matters Not on the Defense of Whether Defendant’s Statement Was Substantially True ss sicscsscisrrmnnanincncnannniennetintarannnnincniananen OL E. Contrary to Defendant’s Position, There is a Genuine Issue of Material Fact as to Whether She Created or Distributed Child emhiue or Whether the Government Was Aware of Same. . oecesbes iiinensevacneevievoeigeanas OD F. Defendant Did Act as a “Madame” For Epstein to Traffic Ms. Giuffre to The RiGhi and Famous, .cvesncaciiccsvesiarvstvvnssivacitocssenteevevewvenssieesacesedeccttevssecuseseccessansssvivnn OS

Case 18-2868, Document 280, 08/09/2019, 2628232, Page6 of 74 TABLE OF AUTHORITIES Page Cases Baiul v. Disson, GOT FF Apap! 18, (Od Cie 2015) ssa cacensncvsccgnusvnteracdcevenctvoiseassinsovandusaovesvov usin sosibdesvarst asians 50 Black v. Green Harbour Homeowners’ Ass'n, Inc., 19:A;D.3d:962, 798 N.Y.S:2d 753 (2005) vsisvsssirsesissccccsnstesecveavvvenvsasesssvcvseventavivess dinsceneremanesnnse 43 Block v. First Blood Associates, 691 F. Supp. 685 (Sweet, J.) (S.D.N.Y. 1988) c.essssscsssssssssscssssssssessesessssseseeesnesseseseeee 41, 42, 43 Brady v. Town of Colchester, BOSE 20205: (Qdi Cite TOSS) acciscsassscctaectaseseseteseabenstreadesaasstatsiaatntelsiidans asadhondtanieaaniatn atest 27 Chambers v. TRM Copy Ctrs. Corp. 43 F.3d 29 (2d Cir. 1994) Contemporary Mission, Inc. v. N.Y. Times Co 842 F.2d 612 (2d Cir. 1988) Da Silva v. Time Inc., 908 F. Supp. 184 (S.D.N.Y. 1995) vacccssssssscssssssssssccssssssscscesessssseeecessnssseeseesunsseseseeusessseeseeees 47 Davis v. Costa-Gavras, 580 F. Supp. 1082 (S.D.N.Y. 1984). De Sole v. Knoedler Gallery, LLC, 139 F, Supp. 3d 618 (S.D.N.Y. 2015) ccssssssscssssssscssccsssssssesecsssssssesseussssssseseesassssseesessasessseeeeee5O Eliah v. Ucatan Corp., A533, Supp: 309: CW DN: YA977) sacsssssisssossssossacacassstssssessvssvnicqstasinesbacvasssonincciasssseCetpens 29 Flomenhaft v. Finkelstein, 127 A.D.3d 634, 8 N.Y.S.3d 161 (N.Y. App. Div. 2015) cccesssssssssssssssssessssssnsesseenssssenennseee 42 Frechtman v. Gutterman, 115 A.D.3d 102, 979 N.Y.S.2d 58: (2014). .csseccsssssscccsssssesssssscosasasoncavonsoossnsansavasssenaasonesessssansasees 42 Friedman v. Meyers, ASD B2d'435 (Od Cite L973 sas sssicanscocdassasssaesss sasasnsaxaasuabieavesssfosibaseiessua aaistoiodessspapsancsaaaviasisessnis 36 Front v. Khalil, 24.N.Y.3d 713 (2015)..

Case 18-2868, Document 280, 08/09/2019, 2628232, Page7 of 74 Gerts v. Robert Welch, In 418 U.S. 323 (1974)... Giuffre v. Maxwell, 165'F.Supp:-3d 147 (S.DIN-Y< 2016) s scccisssssesvsesteacecseesnstsconstverveseresccvonavens tessvveyavicovcenensy passim Greenberg v. CBS Inc., 69'A.Di2d:693;419 N-YS,20 988 (1979) csisnsstricinssecssverintinsrvacenstvecineneunivnnitereccecenneneanne 54 Harte-Hanks Comme'ns, Inc. v. Connaughton, 491 U.S. 657, 109 S. Ct. 2678, 105 L. Ed. 2d 562 (1989) on. ceecsscsesecsssesessessseceescseeeeneseseesenee 49 HB v. Monroe Woodbury Cent. School Dist., 2012 WL 4477552. (S:ID.NLY. Sept. 27,2012) \sccisiccsesseteastssasssssseseccnoaecsessabasesossnsdvensvoaszssserbessss 34 Herbert v. Lando, 596 F. Supp. 1178 (S.D.N.Y. 1984) c.esscsssssccsssssssssccssssssscssceesssssceecesssseseseceuaseseesscennessseeeeeee 51 Hutchinson v. Proxmire, 443 U.S. 111, 99 S. Ct. 2675, 61 L.Ed.2d 411 (1979) ..cessesessssssssessecssssssesssssssssssssseresssessessee OS In re “Agent Orange” Prod. Liab. Litig. 517 F.3d 76 (2d Cir. 2008)........... Karaduman v. Newsday, Inc., AVG INBi2d $57! (1980) ees ccsssnninissceesadinsscovsuansbnisbicdesiechobtaguavistsbarcssieartbuoeinssdbuneasciociigi GL Kirk v. Heppt, 532 F. Supp. 2d 586 (S.D.N.Y, 2008) .cssscsscssssssssssccsssssssessessssssecescessnssseeseessnseseeseeenesesecseees 42 Lerman vy. Flynt Distrib. Co., 745 F.2d 123 (2d Cir. 1984).. Levy v. Smith, 18 NLY.S 34.438 (NLY.A.D. 2 Dept. 2015) sscccissssscccsosssssssssscasssssescavosssosssssnsavasssenzanonesedsssasosooes 28 Lopez v. Univision Communications, Inc., 45 F. Supp.2d 348 (S.D.N.Y. 1999)... Mitre Sports Int’! Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240 (S.D.N.Y. 2014)....... National Puerto Rican Day Parade, Inc. v. Casa Publications, Inc., 914.N.Y.S.2d 120, 79 A.D.3d 592 (N.Y.A.D. 1 Dept. 2010) Nehls v. Hillsdale Coll., 178 F. Supp. 2d 771 (B.D. Mich. 2001) ...sssssssssssssssssssssssssessssssssssstsssssesssssssssssssssssassesseseene SL vi

Case 18-2868, Document 280, 08/09/2019, 2628232, Page8 of 74 Net Jets Aviation, Inc. vy. LHC Commce’ns, LLC, 537 F.3d 168 (2d Cir. 2008) New York Times Co. v. Sullivan, 376 U.S. 254, 84S. Ct. 710, 11 L.Ed.2d 686 (1964) oo. eecesecessesesesessesesesesecesseseeceneseseesens 50 Pacenza v. IBM Corp., 363.0, Agppix 128 (2d Cite 2010) a cacessessoscnesvinncasdvavtonevonigei volaadenctionssovsinenedtboonarnncmides 34 Patrick y. Le Fevre, TAS 2G 153: (Qi Cit VOSA) yt b0, eds ssoacerapaasesatesesaabeaareadeasaateanerrtacresamtanasadabonauanicaisireanat erie 36 Petrus v Smith, 91 AD 2d! 1190: GN LY ACD: W983) iiss. accssatssodssssensavessseniteasassedancasasencncde cata cabatedoassiasesevnazeasoesbeasedd 42 Philadelphia Newspapers, Inc. v. Hepp. 475 U.S. 767 (1986)... Rand v. New York Times Co., 430 N.Y.S.2d 271, 75 A.D.2d:417 (N.Y.A.D. 1980)......ccccsssssesssccnosesseseseassessessavenesoassssseasesones 32: Rubens vy. Mason, B87 BS! 183 (2d Cit: 2004) cs sassicasssesss cssecssstnesvsvstasanssevsssecedonnvstvsscssasassssssensseabvesissieabiendecesogionnty 35 Sexter & Warmflash, P.C. v. Margrabe, 38 A.D.3d 163 (N.Y.A.D. 1 Dept. 2007) -ssccsesssssssscsssssssssscessssssesscessnssseeseessnssseesscenesesesseeee 42 Stern v. Cosby, 645 F. Supp. 2d 258 (S.D.N.Y, 2009) vcesscssccsssssssssscssssssseesesssssssessssessssssesseussnssssessersnsesne27, 47 Swan Brewery Co. Ltd. y. U.S. Trust Co. of New Yor 832 F. Supp. 714 (S.D.N.Y. 1993) Rules Fed. R. Civ. P. 56. Other Authorities Merriam-Webster (11"" ed. 2006) RESTATEMENT (SECOND) OF TorTs § 576 (1977) .. SACK ON DEFAMATION § 2.7.2 at 2-113 to 2-114 (4th ed. 2016) vii

Case 18-2868, Document 280, 08/09/2019, 2628232, Page9 of 74 I. PRELIMINARY STATEMENT There can be no question that disputed issues of material facts preclude granting summary judgment when, in a one-count defamation case, Defendant presents the Court with a 68-page memorandum of law, a 16-page statement of purported facts, and approximately 700 pages of exhibits. The sheer scope of Defendant’s response, if anything, conclusively demonstrates that volumes of disputed facts surround the core question of whether Defendant abused Ms. Giuffre. Indeed, Defendant acknowledges a dispute between the parties as to whether she abused Ms. Giuffre. See, e.g., Motion for Summary Judgment at 1; Motion to Dismiss at 1. This Court already said that this disputed factual question is central to this case: Either Plaintiff is telling the truth about her story and Defendant’s involvement, or defendant is telling the truth and she was not involved in the trafficking and ultimate abuse of Plaintiff. The answer depends on facts. Defendant’s statements are therefore actionable as defamation. Whether they ultimately prove to meet the standards of defamation (including but not limited to falsity) is a matter for the fact-finder. Order Denying Defendant’s Motion to Dismiss at 10. While this fact remains in dispute, summary judgment is foreclosed. But even turning to Defendant’s claims, the avalanche of aspersions she casts upon Ms. Giuffre and her counsel should not distract the Court from the fact that the instant motion cannot come within sight of meeting the standard for an award of summary judgment. The most glaring and emblematic example of the Defendant’s far-fetched claims appears in her attempt to move away from her defamatory statement by arguing that it was her attorney and not her, who issued the defamatory statement for the press to publish, though she is forced to admit the statement was made on her behalf. This is an untenable position to take at trial, and an impossible argument to advance at the summary judgment stage, as both the testamentary and documentary evidence positively refute that argument. Defendant incorrectly asks this Court to make a factual

Case 18-2868, Document 280, 08/09/2019, 2628232, Page10 of 74 finding that her defamatory press release was actually a legal opinion, issued not by her, but by her lawyer, to the media, despite documentary evidence showing otherwise. Defendant also argues that she has proven the truth of her statement calling Ms. Giuffre a liar with respect to the statements Ms. Giuffre made about Defendant. To the contrary, voluminous evidence, both documentary and testimonial from numerous witnesses, corroborate Ms. Giuffre’s account of Defendant’s involvement in the sexual abuse and trafficking of Ms. Giuffre. Just to briefly highlight a few, Johanna Sjoberg, testified that Defendant recruited her under the guise of a legitimate assistant position, but asked her to perform sexual massages for Epstein, and punished her when she didn’t cause Epstein to orgasm.' Tony Figueroa testified that Defendant contacted him to recruit high school-aged girls for Epstein, and also testified that Maxwell and Epstein participated in multiple threesomes with Virginia Giuffre. Even more shockingly, the butler for Defendant’s close friend witnessed, first-hand, a fifteen-year-old Swedish girl crying and shaking because Defendant was attempting to force her to have sex with Epstein and she refused. This is a fraction of the testimony that will be elicited at trial about Defendant’s involvement in the sexual abuse and trafficking of Ms. Giuffre. Defendant’s primary argument in support of her contention that she did not abuse and traffic Ms. Giuffre as a minor child is that employment records show that Ms. Giuffre was either sixteen or seventeen when Defendant recruited her from her job at Mar-a-Lago for sex with Epstein, not fifteen-years-old as Plaintiff originally thought. Call this the “yes-I’m-a-sextrafficker-but-only-of-sixteen-year-old-girls” defense. Defendant does not explain why sexual abuse of a fifteen year old differs in any material way from sexual abuse of a sixteen or seventeen year old. All instances involve a minor child, who cannot consent, and who is 'See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr, at 8:5-10; 13:1-3; 12:17-14:3; 15:1-5; 32:9-16; 34:5-35:1; 36:2-1.

Case 18-2868, Document 280, 08/09/2019, 2628232, Page11 of 74 protected by federal and state laws. The fact remains that Defendant recruited Ms. Giuffre while she was a minor child for sexual purposes and then proceeded to take her all over the world on convicted pedophile Jeffrey Epstein’s private jet, the “Lolita Express,”” as well as to his various residences, and even to her own London house. Flight logs even reveal twenty-three flights that Defendant shared with Ms. Giuffre — although Defendant claims she is unable to remember even a single one of those flights. Inconsequential details that Ms. Giuffre may have originally remembered incorrectly do not render her substantive claims of abuse by Defendant false, much less deliberate “lies.” At most, these minor inaccuracies, in the context of a child suffering from a troubled childhood and sexual abuse, create nothing more than a fact question on whether Defendant’s statement that Ms. Giuffre lied when she accused Defendant of abuse is “substantially true,” thereby precluding summary judgment. See Mitre Sports Int’l Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240, 255 (S.D.N.Y. 2014) (“Because determining whether COI is substantially true would require this court to decide disputed facts ... summary judgment is not appropriate”). Defendant has tried to spin these inconsequential mistakes of memory into talismanic significance and evidence of some form of bad-faith litigation, but this claim fails under the weight of the evidence. As the Court knows, the clear weight of the evidence establishes Defendant’s heavy and extensive involvement in both Jeffrey Epstein’s sex trafficking ring and in recruiting Ms. Giuffre, living with her and Jeffrey Epstein in the same homes while Ms. Giuffre was a minor, and traveling with Ms. Giuffre and Jeffrey Epstein — including 23 documented flights. Even the house staff testified that Defendant and Ms. Giuffre were regularly * See, e.g.: “All aboard the ‘Lolita Express’: Flight logs reveal the many trips Bill Clinton and Alan Dershowitz took on pedophile Jeffrey Epstein’s private jet with anonymous women” at The Daily Mail, http://www.dailymail.co.uk/news/article-2922773/Newly-released-flight-logs-reveal-time-trips-Bill-ClintonHarvard-law-professor-A lan-Dershowitz-took-pedophile-Jeffrey-Epstein-s-Lolita-Express-private-jet-anonymouswomen.html.

Case 18-2868, Document 280, 08/09/2019, 2628232, Page12 of 74 together. See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 103:4-9 (“Q. After that day, do you recall that she started coming to the house more frequently. A. Yes, she did. Q. In fact, did she start coming to the house approximately three times a week? A. Yes, probably.”). It is also undisputed that witnesses deposed in this case have testified about Defendant’s role as a procurer of underage girls and young women for Jeffrey Epstein. At the very least, a trier of fact should determine whether the evidence establishes whether or not Ms. Giuffre’s claims of Defendant being involved in her trafficking and abuse are true. Defendant’s summary judgment motion should be denied in its entirety. Il. UNDISPUTED FACTS The record evidence in this case shows that Defendant shared a household with convicted pedophile Jeffrey Epstein for many years. While there, she actively took part in recruiting underage girls and young women for sex with Epstein, as well as scheduling the girls to come over, and maintaining a list of the girls and their phone numbers. Ms. Giuffre was indisputably a minor when Defendant recruited her to have sex with convicted pedophile Jeffrey Epstein. Thereafter, Ms. Giuffre flew on Epstein’s private jets — the — Lolita Express” — with Defendant at least 23 times. A. It is an Undisputed Fact That Multiple Witnesses Deposed in This Case Have Testified That Defendant Operated as Convicted Pedophile Jeffrey Epstein’s Procurer of Underage Girls. 1. It is an undisputed fact that Joanna Sjoberg testified Defendant lured her from her school to have sex with Epstein under the guise of hiring her for a job answering phones. Ms. Sjoberg’s account of her experiences with Defendant are chillingly similar. As with Ms. Giuffre, Defendant, a perfect stranger, approached Ms. Sjoberg while trolling Ms. Sjoberg’s school grounds. She lured Ms. Sjoberg into her and Epstein’s home under the guise of a legitimate job of answering phones, a pretext that lasted only a day. A young college student, 4

Case 18-2868, Document 280, 08/09/2019, 2628232, Page13 of 74 nearly 2,000 miles from home, Defendant soon instructed Ms. Sjoberg to massage Epstein, and made it clear that Sjoberg’s purpose was to bring Epstein to orgasm during these massages so that Defendant did not have to do it. Q. And when did you first meet Ms. Maxwell? A. 2001. March probably. End of February/beginning of March. Q. And how did you meet her? A. She approached me while I was on campus at Palm Beach Atlantic College. eR Q. And how long did you work in that position answering phones and doing -A. Just that one day. eR Q. And what happened that second time you came to the house? A. At that point, I met Emmy Taylor, and she took me up to Jeffrey’s bathroom and he was present. And her and I both massaged Jeffrey. She was showing me how to massage. And then she -- he took -- he got off the table, she got on the table. She took off her clothes, got on the table, and then he was showing me moves that he liked. And then I took my clothes off. They asked me to get on the table so I could feel it. Then they both massaged me. 2 Q. Who did Emmy work for? 2 A. Ghislaine. 3 Q. Did Maxwell ever refer to Emmy by any particular term? 5 A. She called her her slave. RE Q. Did Jeffrey ever tell you why he received so many massages from so many different girls? A. He explained to me that, in his opinion, he needed to have three orgasms a day. It was biological, like eating. eR Q. Was there anything you were supposed to do in order to get the camera? THE WITNESS: I did not know that there were expectations of me to get the camera until after. She [Defendant] had purchased the camera for me, and I was over there giving Jeffrey a massage. I did not know that she was in possession of the camera until later. She told me -called me after I had left and said, I have the camera for you, but you cannot receive it yet because you came here and didn’t finish your job and I had to finish it for you. Q. And did you -- what did you understand her to mean? A. She was implying that I did not get Jeffrey off, and so she had to do it. Q. And when you say “get Jeffrey off,” do you mean bring him to orgasm? A. Yes. eR Q. Based on what you knew, did Maxwell know that the type of massages Jeffrey was getting typically involved sexual acts? THE WITNESS: Yes. Q. What was Maxwell’s main job with respect to Jeffrey?

Case 18-2868, Document 280, 08/09/2019, 2628232, Page14 of 74 THE WITNESS: Well, beyond companionship, her job, as it related to me, was to find other girls that would perform massages for him and herself. Ms. Sjoberg also testified about sexual acts that occurred with her, Prince Andrew, and Ms. Giuffre, when she and Defendant were staying at Epstein’s Manhattan mansion: Q. Tell me how it came to be that there was a picture taken. THE WITNESS: I just remember someone suggesting a photo, and they told us to go get on the couch. And so Andrew and Virginia sat on the couch, and they put the puppet, the puppet on her lap. And so then I sat on Andrew’s lap, and I believe on my own volition, and they took the puppet’s hands and put it on Virginia’s breast, and so Andrew put his on mine.* Ms. Sjoberg’s testimony corroborates Ms. Giuffre’s account of how Defendant recruited her (and others) under a ruse of a legitimate job in order to bring them into the household to have sex with Epstein. Ms. Sjoberg’s testimony also corroborates Ms. Giuffre’s account of being lent out to Prince Andrew by Defendant, as even the interaction Ms. Sjoberg witnessed included a sexual act: Prince Andrew using a puppet to touch Ms. Giuffre’s breast while using a hand to touch Ms. Sjoberg’s breast. 2, It is an undisputed fact that Tony Figueroa testified that Defendant would call him to bring over underage girls and that Defendant and Epstein would have threesomes with Ms. Giuffre.” Tony Figueroa testified that Plaintiff told him about threesomes Ms. Giuffre had with Defendant and Epstein which included the use of strap-ons: Q. Okay. And tell me everything that you remember about what Ms. Roberts said about being intimate with Ms. Maxwell and Mr. Epstein at the same time. A. [remember her talking about, like, strap-ons and stuff like that. But, I mean, like I said, all the details are not really that clear. But I remember her talking about, like, how _ they would always be using and stuff like that. Q. She and Ms. Maxwell and Mr. Epstein would use strap-ons? A. Uh-huh (affirmative). ae 3 See MeCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 8:5-10; 13:1-3; 12:17-14:3; 15:1-5; 32:9-16; 34:5-35:1; 36:2-15. * See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 82:23-83:9. ° Defendant attempts to discredit Figueroa’s damaging testimony by repeatedly mentioning that he has been convicted for a drug-related offense. Unsurprisingly, in this attack, Defendant does not mention that she has a DUI conviction. See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 390:13-15. (April 22, 2016). 6

Case 18-2868, Document 280, 08/09/2019, 2628232, Page15 of 74 Q. Other than sex with the Prince, is there anyone else that Jeffrey wanted Ms. Roberts to have sex with that she relayed to you? A. Mainly, like I said, just Ms. Maxwell and all the other girls. Q. Ms. Maxwell wanted -- Jeffrey wanted Virginia to have sex with Ms. Maxwell? A. And him, yeah. Q. And did she tell you whether she had ever done that? A. Yeah. She said that she did. Bet Q. And what did she describe having happened? A. I believe I already told you that. With the strap-ons and dildos and everything.° on eeee—C™SC(‘(‘!CG Figueroa also testified that Defendant called him to ask if he had found any other girls for Epstein, thereby acting as procurer of girls for Epstein: Q. [W]hen Ghislaine Maxwell would call you during the time that you were living with Virginia, she would ask you what, specifically? A. Just if [had found any other girls just to bring to Jeffrey. Q. Okay. A. Pretty much every time there was a conversation with any of them, it was either asking Virginia where she was at, or asking her to get girls, or asking me to get girls. eR Q. Okay. Well, tell me. When did Ms. Maxwell ask you to bring a girl? A. Never in person. It was, like, literally, like, on the phone maybe, like, once or twice. Q All right. Did Ms. Maxwell call you frequently? A.No. Q. All right. How many times do you think Ms. Maxwell called you, at all? A. I'd just say that probably a just a few, a couple of times. Maybe once or twice. Q. One or two -A. The majority of the time it was pretty much his assistant. Q. How do you know Ms. Maxwell’s voice? A. Because she sounds British. Q. So someone with a British accent called you once or twice and asked for -A. Well, she told me who she was. Q. Okay. And what did she say when she called you and asked you to bring girls? A. She just said, “Hi. This is Ghislaine. Jeffrey was wondering if you had anybody that could come over.”* ® See McCawley Dec. at Exhibit 4, Figueroa June 24, 2016 Dep. Tr. Vol. 1 at 96-97 and 103. T See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 55:19-58:23 (July 22, 2016). * See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 200:6-18; 228:23-229:21. 7

Case 18-2868, Document 280, 08/09/2019, 2628232, Page16 of 74 3. It is an undisputed fact that Rinaldo Rizzo testified that Defendant took the passport of a 15-year-old Swedish girl and threatened her when she refused to have sex with Epstein. Rinaldo Rizzo was the house manager for one of Defendant’s close friends, Eva Dubin. Mr. Rizzo testified - through tears — how, while working at Dubin’s house, he observed Defendant bring a 15 year old Swedish girl to Dubin’s house. In distress, the 15 year old girl tearfully explained to him that Defendant tried to force her to have sex with Epstein through threats and stealing her passport: Q. How old was this girl? A. 15 years old. Ret Q. Describe for me what the girl looked like, including her demeanor and anything else you remember about her when she walks into the kitchen. A. Very attractive, beautiful young girl. Makeup, very put together, casual dress. But she seemed to be upset, maybe distraught, and she was shaking, and as she sat down, she sat down and sat in the stool exactly the way the girls that I mentioned to you sat at Jeffrey’s house, with no expression and with their head down. But we could tell that she was very nervous. Q. What do you mean by distraught and shaking, what do you mean by that? A. Shaking, I mean literally quivering. Bet Q. What did she say? A. She proceeds to tell my wife and I that, and this is not -- this is blurting out, not a conversation like I’m having a casual conversation. That quickly, I was on an island, I was on the island and there was Ghislaine, there was Sarah, she said they asked me for sex, I said no. And she is just rambling, and I’m like what, and she said -- I asked her, I said what? And she says yes, I was on the island, I don’t know how I got from the island to here. Last afternoon or in the afternoon I was on the island and now I’m here. And I said do you have a -- this is not making any sense to me, and I said this is nuts, do you have a passport, do you have a phone? And she says no, and she says Ghislaine took my passport. And I said what, and she says Sarah took her passport and her phone and gave it to Ghislaine Maxwell, and at that point she said that she was threatened. And I said threatened, she says yes, I was threatened by Ghislaine not to discuss this. And I’m just shocked. So the conversation, and she is just rambling on and on, again, like I said, how she got here, she doesn’t know how she got here. Again, I asked her, did you contact your parents and she says no. At that point, she says I’m not supposed to talk about this. I said, but I said: How did you get here. I don’t understand. We were totally lost for words. And she said that before she got there, she was threatened again by Jeffrey and Ghislaine not to talk about what I had mentioned earlier, about -- again, the word she used was sex. Q. And during this time that you’re saying she is rambling, is her demeanor continues to be what you described it?

Case 18-2868, Document 280, 08/09/2019, 2628232, Page17 of 74 A. Yes. Q. Was she in fear? A. Yes. Q. You could tell? A. Yes. A. She was shaking uncontrollably.” 4. It is an undisputed fact that Lyn Miller testified that she believed Defendant became Ms. Giuffre’s “new mama”. Lyn Miller is Ms. Giuffre’s mother. She testified that when Ms. Giuffre started living with Defendant, Defendant became Ms. Giuffre’s “new momma.”!° Incredulously, Defendant testified that she barely remembered Ms. Giuffre.'! 5. It is an undisputed Fact that Detective Joseph Recarey testified that he sought to investigate Defendant in relation to his investigation of Jeffrey Epstein. Detective Recarey led the Palm Beach Police’s investigation of Epstein. He testified that Defendant procured girls for Epstein, and that he sought to question her in relation to his investigation, but could not contact her due to the interference of Epstein’s lawyer: Q. A cross-reference of Jeffrey Epstein’s residence revealed which affiliated names? A. It revealed Nadia Marcinkova, Ghislane Maxwell, Mark Epstein. Also, the crossreference, any previous reports from the residence as well. Q. During your investigation, did you learn of any involvement that Nadia Marcinkova had with any of the activities you were investigating? cet Q. The other name that is on here as a cross-reference is Ghislane Maxwell. Did you speak with Ghislane Maxwell? A. I did not. Q. Did you ever attempt to speak with Ghislane Maxwell? A. I wanted to speak with everyone related to this home, including Ms. Maxwell. My contact was through Gus, Attorney Gus Fronstin, at the time, who initially had told me that he would make everyone available for an interview. And subsequent conversations later, no one was available for interview and everybody had an attorney, and I was not going to be able to speak with them. Q. Okay. During your investigation, what did you learn in terms of Ghislane Maxwell’s involvement, if any? ° See McCawley Dec. at Exhibit 14, Rinaldo Rizzo's June 10, 2016 Dep. Tr. at 52:6-7; 52:25-53:17; 55:23-58:5 ° See McCawley Dec. at Exhibit 12, Lynn Miller's May 24, 2016 Dep. Tr. at 115. "' See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 77:25-78:15 (April 22, 2016). 9

Case 18-2868, Document 280, 08/09/2019, 2628232, Page18 of 74 THE WITNESS: Ms. Maxwell, during her research, was found to be Epstein’s long-time friend. During the interviews, Ms. Maxwell was involved in seeking girls to perform massages and work at Epstein’s home.” 6. It is an undisputed fact that Pilot David Rodgers testified that he flew Defendant and Ms. Giuffre at least 23 times on Epstein’s jet, the “Lolita Express” and that “GM” on the flight logs Stands for Ghislaine Maxwell. Notably, at Defendant’s deposition, Defendant refused to admit that she flew with Ms. Giuffre, and denied that she appeared on Epstein’s pilot’s flight logs.'* However, David Rodgers, Epstein pilot, testified that the passenger listed on his flight logs bearing the initials - GM — was, in fact, Ghislaine Maxwell, and that he was the pilot on at least 23 flights in which Defendant flew with Plaintiff.'* The dates of those flights show that Ms. Giuffre was an underage child on many of them when she flew with Defendant. ° 7. It is an undisputed fact that Sarah Kellen, Nadia Marcinkova, and Jeffrey Epstein invoked the Fifth Amendment when asked about Defendant trafficking girls for Jeffery Epstein. Both Sarah Kellen and Nadia Marcinkova lived with Jeffrey Epstein for many years. They both invoked the Fifth Amendment when asked about Defendant’s participation in recruiting underage girls for sex with Epstein. Marcinkova testified as follows: Q. Did Ghislaine Maxwell work as a recruiter of young girls for Jeffrey Epstein when you met her? A. Same answer. [Invocation of Fifth Amendment] ke Q. Have you observed Ghislaine Maxwell and Jeffrey Epstein convert what started as a massage with these young girls into something sexual? A. Same answer.'® !? See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 27:10-17; 28:21-29:20. See McCawley Dec. at Exhibit 11, Maxwell’s April 22, 2016 Dep. Tr. at 78-79, 144. See McCawley Decl. at Exhibit 41, Rodgers Dep. Ex. 1, GIUFFRE 007055-007161 (flight records evidencing Defendant (GM) flying with Ms. Giuffre). 'S See McCawley Dec. at Exhibit 15, David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36; see also Exhibit 41, Rodgers Dep. Ex. | at flight #s 1433-1434, 1444-1446, 1464-1470, 1478-1480, 1490-1491, 1506, 1525-1526, 1528, 1570 and 1589. "© See McCawley Dec. at Exhibit 10, Marcinkova Dep. Tr. at 10:18-21; 10 2:11-15.

Case 18-2868, Document 280, 08/09/2019, 2628232, Page19 of 74 Kellen testified as follows: Q. Did Ghislaine Maxwell work as a recruiter for young girls for Jeffrey Epstein when you met her? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege . . . Bec Q. Isn’t it true that Ghislaine Maxwell would recruit underage girls for sex and sex acts with Jeffrey Epstein? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege . . _ Similarly, Jeffrey Epstein invoked the Fifth Amendment when asked about Defendant’s involvement in procuring underage girls for sex with him. Q. Maxwell was one of the main women whom you used to procure underage girls for sexual activities, true? THE WITNESS: Fifth. ae Q. Maxwell was a primary co-conspirator in your sexual abuse scheme, true? THE WITNESS: Fifth. Q. Maxwell was a primary co-conspirator in your sex trafficking scheme, true? THE WITNESS: Fifth. Q. Maxwell herself regularly participated in your sexual exploitation of minors, true? THE WITNESS: Fifth.'* 8. It is an undisputed fact that Juan Alessi testified that Defendant was one of the people who procured some of the over 100 girls he witnessed visit Epstein, and that he had to clean Defendant’s sex toys. Juan Alessi was Epstein’s house manager. He testified as follows: Q. And over the course of that 10-year period of time while Ms. Maxwell was at the house, do you have an approximation as to the number of different females — females that you were told were massage therapists that came to house? A. I cannot give you a number, but I would say probably over 100 in my stay there. eR Q. I don’t think I asked the right — the question that I was looking to ask, so let me go back. Did you go out looking for the girls — A. No. Q. —to bring — A. Never Q. —as the massage therapists? A. Never. Q. Who did? "” See McCawley Dec. at Exhibit 8, Kellen Dep. Tr. at 15:13-18; 20:12-16. 'S See McCawley Dec. at Exhibit 3, Epstein Dep. Tr. at 116:10-15; 117:18-118:10. 11

Case 18-2868, Document 280, 08/09/2019, 2628232, Page20 of 74 A. Ms. Maxwell, Mr. Epstein and their friends, because their friend relay to other friends they knew a massage therapist and they would send to the house. So it was referrals. bet Q. Did you have occasion to clean up after the massages? A. Yes. Q. Okay. And that is after both a massage for Jeffrey Epstein, as well as clean up after a massage that Ghislaine Maxwell may have received? A. Yes. Q. And on occasion, after -- in cleaning up after a massage of Jeffrey Epstein or Ghislaine Maxwell, did you have occasion to find vibrators or sex toys that would be left out? A. yes, I did.” 9. It is an undisputed fact that Defendant was unable to garner a single witness throughout discovery who can testify that she did not act as the procurer of underage girls and young women for Jeffrey Epstein. Defendant has not been able to procure a single witness - not one — to testify that Defendant did not procure girls for sex with Epstein or participate in the sex. Even one of her own witnesses, Tony Figueroa, testified that she both procured girls and participated in the sex. Another one of Defendant’s witnesses, Ms. Giuffre’s mother, named Defendant as Ms. Giuffre’s “new mamma.” Indeed, those who knew her well, who spent considerable time with her in Epstein’s shared household, like Juan Alessi, Alfredo Rodriguez and Joanna Sjoberg, have testified that she was Epstein’s procuress. Others who lived with her — Jeffrey Epstein, Nadia Marcinkova, and Sarah Kellen — invoked the Fifth Amendment so as not to answer questions on the same. No one has testified to the contrary. B. Documentary Evidence also Shows that Defendant Trafficked Ms. Giuffre and Procured her for Sex with Convicted Pedophile Jeffrey Epstein while She Was Underage. 1. The Flight Logs Defendant has never offered a legal explanation for what she was doing with, and why she was traveling with, a minor child on 21 flights while she was a child, including 6 international flights, aboard a convicted pedophile’s private jet all over the world. Her motion for " See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 28:6-15; 30:51-25; 52:9-22. 12

Case 18-2868, Document 280, 08/09/2019, 2628232, Page21 of 74 summary judgment — as well as all previous briefing papers — are absolutely silent on those damning documents. 2. The Photographs Throughout a mountain of briefing and, and even in her own deposition testimony, Defendant never offered an explanation regarding Ms. Giuffre’s photographs of her, Defendant, and Epstein. She never offered a legal explanation for why Prince Andrew was photographed with his hand around Ms. Giuffre’s bare waist while she was a minor child, while posing with Defendant, inside Defendant’s house in London. This particular photograph corroborates Ms. Giuffre’s claims, and there is no other reasonable explanation why an American child should be in the company of adults not her kin, in the London house owned by the girlfriend of a now: 20 convicted sex offender. Ms. Giuffre also produced pictures of herself taken when she was in New York with Defendant and Epstein, and from a trip to Europe with Defendant and Epstein:*! °” See McCawley Dec at Exhibit 42, GIUFFRE007167, Prince Andrew and Defendant Photo. *! See McCawley Dec at Exhibit 42, GIUFFRE007182 - 007166. 13

Case 18-2868, Document 280, 08/09/2019, 2628232, Page22 of 74 And, Ms. Giuffre has produced a number of pictures of herself taken at the Zorro Ranch, 22 Epstein’s New Mexico Ranch, two of which are below.” Finally, among other nude photos, which included full nudes of Defendant, Ms. Giuffre produced images of females that the Palm Beach Police confiscated during the execution of the » See McCawley Dec at Exhibit 42, GIUFFRE007175; 007173. 14

Case 18-2868, Document 280, 08/09/2019, 2628232, Page23 of 74 warrant, including one photograph revealing the bare bottom of a girl who appears to be prepubescent (Ms. Giuffre will only submit its redacted form):”° 3. The Victim Identification Letter In 2008, the United States Attorney’s office for the Southern District of Florida identified Ms. Giuffre as a protected “victim” of Jeffrey Epstein’s sex abuse. The U.S. Attorney mailed Ms. Giuffre a notice of her rights as a crime victim under the CVRA.*4 Re: Jeffrey Epstein/ ____ NOTIFICATION OF IDENTIFIED VICTIM Dear By virtue of this letter, the United States Attomey’s Office for the Southern District of Florida provides you with the following notice because you are an identified victim of a federal offense. 4, New York Presbyterian Hospital Records Ms. Giuffre has provided extensive medical records in this case, including medical records from the time when Defendant was sexually abusing and trafficking her. Ms. Giuffre produced records supporting her claim of being sexually abused in New York resulting in both * See McCawley Dec at Exhibit 44, GIUFFRE007584. 4 See McCawley Dec. at Exhibit 30, GIUFFRE 002216-002218, Victim Notification Letter. 15

Case 18-2868, Document 280, 08/09/2019, 2628232, Page24 of 74 Defendant and Epstein taking Plaintiff to New York Presbyterian Hospital in New York while she was a minor.”* The dates on the hospital records show she was seventeen years old. 5. Judith Lightfoot Psychological Records As the Court is aware, Defendant propounded wildly overbroad requests for production concerning the past eighteen years of Ms. Giuffre’s medical history. Defendant repeatedly and vehemently argued to the Court that it was essential to procure every page of these records ina fanfare of unnecessary motion practice. See, e.g., Defendant’s Motion to Compel (DE 75); Defendant’s Motion for Sanctions at 10 (“Ms. Maxwell has been severely prejudiced by Plaintiff's failure to provide the required identifying information and documents from her health care providers.”). Ms. Giuffre and her counsel took on the considerable burden and significant expense of retrieving and producing over 250 pages of medical records from over 20 providers, spanning two continents and nearly two decades. Now that those records have been collected, Defendant’s 68 page motion makes no reference to a single medical record produced by Ms. Giuffre, nor a single provider, nor a single treatment, nor or a single medication prescribed. After Defendant’s repeated motion practice stressing the essentiality of these records, this may surprise the Court. But not Ms. Giuffre. Defendant’s requests unearthed documents that are highly unfavorable to Defendant that corroborate Ms. Giuffre’s claims against her. Years before this cause of action arose, Ms. Giuffre sought counseling from a psychologist for the trauma she continued to experience after being abused by Defendant and Epstein. A 2011 psychological treatment record, written by her treating psychologist, unambiguously describes Defendant as Ms. Giuffre’s abuser: * See McCawley Dec at Exhibit 33, GIUFFRE003259-003290. 16

Case 18-2868, Document 280, 08/09/2019, 2628232, Page25 of 74 . .. [Ms. Giuffre] was approached by Ghislaine Maxwell who said she could help her get a job as a massage therapist . . . seemed respectable . . . was shown how to massage, etc., Geoff [sic] Epstein. Told to undress and perform sexual acts on person. Miss Maxwell promised her $200 a job.° Therefore, years before Defendant defamed her, Ms. Giuffre confided in her treating psychologist that Maxwell recruited her for sex with Epstein. 6. Message Pads Detective Recarey, the lead investigator of the criminal investigation into Epstein and his associates’ sex crimes, recovered carbon copies of hand-written messages taken by various staff, including Defendant, at Epstein’s Palm Beach residence.2” These were collected both from trash pulls from the residence and during the execution of the search warrant where the pads were found laying out in the open in the residence.”* The search warrant was executed in 2005 and the message pads collected include messages recorded in 2004 and 2005. Numerous witnesses have described that these copies of collected messages accurately reflect those taken by various staff at the Palm Beach Epstein mansion between 2004 and 2005.” The messages raise a question of fact as to Maxwell’s involvement in the sexual abuse of minors and are relevant to refute Maxwell’s denial of any involvement with Epstein during relevant time periods, and, accordingly her denial of knowledge of certain events. While there were hundreds of these messages recovered during the investigation, this small sample demonstrates the undeniable reality that there exists a genuine issue of material fact with respect to Defendant’s involvement in and knowledge of the activities described by Giuffre which Maxwell has said we “untrue” and “obvious lies.” °6 See McCawley Dec. at Exhibit 38, Lightfoot Records, GIUFFRE005437. 27 See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 45:13-25; 97:9-98:8. *8 See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 25:12-21; 40:5-15; 41:16-23; 42:14-43:10; 45:13-25; see also search warrant video showing the pads openly displayed on the desk. » See McCawley Dec. at Exhibit 21, 1, 16, 11, Rodriguez Dep. Tr. at 73:19-74:12; Alessi Dep. Tr. at 141:18-21; Sjoberg Dep. Tr. at 64:1-6; Maxwell Dep. Tr. at 147:23-148:3; 148:19-149:14. 17

Case 18-2868, Document 280, 08/09/2019, 2628232, Page26 of 74 This sampling reveals that Maxwell, “GM,” took messages at the residence, including from underage girls who were calling to schedule a time to come over to see Epstein. This demonstrates that Maxwell was at Epstein’s Palm Beach mansion in 2004 and 2005, incidentally a time period she has denied being around the house in her deposition. See supra GIUFFRE001412; 001435; 001449. The messages also reveal that multiple “girls” were leaving messages that were being taken and memorialized and left out in the open for anyone to see. Certain messages also make clear that a number of these “girls” were in school. In addition to taking messages herself (and the staff working under her direction taking these relevant messages), staff employees were taking and leaving messages for Defendant. This is evidence that Maxwell was in the house at relevant times, including times that she has now testified under oath that she was not there. Other messages demonstrate Epstein and Maxwell’s friends, including Jean Luc Brunel, leaving messages relating to underage females. The following is a small sampling of such messages: IMPORTANT MESSAGE IMPORTANT MESSAGE IMPORTANT MESSAGE saonidss GIUFFREO01412 (SAQ01092) GIUFFREO01427 (SAQ01456) GIUFFRE001388 (SAQ01067)

Case 18-2868, Document 280, 08/09/2019, 2628232, Page27 of 74 IMPORTANT MESSAGE SAO01461 GIUFFRE001432 (SAQ01461) IMPORTANT MESSAGE iswmesrarcal| — [esc aoae justdid a gp) 2G, yeas - ae ee eet rere | GIUFFREO01426 (SA001455) IMPORTANT MESSAGE GIUFFREO01448 (SAQ01476) IMPORTANT MESSAGE aihles ROR = » fbn = aero ——[ rneco [ou 0 wero = [emeranou| —fexeu aiaaoe ote has a feather “Por you to teach you tot! to speak Vus@ian Ser 7s Zu F Yeors eked | sedel GIUFFREO01423 (SA001452) a framrenso _X[mracecar fees eras cyl fc a Trim Beach Yeeosy te skeuy | Secs nn Inulp hee ne ShoGE voit Cabostescye — sao GIUFFREO01454 (SA002830)

Case 18-2868, Document 280, 08/09/2019, 2628232, Page28 of 74 The following are descriptions of a sampling of messages pads*” that create a genuine dispute of material fact: One message pad reflects a who is identified in the Palm Beach Police Report as a minor, contacting Jeffrey Epstein for “work” explaining that she does not have any money. The term “work” was often used by members of Jeffrey Epstein’s sexual trafficking ring to refer to sexual massages. (See GIUFFRE05660 (“She stated she was called by Sara for her to return to work for Epstein stated ‘work’ is the term used by Sarah to provide the massage in underwear.”). Giuffre 001462: July 5th no year to JE from am) ”T need work. I mean I don’t have money. Do you have some work for me?” Other message pads reflect J who was a minor, calling and leaving a message at the Palm Beach mansion that she has recruited another girl for Jeffrey Epstein. The second message demonstrates that Jeffrey Epstein required different girls to be scheduled every day of the week. The third shows an offer to have two minor girls come to the home at the same time to provide sexual massages. These type of messages indicate the lack of secrecy of the fact that multiple young females were visiting every day and at least raises a question of fact whether Maxwell was knowledgeable and involved as Giuffre has said, or whether Giuffre was lying and Maxwell was not at all involved or aware of this activity, as Defendant would attempt to have the world believe. Giuffre 001428 — undated Jeffrey From - “Has girl for toni ht” ;Giuffre 001432 (pictured above)— 7/9/04 — Mr. Epstein From is available on Tuesday no one for tomorrow”; GIUFFRE 001433 TTT04 = Mr. Epstein from — “Me and can come tomorrow any time or FBalone” ; ; Giuffre — 001452 — undated Jeffrey from “Has girl for tonight.” Other message pads demonstrate that there was a pattern and practice of using young females to recruit additional young females to provide sexual massages on a daily basis. Giuffre 001413 (pictured above)— JE from “N” — ‘ hasn’t confirmed for 11:00 yet, so she is keeping on hold in case doesn’t call back; Giuffre 001448 -8/20/05 JE from - confirmed _ at 4 pm. Who is scheduled for morning? I believe wants to work.” This message pad reflects that a friend of Jeffrey Epstein is sending him a sixteen year old Russian girl for purposes of sex. Giuffre 001563 (pictured above)- 6/1/05 For Jeffrey From Jean Luc “He has a teacher for you to teach you how to speak Russian. She is 2X8 years old not blonde. Lessons are free and you can have your 1st today if you call.” This message pad directly refutes Maxwell’s sworn testimony that she was not present during the year 2005 at Jeffrey Epstein’s Palm Beach mansion because this shows leaving a message for Jeffrey at the Palm Beach home that she was going to work out *” See McCawley Dec. at Exhibit 28. 20

Case 18-2868, Document 280, 08/09/2019, 2628232, Page29 of 74 with the Defendant on September 10, 2005. The police were only able to retrieve a fraction of these message pads during their trash pull but even in the few they recovered, it shows Maxwell was regularly at the Palm Beach home during the time period she claimed she was not. To the contrary, she was both sending and receiving messages and messages, like this one, reflect her presence at the mansion. Giuffre 001412 — 9/10/05 (during the year Maxwell says she was never around) JE from — “I went to Sarah and made her water bottle and I went to work out with GM.” These message pads further corroborate that Defendant lied in her testimony and she was in fact in regular contact with Jeffrey Epstein during the years 2004 and 2005. For example, the message from “Larry” demonstrates that Defendant is at the Palm Beach mansion so frequently that people, including Epstein’s main pilot Larry Visoski, are leaving messages for Maxwell at the Palm Beach house. Giuffre 001435 7/25/04 — Mr. Epstein from Ms. Maxwell — “tell him to call me”; Giuffre — 001449 — 8/22/05 — JE from GM; Giuffre — 001453 — 4/25/04 for Ms. Maxwell From Larry “returning your call”; This message pad shows that Defendant was clearly actively involved in Jeffrey Epstein’s life and the activities at his Palm Beach mansion. Giuffre — 001454 — undated Jeffrey From Ghislaine — “Would be helpful to have come to Palm Beach today to stay here and help train new staff with Ghislaine.” This message pad clearly reflects an underage female (noted by the police redaction of the name) leaving a message asking if she can come to the house at a later time because she needs to “stay in school.” Giuffre 001417 (pictured above)— Jeffrey 2/28/05 Redacted name “She is wondering if 2:30 is o.k. She needs to stay in school.” This message pad reflects a message from who was under the age of eighteen at the time she was going over to Jeffrey Epstein’s home to provide sexual massages according to the Palm Beach Investigative Report. Giuffre 001421 3/4/05 to Jeffrey from “Tt is o.k. for to stop by and drop something?” These message pads reflect the pattern of underage girls (noted by the police redaction of the name on the message pad) calling the Palm Beach mansion to leave a message about sending a “female” over to provide a sexual massage. Giuffre 001423 11/08/04 To Mr. JE — redacted from — “I have a female for him” Giuffre 001426 (pictured above) — 1/09/05 JE To JE from Redacted — “I have a female for him.” This message pad reflects the pattern and practice of having young girls bring other young girls to the house to perform sexual massages. Indeed the = reflected in this message pad corresponds in name to the a” that Tony Figueroa testified he initially brought to Jeffrey Epstein during the time period that the Defendant was requesting that Tony find some young females to bring to Jeffrey Epstein’s home. See Figueroa at 184185. The Palm Beach Police Report reflects that ; | hl and ; ff also brought seventeen year old to the home to perform sexual massages. See GIUFFRE 05641. =i thereafter recruited a number of other young girls to perform sexual 21

Case 18-2868, Document 280, 08/09/2019, 2628232, Page30 of 74 massages as reflected in the Palm Beach Police Report. Giuffre 001427 (pictured above) — 1/2/03 — JE from =a “Wants to know if she should bring her friend Ea with tonight.” e This message pad reflects multiple sexual massages being scheduled for the same day which corroborates Virginia GIUFFRE, a: Johanna Sjorberg’s testimony that Jeffrey Epstein required that he have multiple orgasms in a day which occurred during these sexual massages. Giuffre 001449 (pictured above) — 9/03/05 JE from —“T left message for i to confirm for 11:00 a.m. and fy for 4:30 p.m.” e This message pad shows a friend of Jeffrey Epstein’s discussing with him how he had sex with an 18 year old who had also been with Jeffrey Epstein. Giuffre — 001456 (pictured above)— undated JE from Jean Luc — “He just did a good one — 18 years — she spoke to me and said “I love Jeffrey.” Law enforcement was able to confirm identities of underage victims through the use of the names and telephone numbers in these message pads: Q. The next line down is what I wanted to focus on, April 5th, 2005. This trash pull, what evidence is yielded from this particular trash pull? THE WITNESS: The trash pull indicated that there were several messages with written items on it. There was a message from HR indicating that there would be an 11:00 appointment. There were other individuals that had called during that day. Q. And when you would -- when you would see females’ names and telephone numbers, would you take those telephone numbers and match it to -- to a person? THE WITNESS: We would do our best to identify who that person was. Q. And is that one way in which you discovered the identities of some of the other what soon came to be known as victims? THE WITNESS: Correct. Bet Q. Did you find names of other witnesses and people that you knew to have been associated with the house in those message pads? THE WITNESS: Yes. Q. And so what was the evidentiary value to you of the message pads collected from Jeffrey Epstein’s home in the search warrant? THE WITNESS: It was very important to corroborate what the victims had already told me as to calling in and for work.*! is The Black Book Palm Beach Police confiscated an extensive lists of contacts with their phone numbers form Defendant and Epstein’s residence.*” Ghislaine Maxwell maintained a contact list in an *! See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 42:14-43:17; 78:25:-79:15. 22

Case 18-2868, Document 280, 08/09/2019, 2628232, Page31 of 74 approximately 100-page-long hard copy, which was openly available to other house employees. It consisted primarily of telephone numbers, addresses, or email addresses for various personal friends, associates, employees, or personal or business connections of Epstein or Defendant. Prior to being terminated by Defendant, the Palm Beach house butler Alfredo Rodriguez printed a copy of this document and ultimately provided it to the FBI. This document reflects the numerous phone numbers of Defendant, Epstein as well as staff phone numbers. Additionally, and importantly, there are several sections entitled “Massage” alongside a geographical designation with names of females and corresponding telephone numbers. These numbers included those of underage females (with no training in massage therapy ) — including fF identified during the criminal investigation of Epstein. This document is an authentic reflection of the people who were associated with Epstein, Defendant, and the management of their properties, and the knowledge each had of the contents of the document. 8. Sex Slave Amazon.com Book Receipt Detective Recarey authenticated an Amazon.com receipt that the Palm Beach Police collected from Jeffrey Epstein’s trash. The books he ordered are titled: (1) SM 101: A Realistic Introduction, Wiseman, Jay; (2) SlaveCraft: Roadmaps for Erotic Servitude — Principles, Skills and Tools by Guy Baldwin; and (3) Training with Miss Abernathy: A Workbook for Erotic Slaves and Their Owners, by Christina Abernathy, as shown below: *® See McCawley Dec. at Exhibit 45, Phone List, Public Records Request No.: 16-268 at 2282 — 2288. 23

Case 18-2868, Document 280, 08/09/2019, 2628232, Page32 of 74 i This disturbing 2005 purchase corroborate Ms. Giuffre’s account of being sexually exploited by Defendant and Epstein — not to mention the dozens of underage girls in the Palm Beach Police Report. Additionally, Defendant testified that she was not with Jeffrey Epstein in 2005 and 2006 when he was ordering books on how to use sex slaves; however, record evidence contradicts that testimony. 9. Thailand Folder with Defendant’s Phone Number Defendant also was integral in arranging to have Virginia go to Thailand. While Epstein had paid for a massage therapy session in Thailand, there was a catch. Defendant told Virginia she had to meet young girls in Thailand and bring her back to the U.S. for Epstein and Defendant. Indeed, on the travel records and tickets Defendant gave to Virginia, Defendant wrote on the back the name of the girl Virginia was supposed to meet, and she was also instructed to check in frequently with Defendant as it was further signified by the words “Call Ms. Maxwell O) i”: on Virginia’s travel documents. In this case, Virginia also produced the hard copy records from her hotel stay in Thailand paid for by Epstein. See McCawley Dec. at Exhibit 32, 43, GIUFFRE 003191-003192; GIUFFRE 00741 1-007432. 24

Case 18-2868, Document 280, 08/09/2019, 2628232, Page33 of 74 10. It is undisputed fact that the FBI report and the Churcher emails reference Ms. Giuffre’s accounts of sexual activity with Prince Andrew that she made in 2011, contrary to Defendant’s argument that Ms. Giuffre never made such claims until 2014. Based on the FBI’s Interview of Ms. Giuffre in 2011, they wrote a report reflecting Ms. Giuffre’s claims concerning her sexual encounters with Prince Andrew:*? GIUEFRE anal kent shopping and purchased makeup, clothing, and a Sepparcy nag, The Tpeme were purchased with JcrureRe, ani jreturnedf instructed GIUFFRE to get ready. When GIUFFRE came down after gettin ready, she was introduced tof GIGETRE traveled to coos Taw Taree danced Jat CLUB TRAMP Tayed at CLUB TRANP Tor an hour or hour and a half and drank @ couple of cocktails before returning GIUFERE had not received any direction tron [ ‘After returning toL GivFFRE Taquested fo Take a photograph of hey TUPERE advised that she still had the original photograph in her possession and would provide it to the interviewing agents. GIUVEFRE proceeded with| Approximately two months later, GIUFFRE net Jac [siorrRe cecaiea] JarorenE recatied oking about trading GIUFFRE In because Tie was getting too old 3 See McCawley Dec. at Exhibit 31, GIUFFRE001235-1246, FBI Redacted 302. 25

Case 18-2868, Document 280, 08/09/2019, 2628232, Page34 of 74 Additionally, 2011 correspondence with Sharon Churcher shows that Ms. Giuffre disclosed her sexual encounters with Prince Andrew, but Churcher had to check with the publisher’s lawyers “on how much can be published,” -----Original Message----From: Sharon.Churcher@mailonsunday.co.uk Sent: Friday, 18 February 2011 7:25 AM To: Virginia Giuffre Hi there Have been up all night writing. Won't have an opinion from our lawyer on how much can be published until London wakes up. The lawyers wanted internal FBI documents but | think the Justice Dept letter is all you have from the feds??? Anyway can | give you a call early afternoon? Maybe have a late lunch? Ss See McCawley Dec. at Exhibit 34, GIUFFRE003678. Accordingly, there is documentary evidence that refutes Defendant’s meritless argument that Ms. Giuffre did not allege she had sex with Prince Andrew until 2014. To the contrary, two sources, including the FBI, show Ms. Giuffre made these claims in 2011. Cc. Defendant Has Produced No Documents Whatsoever That Tend to Show That She Did Not Procure Underage Girls For Jeffrey Epstein. Defendant has produced no documents that even tend to show that she did not procure underage girls for sex with Epstein, and no documents that tend to show that she did not participate in the abuse. Indeed, Defendant refused to produce any documents dated prior to 2009, which includes the 2000-2002 period during which she abused Ms. Giuffre. Against this backdrop of an avalanche of evidence showing the Defendant sexually trafficked Ms. Giuffre, summary judgment on any of the issues advanced by Defen dant is inappropriate. While we discuss the particulars of the individual claims below, the larger picture is important too. Ms. Giuffre will prove at trial that Epstein and Defendant sexually trafficked her. And yet, when Ms. Giuffre had the courage to come forward and expose what Defendant had done to world — in a Court pleading trying to hold Epstein accountable — Defendant 26

Case 18-2868, Document 280, 08/09/2019, 2628232, Page35 of 74 responded by calling her a liar in a press release intended for worldwide publication. Such heinous conduct is not a mere “opinion,” but rather is defamation executed deliberately and with actual malice. The jury should hear all of the evidence and then render its verdict on Ms. Giuffre’s complaint. Ill. LEGAL STANDARD Rule 56 of the Federal Rules of Civil Procedure provides that a motion for summary judgment may be granted only when “there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” The Second Circuit has repeatedly held that “all ambiguities and inferences to be drawn from the underlying facts should be resolved in favor of the party opposing the motion, and all doubts as to the existence of a genuine issue for trial should be resolved against the moving party.” Swan Brewery Co. Ltd. v. U.S. Trust Co. of New York, 832 F. Supp. 714, 717 (S.D.N.Y. 1993) (Sweet, J.), citing Brady v. Town of Colchester, 863 F.2d 205, 210 (2d Cir. 1988) (internal quotations omitted). In other words, in deciding a motion for summary judgment, the court must construe the evidence in the light most favorable to the non-moving party and draw all reasonable inferences in the non-moving party’s favor. In re “Agent Orange” Prod. Liab. Litig., 517 F.3d 76, 87 (2d Cir. 2008). Stern v. Cosby, 645 F. Supp. 2d 258, 269 (S.D.N.Y.2009). Summary judgment should be denied “if the evidence is such that a reasonable jury could return a verdict” in favor of the non-moving party. See Net Jets Aviation, Inc. v. LHC Commc’ns, LLC, 537 F.3d 168, 178-79 (2d Cir. 2008). IV. LEGAL ARGUMENT A. Defendant is Liable for the Publication of the Defamatory Statement and Damages for Its Publication Defendant’s lead argument is that, when she issued a press release attacking Ms. Giuffre to members of the media, she somehow is not responsible when the media quickly published her 27

Case 18-2868, Document 280, 08/09/2019, 2628232, Page36 of 74 attacks. If accepted, this remarkable claim would eviscerate defamation law, as it would permit a defamer to send defamatory statements to the media and then stand back and watch — immune from liability — when (as in this case) the defamatory statements are published around the world. This absurd position is not the law, particularly given that the Defendant released a statement to media asking them to “[p]lease find attached a quotable statement on behalf of Ms. Maxwell.” To make her claim seem plausible, Defendant cites older cases, some dating back as far as 1906. This presents a distorted picture of the case law on these issues. As a leading authority on defamation explains with regard to liability for republication by another of statement by a defendant: “Two standards have evolved. The older one is that the person making the defamatory statement is liable for republication only if it occurs with his or her express or implied authorization of consent. The more modern formulation adds responsibility for all republication that can reasonably be anticipated or that is the ‘natural and probable consequence’ of the publication.” SACK ON DEFAMATION § 2.7.2 at 2-113 to 2-114 (4th ed. 2016). In this case, however, the nuances of the applicable legal standards make little difference because Defendant so clearly authorized — indeed, desired and did everything possible to obtain — publication of her defamatory statements attacking Ms. Giuffre. 1. Under New York Law, Defendant is liable for the media’s publication of her press release. Given the obvious purposes of defamation law, New York law unsurprisingly assigns liability to individuals for the media’s publication of press releases. Indeed, New York appellate courts have repeatedly held that an individual is liable for the media publishing that individual’s defamatory press release. See Levy v. Smith, 18 N.Y.S.3d 438, 439, 132 A.D.3sd 961, 962-63 (N.Y.A.D. 2 Dept. 2015) (Generally, [o]ne who makes a defamatory statement is not responsible for its recommunication without his authority or request by another over whom he 28

Case 18-2868, Document 280, 08/09/2019, 2628232, Page37 of 74 has no control . . . Here, however . . . the appellant intended and authorized the republication of the allegedly defamatory content of the press releases in the news articles”); National Puerto Rican Day Parade, Inc. v. Casa Publications, Inc., 914 N.Y.S.2d 120, 123, 79 A.D.3d 592, 595 (N.Y.A.D. 1 Dept. 2010) (affirming the refusal to dismiss defamation counts against a defendant who “submitted an open letter that was published in [a] newspaper, and that [the defendant] paid to have the open letter published,” and finding that the defendant “authorized [the newspaper] to recommunicate his statements.”) See also RESTATEMENT (SECOND) OF TORTS § 576 (1977) (“The publication of a libel or slander is a legal cause of any special harm resulting from its repetition by a third person if. . . the repetition was authorized or intended by the original defamer, or . . . the repetition was reasonably to be expected.”)** Defendant deliberately sent her defamatory statement to major news media publishers for worldwide circulation because Defendant wanted the public at large to believe that Ms. Giuffre was lying about her abuse. Defendant even hired a public relations media specialist to ensure the media would publish her statement. Her efforts succeeded: her public relations agent instructed dozens of media outlets to publish her “quotable” defamatory statement and they did. Despite this deliberate campaign to widely publicize her defamatory statement, Defendant now disclaims any responsibility for the media publishing her press release. If we understand Defendant’s position correctly, because she somehow lacked “control” over what major newspapers and other media finally put in their stories, she escapes liability for defamation. This nonsensical position would let a defamer send a false and defamatory letter to major media, and then, when they published the accusation, escape any liability. Such an MCf, Eliah v. Ucatan Corp., 433 F. Supp. 309, 312-13 (W.D.N.Y. 1977) (“The alleged multistate publication of plaintiff's photograph without her consent thus gives rise to a single cause of action. ... However, evidence of the multistate publication of the magazine and the number of copies sold would be competent and pertinent to a showing of damages, if any, suffered by plaintiff.”) 29

Case 18-2868, Document 280, 08/09/2019, 2628232, Page38 of 74 argument is not only an affront to logic, but it is contrary to prevailing New York case law, cited above. Perhaps even more important, in the context of the pending summary judgment motion, it would require Defendant to convince the jury that she did not “authorize or intend” for the major media to publish her press release. Obviously the disputed facts on this point are legion, and summary judgment is accordingly inappropriate. Even the cases Defendant cites contradict her argument. She first cites Geraci v. Probst, in which a defendant sent a letter to the Board of Fire Commissioners, and, years later, a newspaper published the letter. The court held that the defendant was not liable for that belated publication, “made years later without his knowledge or participation.” /d., at 340. By contrast, Defendant not only authorized the defamatory statement, but paid money to her publicist to convince media outlets to publish it promptly — actions taken with both her knowledge and consent. Defendant’s statement was thus not published “without [her] authority or request,” as in Geraci, but by her express authority and by her express request. Defendant’s publicist’s testimony and the documents produced by Defendant’s publicist unambiguously establish that the media published her press release with Defendant’s authority and by her request: Q. When you sent that email were you acting pursuant to Ms. Maxwell’s retention of your services? A. Yes, I was ae Q. The subject line does have “FW” which to me indicates it’s a forward. Do you know where the rest of this email chain is? A. My understanding of this is: It was a holiday in the UK, but Mr. Barden was not necessarily accessible at some point in time, so this had been sent to him originally by Ms. Maxwell, and because he was unavailable, she forwarded it to me for immediate action. I therefore respond, “Okay, Ghislaine, I'll go with this.” It is my understanding that this is the agreed statement because the subject of the second one is “Urgent, this is the statement” so J take that as an instruction to send it out, as a positive command: “This is the statement.”*° * See McCawley Dec. at Exhibit 6, Ross Gow Dep. Tr. at 14:15-17; 44:6-45:13 (emphasis added). 30

Case 18-2868, Document 280, 08/09/2019, 2628232, Page39 of 74 Similarly, another case cited by Defendant, Davis v. Costa-Gavras, involved a libel claim against a book author who wrote an account of the 1972 military coup in Chile. Years later, the plaintiff attempted to ascribe defamation liability to a third-party publishing house’s decision to republish the book in paperback form and a third-party filmmaker who released a movie based on the book. The Court held that a “party who is ‘innocent of all complicity’ in the publication of a libel cannot be held accountable . . . [but that] a deliberate decision to republish or active participation in implementing the republication resurrects the liability.” 580 F. Supp. 1082, 1094 (S.D.N.Y. 1984). Here, Defendant made a deliberate decision to publish her press release, and actively participated in that process. At the very least, the jury must make a determination of whether Defendant was “innocent of all complicity” for a libelous statement contained in her press release. Finally, Defendant cites Karaduman v. Newsday, Inc., 416 N.E.2d 557 (1980), which held that reporters of a series of articles on narcotics trade “cannot be held personally liable for injuries arising from its subsequent republication in book form absent a showing that they approved or participated in some other manner in the activities of the third-party republisher.” Id., 416 N.E.2d at 559-560. Again, the jury could reasonably find that Defendant both approved of, and even participated in, the media’s publication of her press release. Indeed, it is hard to understand how any jury could find anything else. Defendant was obviously “active” in influencing the media to publish her defamatory press release, she both “approved” of and pushed for the publication of the press release. Accordingly, she is liable for its publication.*° *° On page 14 of her motion, Defendant makes wholly contradictory statements. In back-to-back sentences, she tells the Court that (1) she has no control over whether the media published the statement she sent to the media (with instructions to publish it by an influential publicist); (2) her public relations representative gave instructions to the media on how to publish it (in full); and (3) her public relations representative “made no effort to control” how the media would publish it. Indeed, the best evidence of Defendant’s control over the press is the fact dozens of media outlets obeyed her directive to publish her defamatory statement. 31

Case 18-2868, Document 280, 08/09/2019, 2628232, Page40 of 74 Therefore, disclaiming responsibility for the media’s publication of a statement (for which she hired a publicist for the purpose of influencing the media to publish that statement) is contrary to both prevailing case law, and the cases cited by Defendant. 2. Defendant is liable for the media’s publication of the defamatory statement. After arguing, contrary to New York law, that she is not liable for the media’s publication of her own press release, Defendant next argues that she is not liable for the media’s publications of the defamatory statement contained within her press release if the media chose to make even the tiniest of editorial changes. If we understand Defendant’s argument correctly, any omission of any language from a press release is somehow a “selective, partial” publication for which she escapes liability. Mot. at 14. Once again, this claim is absurd on its face. It would mean that a defamer could send to the media a long attack on a victim with one irrelevant sentence and, when the media quite predictably cut that sentence, escape liability for the attack. Moreover, even on its face, the claim presents a jury question of what changes would be, in context, viewed as “selective” or “partial” publications — something that only a jury could determine after hearing all of the evidence. In support of this meritless argument, Defendant cites Rand v. New York Times Co., for the proposition that a defendant cannot be liable for a publisher’s “editing and excerpting of her statement.” 430 N.Y.S.2d 271, 274, 75 A.D.2d 417, 422 (N.Y.A.D. 1980). This argument fails for several reasons. First, there is no “republication” by the media as a matter of law. Defendant issued a defamatory statement to the press, and its publication (as Defendant intended) is not a “republication” under the law, as discussed above. Second, there was no “editing” or paraphrasing or taking the quote out of context of the core defamatory statement in the press release: that Ms. Giuffre is a liar. The “obvious lies” passage is the heart of the message 32

Case 18-2868, Document 280, 08/09/2019, 2628232, Page41 of 74 Defendant sent to the press: that Ms. Giuffre was lying about her past sexual abuse. Even in isolation, Defendant’s quote stating that Ms. Giuffre’s claims are “obvious lies” does not distort or misrepresent the message Defendant intended to convey to the public that Ms. Giuffre was lying about her claims. As this Court explained in denying Defendant’s Motion to Dismiss, this case “involves statements that explicitly claim the sexual assault allegations are false.” Giuffire v. Maxwell, 165 F. Supp. 3d 147, 152 (S.D.N.Y. 2016). Furthermore, the facts at issue here make the Rand holding inapposite. In Rand, a newspaper paraphrased and “sanitized” defendant’s words. No such changing, sanitizing, or paraphrasing occurred in the instant case: the media quoted Defendant’s statement accurately. Further, the phrase at issue in Rand was that certain people “screwed” another person. The speaker/newspaper used the term “screwed” in reference to a record label’s dealings with a performing artist, and not did not mean “screwed” in the literal sense, but as “rhetorical hyperbole, and as such, is not to be taken literally.” Jd. By contrast, there is no hyperbole in Defendant’s defamatory statement, and it was never distorted or paraphrased by any publication known to Ms. Giuffre. A jury could reasonable conclude that Defendant’s statement that Ms. Giuffre’s claims of child sexual abuse are “obvious lies” is not a rhetorical device, nor hyperbole, but a literal and particular affirmation that Ms. Giuffre lied. Accordingly, there is no support in the factual record that the media reporting that Defendant stated that Ms. Giuffre’s claims of childhood sexual abuse are “obvious lies” is a distortion of Defendant’s message or hyperbole. Even a cursory review of the press release would lead to that conclusion. Moreover, to the extent that there is any dispute that Defendant’s statement had a different meaning outside of the context of the remainder of the press release, 33

Case 18-2868, Document 280, 08/09/2019, 2628232, Page42 of 74 such a determination of meaning and interpretation is a question of fact for the jury to decide, and is inappropriate for a determination upon summary judgment. B. Material Issues of Fact Preclude Summary Judgment. 1. The Barden Declaration presents disputed issues of fact. The primary basis of Defendant’s motion for summary judgment is her attorney’s selfserving, post hoc affidavit wherein he sets forth his alleged “intent” with regard Defendant’s defamatory statement.*” Ms. Giuffre disputes Defendant’s attorney’s alleged and unproven “intent” (not to mention Defendant’s “intent”), not only because Defendant refuses to turn over her attorney’s communications, but also because questions of intent are questions of fact to be determined by a trier of fact. Furthermore, ample record evidence contradicts the claimed “intent.” a. The Barden Declaration is a deceptive back-door attempt to inject Barden’s advice without providing discovery of all attorney communications. In her brief, Defendant discloses her attorney’s alleged legal strategy and alleged legal advice; however, she deliberately states that her attorney “intended,” instead of her attorney “advised,” when discussing her attorney’s legal strategy and advice, using that phrase at least 37 9939 ce, 1740 ce, ol times,** and using phrases such as Barden’s “beliefs, purposes, ‘goals,””” and >” The Barden declaration is problematic for other reasons as well. In addition to Defendant’s over-length, 68-page motion and among Defendant’s 654 pages of exhibits lies an eight-page attorney affidavit that proffers legal conclusions and arguments. This exhibit is yet another improper attempt to circumvent this Court’s rules on page limits. See Pacenza v. IBM Corp., 363 F. App'x 128, 130 (2d Cir. 2010) (affirming lower court decision to strike “documents submitted . . . in support of his summary judgment motion [that] included legal conclusions and arguments” because those “extraneous arguments constituted an attempt . . . to circumvent page-limit requirements submitted to the court.”); cf, HB v. Monroe Woodbury Cent. School Dist., 2012 WL 4477552, at *6 (S.D.N.Y. Sept. 27, 2012) (“The device of incorporating an affirmation into a brief by reference, as Plaintiffs have done here, in order to evade the twenty-five page limit, rather obviously defeats the purpose of the rule”). The court should disregard the Barden Declaration for that reason alone 38 MSI at 7 (three times), 8 (three), 15 (four), 16, 25 (five), 26, 33, 35 (two), 36 (three); Statement of Facts at 6 (two), 7 (five); Decl. of Philip Barden at 4 (four), 5 (three). °° MSJ at 25, 35; Statement of Facts at 7 (two); Decl. of Philip Barden at 3, 4 (three), 5 (two). 4° MSJ at 8, 25, 35; Statement of Facts at 7 (three); Decl. of Philip Barden at 4 (two), 5 (three). 34

Case 18-2868, Document 280, 08/09/2019, 2628232, Page43 of 74 “contemplations” 25 other times. All the while Defendant has claimed a privilege as to her communications with Barden. Defendant attempts to convince the Court that she only granted Gow permission to publish the defamatory statement as part of “Mr. Barden’s deliberated and carefully crafted” (MSJ at 16) legal strategy and advice. Yet, she still refused to turn over her communications with Barden under the auspices of attorney-client privilege.” Such gamesmanship should not be permitted. If the Court were to consider the Barden Declaration (which it shouldn’t), it would be ruling on a less than complete record because, based on this Declaration, it is necessary that Defendant disclose all communications with him and possibly others. Ms. Giuffre doesn’t have those communications, the court doesn’t have those communications; therefore, Defendant is asking for summary judgment on an incomplete record. The Court should also not consider the Barden Declaration because it will be inadmissible as unduly prejudicial. It is a self-serving declaration by a non-deposed witness made without turning over the documents that are relevant to the declaration. See, e.g., Rubens v. Mason, 387 F.3d 183, 185 (2d Cir. 2004) (“We find that the District Court predicated its grant of summary judgment as to liability on an affidavit from the arbitrator who presided over the underlying arbitration, the probative value of which was substantially outweighed by the danger of unfair prejudice. The affidavit, therefore should not have been admitted. We therefore vacate the grant of summary judgment to the defendants on liability and remand to the District Court.”). b. Defendant’s summary judgment argument requires factual findings regarding Barden’s intent, thereby precluding summary judgment. Even were the Court to consider this Declaration and representations therein — which it should not — the declaration itself demonstrates that the Court would have to make factual 4 MSJ at 27. ® See McCawley Dec. at Exhibit 22, Defendant’s Privilege Log. 35

Case 18-2868, Document 280, 08/09/2019, 2628232, Page44 of 74 finding as to what Mr. Barden’s intent really was. Finding about intent are inappropriate at the summary judgment stage, as this Court and the Second Circuit have recognized. This Court has explained, “if it is necessary to resolve inferences regarding intent, summary judgment is not appropriate.” Id. (Sweet, J.) (emphasis added), citing Patrick v. Le Fevre, 745 F.2d 153, 159 (2d Cir. 1984); Friedman v. Meyers, 482 F.2d 435, 439 (2d Cir. 1973) (other citations omitted). G. There are factual disputes regarding Barden’s Declaration. Finally, there are material disputes over the statements in the Barden Declaration because they are directly refuted by record evidence. For example, the instant motion and the Barden Declaration describe the press release merely as a document expressing “his [Mr. Bardent’s] opinion — in the form of a legal argument —as a lawyer would be,” as opposed to a press release for dissemination by the media to the public. Record evidence refutes this claim, as (1) the press release was sent to journalists, not media publishers or in-house counsel; (2) the press release instructed the journalists to publish the defamatory statement (“Please find attached a quotable statement on behalf of Ms. Maxwell”); (3) it was issued by a publicist on Defendant’s behalf and not by an attorney, without any reference to attorneys or laws — indeed, Gow testified that Barden was unavailable to approve the statement; and (4) Gow testified that he issued the statement only after he understood Defendant to have “signed off” it, an understanding he formed based on Defendant's “positive command” to him: “This is the agreed statement.” Q. When you sent that email were you acting pursuant to Ms. Maxwell’s retention of your services? A. Yes, I was. eR Q. When you say “agreed statement” can you tell me more about what you mean? Who agreed to the statement? A. Ineed to give you some context, if I may, about that statement. So, this is on New Year’s Day. I was in France so the email time here of 21:46, in French time was 22:46, and I was getting up early the next morning to drive my family back from the south of France to England, which is a 14-hour journey, door to door. So on the morning of th® 2nd of January, 36

Case 18-2868, Document 280, 08/09/2019, 2628232, Page45 of 74 bearing in mind that Ms. Maxwell, I think was in New York then, she was five hours behind, so there was quite a lot of, sort of time difference between the various countries here, I sent her an email, I believe, saying - parsing this-- forwarding this email to her saying “How do you wish to proceed?” And then I was on the telephone-- I had two telephones in the car, I received in excess of 30 phone calls from various media outlets on th° 2nd of January, all asking for information about how Ms. Maxwell was looking to respond to the latest court filings, which were filed on the 30th of December as I understand. And by close-- towards close of play on the 2nd, I received an email forwarded by Ms. Maxwell, containing a draft statement which my understanding was the majority of which had been drafted by Mr. Barden with a header along the lines of “This is the agreed statement.”: At close of play on th® 2nd. So—I was—I had gone under the Channel Tunnel and I was sitting on the other side and that email, which my understanding was that it had been signed off by the client, effectively, was then sent out to a number of media, including Mr. Ball and various other UK newspapers. Q. Mr. Gow, when you say “end of play” and “close of play,” are you referring to sending the email that is Exhibit 2? A. Yes, lam ae Q. The subject line does have “FW” which to me indicates it’s a forward. Do you know where the rest of this email chain is? A. My understanding of this is: It was a holiday in the UK, but Mr. Barden was not necessarily accessible at some point in time, so this had been sent to him originally by Ms. Maxwell, and because he was unavailable, she forwarded it to me for immediate action. I therefore respond, “Okay, Ghislaine, I’ll go with this.” It is my understanding that this is the agreed statement because the subject of the second one is “Urgent, this is the statement” so I take that as an instruction to send it out, as a positive command: “This is the statement.”* Accordingly, record evidence shows that the press release was intended as press release, and not as a “legal argument.” Record evidence also establishes that Defendant circulated the press release to Barden and Gow, and then gave a “positive command” to Gow to publish it. Additionally, there is no indicia that the press release is a legal opinion. To the contrary, it was issued by, and specifically attributed to, a woman who has personal knowledge of whether Ms. Giuffre’s claims of sexual abuse are true, and she states that Ms. Giuffre is a liar.“ At the very least, all of these factual issues must be considered by a jury. ® See McCawley Dec. at Exhibit 6, Ross Gow Dep. Tr. at 14:15-17; 31:19-33:7; 44:6-45:13 (emphasis added). Unsurprisingly, Defendant cites no case law to support her argument that her attorney’s alleged influence in preparing the statement Defendant issued to the media somehow shields her from liability. 37

Case 18-2868, Document 280, 08/09/2019, 2628232, Page46 of 74 Another example is that Defendant states that “Gow served only as Mr. Barden’s conduit to the media” (MTD at 25), and “Mr. Barden was directing the January 2-15 statement to a discrete number of media representatives.” Barden wasn’t directing anything — he wasn’t even in the loop when Defendant decided to publish the statement - and the documents prove it. Indeed, the press release itself states that it is “on behalf of Ms. Maxwell,” not Barden, and it was Defendant who gave the “positive command” to Gow to publish it. These are just a couple of examples, among many, of the purported facts asserted in Defendant’s motion and Barden’s Declaration that are directly refuted by facts in the record. Finally, neither the media nor the general public could have known that the statement should be attributed to Barden. His name was nowhere in it, nor is there any reference to counsel. Defendant’s argument that the “context” is the media knowing Barden’s intent or involvement is unsupported by the record. The significant factual disputes about Barden, alone, prevent summary judgment. Cc. Defendant’s Defamatory Statement Was Not Opinion as a Matter of Law. As this Court previously held, correctly, Defendant stating that Ms. Giuffre’s claims of sexual assault are lies is not an expression of opinion: “First, statements that Giuffre’s claims ‘against [Defendant] are untrue,’ have been ‘shown to be untrue,’ and are ‘obvious lies’ have a specific and readily understood factual meaning: that Giuffre is not telling the truth about her history of sexual abuse and Defendant’s role, and that some verifiable investigation has occurred and come to a definitive conclusion proving that fact. Second, these statements (as they themselves allege), are capable of being proven true or false, and therefore constitute actionable fact and not opinion. Third, in their full context, while Defendant’s statements have the effect of generally denying Plaintiff's story, they also clearly constitute fact to the reader.” Giuffre v. Maxwell, 165 F. Supp. 3d 147, 152 (S.D.N.Y. 2016). This Court further explained: “Plaintiff cannot be making claims shown to be untrue that are obvious lies without being a liar. Furthermore, to suggest an individual is not telling the truth 38

Case 18-2868, Document 280, 08/09/2019, 2628232, Page47 of 74 about her history of having been sexually assaulted as a minor constitutes more than a general denial, it alleges something deeply disturbing about the character of an individual willing to be publicly dishonest about such a reprehensible crime. Defendant’s statements clearly imply that the denials are based on facts separate and contradictory to those that Plaintiff has alleged.” Jd. Defendant argues that somehow the “context” of the entire statement “tested against the understanding of the average reader” should be the press release as a whole being read only by journalists. This is an unreasonable construct because the ultimate audience for a press release is the public. Indeed, the purpose of a press release is to reach readers. Unsurprisingly, Defendant cites no case that holds that journalists might somehow believe statements of fact are opinion while others do not. This Court has previously covered this ground when it clearly stated: Sexual assault of a minor is a clear-cut issue; either transgression occurred or it did not. Either Maxwell was involved or she was not. The issue is not a matter of opinion, and there cannot be differing understandings of the same facts that justify diametrically opposed opinion as to whether Defendant was involved in Plaintiffs abuse as Plaintiff has claimed. Either Plaintiff is telling the truth about her story and Defendant’s involvement, or Defendant is telling the truth and she was not involved in the trafficking and ultimate abuse of Plaintiff. Giuffre v. Maxwell, 165 F. Supp.at 152 (S.D.N.Y. 2016). The same conclusion applies now. At the motion to dismiss stage, Defendant had not yet produced the statement she issued to the press. That statement is now in evidence, so there is no ambiguity as to what defendant released to the press. The absurdity of Defendant characterizing his statements calling Ms. Giuffre a liar as mere “opinion” is revealed by the fact that Defendant was the one who was sexually trafficking and otherwise abusing Ms. Giuffre. No reasonable person in any context would construe that as Defendant’s mere “opinion” on the subject, since Defendant knew she was abusing Ms. Giuffre. Indeed, this argument is contradicted by Defendant’s own deposition testimony: 39

Case 18-2868, Document 280, 08/09/2019, 2628232, Page48 of 74 Q. Do you believe Jeffrey Epstein sexually abused minors? A. I can only testify to what I know. I know that Virginia is a liar and I know what she testified is a lie. So I can only testify to what I know to be a falsehood and half those falsehoods are enormous and so I can only categorically deny everything she has said and that is the only thing I can talk about because I have no knowledge of anything else. See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. (April 17, 2016) at 174:6-19. Defendant slyly contends in her motion that “Mr. Barden’s “arguments” in the press release constitute ‘pure opinion,” attempting to disclaim any involvement in making the defamatory statement. However, it is not Mr. Barden’s statement, nor his opinion, that it at issue here. At issue here is Defendant’s statement — a statement attributable to her, that she approved, whose publication she “command{ed],” and for which she hired a public relations representative to disseminate to at least 30 journalists for publication. While Mr. Barden could possibly have had his own opinion as to whether or not his client abused Ms. Giuffre, Defendant cannot express an opinion on a binary, yes/no subject where she knows the truth. As this Court previously articulated, “statements that Giuffre’s claims ‘against [defendant] are untrue,’ have been ‘shown to be untrue,’ and are ‘obvious lies’ have a specific and readily understood factual meaning.” Giuffre v. Maxwell, 165 F. Supp. 3d at 152. Again, at the very least, the jury must pass on such issues. D. The Pre-Litigation Privilege Does Not Apply to Defendant’s Press Release 1. Defendant fails to make a showing that the pre-litigation privilege applies. Defendant’s next argument seeks refuge in the pre-litigation privilege. If we understand the argument correctly, Defendant seems to be saying that because she was contemplating an (unspecified and never-filed) lawsuit involving the British Press, she somehow had a “green light” to make whatever defamatory statements she wanted about Ms. Giuffre. To prove such a 40

Case 18-2868, Document 280, 08/09/2019, 2628232, Page49 of 74 remarkably claim, Defendant relies on caselaw involving such mundane topics as “cease and desist” letters sent to opposing parties and the like. Obviously such arguments have no application to the press release that Defendant sent out, worldwide, attacking Ms. Giuffre’s veracity. The problems with the Defendant’s argument are legion. For starters, there is no record evidence — not even Defendant’s own testimony — suggesting that she was contemplating litigation against Ms. Giuffre, or that her press release was related to contemplated litigation against Ms. Giuffre. Tellingly, the only “evidence” Defendant cites of any alleged contemplated litigation is the self-serving, post hoc, partial waiver of attorney-client privilege found in the Barden Declaration. As discussed above, that Declaration fails to establish that there was good faith anticipated litigation between her and Ms. Giuffre, particularly when evidence in the record contradicts such assertions. At the very least, it is a matter of fact for the jury to decide. In another case in which a defendant attempted to claim pre-litigation privilege applied to statements made to the press, this Court denied summary judgment, and held, “[t]o prevail on a qualified privilege defense [defendant] must show that his claim of privilege does not raise triable issues of fact that would defeat it.” Block v. First Blood Associates, 691 F. Supp. 685, 699-700 (Sweet, J.) (S.D.N.Y. 1988) (denying summary judgment on the pre-litigation qualified privilege affirmative defense because there was “a genuine issue as to malice and appropriate purpose”). Defendant’s claim here likewise fails. First, Defendant’s testimony makes no mention of any contemplated lawsuit — much less, any contemplated lawsuit against Ms. Giuffre. Second, Defendant has offered no witnesses who will testify that she intended to bring any law suit. Third, she did not, in fact, bring any such lawsuit. The only “evidence” is a post hoc Declaration written by her attorney. Finally, it must be 41

Case 18-2868, Document 280, 08/09/2019, 2628232, Page5S0O of 74 remembered, as explained at length above, the Defendant had sexually trafficking Defendant and was attempting to continue to conceal her criminal acts. Whether her statements had an “appropriate purpose,” Block 691 F. Supp. at 699-700 (Sweet, J.) — or were, rather, efforts by a criminal organization to silence its victims — is obviously contested. Accordingly, obvious issues of fact exist as to whether or not Defendant contemplated litigation. Distorting reality, Defendant further argues: “Statements pertinent to a good faith anticipated litigation made by attorneys (or their agents under their direction) before the commencement of litigation are privileged.” (MSJ at 33). The record evidence shows that Defendant’s attorney did not make the defamatory statement. Further, Defendant’s attorney’s agents did not make the defamatory statement. Defendant did. And, there was no statement made by anyone “before the commencement of litigation” because /itigation never commenced. Accordingly, the cases Defendant cites where attorneys are making statements (or where clients are making statements to their attorneys regarding judicial proceedings including malpractice) are wholly inapposite as detailed below. 45 ¢ Front v. Khalil, 24 N.Y.3d 713, 720 (2015) - statement made by attorney. © Flomenhaft v. Finkelstein, 127 A.D.3d 634, 637 n.2, 8 N.Y.S.3d 161 (N.Y. App. Div. 2015) - did not even address pre-litigation privilege, and said that Front, Inc. was not relevant to the case. ¢ Kirk vy, Heppt, 532 F. Supp. 2d 586, 593 (S.D.N.Y. 2008) - the communication at i attorney’s client to the attorney’s malpractice carrier concerning the client’s justi attorney over which the clients actually sued. © Petrus v Smith, 91 A.D.2d 1190 (N.Y.A.D.,1983) - the court held: “[rJemarks of attorney to Surrogate are cloaked with absolute immunity as statements made in course of judicial proceedings — Attorney’s gratuitous opinion outside courthouse calling plaintiff liar . . . is not similarly immune.” (This case undermines the false argument Defendant tries to make). ¢ Klien - contrary to dicta quoted by Defendant from the Klein case, there were no communications made “between litigating parties or their attorneys,” just a press release Defendant instructed her press agent to disseminate to the media. © = Frechtman v. Gutterman, 115 A.D.3d 102, 103, 979 N.Y.S.2d 58, 61 (2014) - the communication at issue was a letter sent by a client to his attorney terminating the representation for malpractice. ¢ Sexter & Warmflash, P.C. v. Margrabe, 38 A.D.3d 163 (N.Y.A.D. 1 Dept. 2007) - privilege applied to letter client sent discharging law firm as the client’s attorneys as statements relating to a judicial proceeding and law firm sued for defamation. ue was made by an iable controversy against the 42

Case 18-2868, Document 280, 08/09/2019, 2628232, Page51 of 74 Similarly, in Black v. Green Harbour Homeowners’ Ass'n, Inc., 19 A.D.3d 962, 963, 798 N.Y.S.2d 753, 754 (2005), cited by Defendant, the Court held a privilege applied to a letter sent by a home owner’s association board of directors to the association’s members informing them of the status of litigation to which the association was a party, and to the association’s letter to the state attorney general sent to discharge it’s duties to the association. In this case, litigation was actually pending, the communication was sent by a party to that litigation as part of its duties, and the communication itself concerned the litigation. Defendant’s press release fits none of those descriptions. Unsurprisingly, Defendant cites to no case in which a Court has held that this or any qualified privilege extends to internationally disseminated press releases defaming a non-party to the purported “anticipated” litigation. Regardless of whether or not Barden had a hand in drafting the statement (another disputed issue of fact for the jury), Defendant issued the statement, instructed that it be published, and the statement she issued was attributed to her, and not to her attorney (or his agents). Accordingly, all the case law Defendant cites about an attorney making a statement (or a client making a statement to their attorney or malpractice carrier) is inapposite. 2. Defendant is foreclosed from using the pre-litigation privilege because she acted with malice. In any event, because Defendant acted with malice, she cannot avail herself of the prelitigation privilege. As this Court has explained denying Defendant’s motion to dismiss, “‘There is no qualified privilege under New York law when such statements are spoken with malice, knowledge of their falsity, or reckless disregard for their truth.’” Giuffre v. Maxwell, 165 F. Supp. 3d at 155 (citing Block, 691 F. Supp. at 699 (Sweet, J.) (S.D.N.Y. 1988). There is ample record evidence that Defendant acted with malice in issuing the press release, thereby making the litigation privilege inapplicable. See Block, 691 F. Supp. at 700 (Sweet, J.) (“Here, sufficient 43

Case 18-2868, Document 280, 08/09/2019, 2628232, Page52 of 74 evidence has been adduced to support the inference that [defendant] acted with malice, and may not, therefore, claim a qualified privilege under New York law . . . a genuine issue as to malice and appropriate purpose has properly been raised and is sufficient to preclude summary judgment.”). For example, Ms. Sjoberg testified that Defendant recruited her for sex with Epstein, thus corroborating Ms. Giuffre’s own account of Defendant’s involvement in abusing her with Epstein. For another example, Jeffrey Epstein’s pilot testified that Defendant flew with Ms. Giuffre on at least 23 flights, thus corroborating Ms. Giuffre’s claims against Defendant. See McCawley Dec. at Exhibit 15, Rodgers Dep. Tr., at 34:3-10. For another example, Tony Figueroa testified that Defendant asked him for assistance in recruiting girls for Epstein — more testimony that corroborates Ms. Giuffre’s claims against Defendant. Defendant’s statements that Ms. Giuffre was lying and her claims of sexual abuse were “obvious lies” were not pertinent to a good faith anticipated litigation but, instead, they were made for an inappropriate purpose — i.e., to bully, harass, intimidate, and ultimately silence Ms. Giuffre. As the record evidence shows, Defendant knew the statements were false because Defendant engaged in and facilitated the sexual abuse of this minor child, therefore, they were made for the inappropriate purpose of “bullying,” “harassment,” and “intimidation.” See Front v. Khalil, 24 N.Y.3d 713, 720 (2015). Simply put, Defendant sexually trafficked Ms. Giuffre — and then tried to silence Ms. Giuffre to keep her crimes secret — circumstances that prevent her from using privileges designed to shield legitimate legal disputes from court interference. New York case law fully confirms that pre-litigation qualified privilege does not apply to this case. Historically, statements made in the course of litigation were entitled to privilege from defamations claims “so that those discharging a public function may speak freely to zealously represent their clients without fear of reprisal or financial hazard.” Jd. at 718. A 2015 New York 44

Case 18-2868, Document 280, 08/09/2019, 2628232, Page53 of 74 Court of Appeals case somewhat extended this privilege by holding that statements made by attorneys prior to the commencement of the litigation are protected by a qualified privilege if those statements are pertinent to a good faith anticipated litigation. /d. at 718. (“Although it is well settled that statements made in the course of litigation are entitled to absolute privilege, the Court has not directly addressed whether statements made by an attorney on behalf of his or her client in connection with prospective litigation are privileged” . . . “to advance the goals of encouraging communication prior to the commencement of litigation” . . . “we hold that statements made prior to the commencement of an anticipated litigation are privileged, and that the privilege is lost where a defendant proves that the statements were not pertinent to a good faith anticipated litigation.”). The Court of Appeals’ reason for allowing this qualified privilege could not be more clear: “When litigation is anticipated, attorneys and parties should be free to communicate in order to reduce or avoid the need to actually commence litigation. Attorneys often send cease and desist letters to avoid litigation. Applying privilege to such preliminary communication encourages potential defendants to negotiate with potential plaintiffs in order to prevent costly and time consuming judicial intervention.” /d. at 719-20. Under this rationale, the Khalil court found that an attorney’s letters to the potential defendant were privileged because they were sent “in an attempt to avoid litigation by requesting, among other things, that Khalil return the alleged stolen proprietary information and cease and desist his use of that information.” /d. at 720. Here, quite unlike Khalil, the Defendant’s statements were (1) made by a non-attorney (Defendant through Gow); (2) concerning a non-party to any alleged anticipated litigation; (3) knowingly false statements; and (4) contained in a press release directed at, and disseminated to, 45

Case 18-2868, Document 280, 08/09/2019, 2628232, Page54 of 74 the public at large. Defendant’s statements cannot be considered “pertinent to a good faith anticipated litigation,” such that the qualified privilege should apply. Finally, though it strains credulity to even entertain the prospect, if Defendant could make even colorable showings on these basic issues, it would remain an issue of fact for the jury to determine whether or not Defendant’s press release, calling Ms. Giuffre’s sex abuse claims “obvious lies,” was any type of “cease-and-desist” statement or a statement that acted to “reduce or avoid” or resolve any “anticipated” litigation. Summary judgment is obviously inappropriate here as well. 3. Defendant cannot invoke the pre-litigation privilege because she has no “meritorious claim” for “good faith” litigation. Finally, Defendant cannot prevail in asserting this qualified privilege because, in order to invoke this privilege, she must have “meritorious claims” for “good faith anticipated litigation.” Khalil specifically states that for the qualified privilege to apply, the statements must be made “pertinent to a good faith anticipated litigation,” and it does not protect attorneys . . . asserting wholly unmeritorious claims, unsupported in law and fact, in violation of counsel’s ethical obligations.” Khalil, 24 N.Y.3d at 718, 720 (emphasis added). Defendant has neither “meritorious claims” nor “good faith anticipated litigation.” Defendant cannot have a “meritorious claim” for “good faith anticipated litigation” against the press (or Ms. Giuffre) because Ms. Giuffre’s reports of her sexual abuse are true, Defendant knows that they are true, and Defendant made a knowingly false statement when she called Ms. Giuffre a liar. Under these circumstances, Defendant has no “meritorious” claim to make in “good faith” relating to either Ms. Giuffre’s statements or their coverage in the press, thereby making her defamatory statements wholly outside the protection of this qualified privilege. At the very least, the issue of 46

Case 18-2868, Document 280, 08/09/2019, 2628232, Page55 of 74 whether Defendant has meritorious claims against the press on the grounds that she did not abuse Ms. Giuffre is a question of fact for the jury to decide. Vv. DEFENDANT HAS NOT - AND CANNOT - SHOW THAT HER DEFAMATORY STATEMENT IS SUBSTANTIALLY TRUE Defendant next claims that her press release calling Ms. Giuffre a liar about her past sex abuse was somehow “substantially true.” Here again, this is a highly disputed claim. On its face, to determine what is “substantially” true or not requires extensive fact finding, such as whether Defendant recruited Ms. Giuffre as a minor child for sex with Defendant’s live-in boyfriend and convicted pedophile, Jeffrey Epstein. Accordingly, summary judgment is not appropriate. See Mitre Sports Intern. Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240, 255 (S.D.N.Y.2014) (denying summary judgment because it would require the Court to decide disputed facts to determine whether the statement at issue was substantially true); Da Silva v. Time Inc., 908 F. Supp. 184, 187 (S.D.N.Y. 1995) (denying motion for summary judgment because there was a genuine issue of material act as to whether defamatory photo and caption were not true, stating “{iJn the instant case Da Silva’s contention that she was a reformed prostitute at the time of photography and publication provides a rational basis upon which a fact-finder could conclude that the photograph was not substantially true”). Additionally, Defendant has remarkably not submitted any evidence that she did not recruit Ms. Giuffre for sex with Epstein. Nor has Defendant offered any evidence that her role in Epstein’s household was not to recruit girls and young women for Jeffrey Epstein. Accordingly, summary judgment is inappropriate. See Stern v. Cosby, 645 F. Supp. 2d 258, 277 (S.D.N.Y. 2009) (because defendant had “not submitted any evidence to show that Statement 11 is substantially true, her motion for summary judgment as to Statement 11 is denied”). 47

Case 18-2868, Document 280, 08/09/2019, 2628232, Page56 of 74 Further, much of the purported evidence upon which Defendant relies to allege the truth of her defamatory statement is merely hearsay, including inadmissible hearsay statements made by Alan Dershowitz, who Defendant did not depose in this case (and whom Ms. Giuffre has not had an opportunity to cross examine). Hearsay cannot establish the truth of a defamatory statement as a matter of law at summary judgment. Lopez v. Univision Communications, Inc., 45 F. Supp.2d 348, 359 (S.D.N.Y.1999) (denying summary judgment and holding “defendants’ evidence as to what they were told by representatives of NYU and Kean College, to the extent offered for the truth of the matters asserted, is inadmissible hearsay and an insufficient basis upon which to grant summary judgment of dismissal on the ground that the statements were substantially true.”). Finally, many of the facts upon which Defendant bases her argument that her defamatory statement was true are wholly tangential to the claims against her by Ms. Giuffre and the defamatory statement. For example, Defendant supports her contention that she did not recruit Ms. Giuffre for sex with Epstein based on the fact that Ms. Giuffre lived independently of her parents before meeting Epstein and Ms. Maxwell. (Of course, a child outside the supervision of her parents makes it much more likely she would be recruited by Defendant into sex trafficking, but that is for the jury to decide.) That fact does not go to whether or not Defendant’s statement calling Ms. Giuffre a liar is true, because Ms. Giuffre never made any claims relating to where she lived prior to meeting Defendant. Moreover, it is immaterial with whom she was living: the fundamental and overarching fact remains that Defendant recruited Ms. Giuffre for sex with Epstein when she was a minor child. Defendant next proffers Ms. Giuffre’s limited high school enrollment and short-term jobs that she held as evidence that she and Epstein did not abuse her. The logic of this position is 48

Case 18-2868, Document 280, 08/09/2019, 2628232, Page57 of 74 unclear. The fact that Ms. Giuffre worked at Taco Bell for a few days hardly establishes she was not abused by Defendant and Epstein. Indeed, if anything its shows the vulnerability of Ms. Giuffre to enticements that a billionaire and his wealthy and powerful girlfriend could offer. In any event, what to make of such fact is something for the jury to consider. They are irrelevant for the same reason as above: Ms. Giuffre never made any claims about her studies or her prior employment. Indeed, neither Ms. Giuffre’s statement about being recruited by Defendant as a child, nor Defendant’s refutation even mentions Ms. Giuffre’s lack of schooling or lack of a stable home as a child. Purported facts that have nothing to do with Ms. Giuffre’s claims of sexual abuse against Defendant, and nothing to do with Defendant calling Ms. Giuffre a liar for such claims, do not establish the “substantial truth” of Defendant’s statement. Tellingly, Defendant cites to no analogous case in any jurisdiction that even suggests otherwise. VI. PLAINTIFF DOES NOT NEED TO ESTABLISH MALICE FOR HER DEFAMATION CLAIM, BUT IN THE EVENT THE COURT RULES OTHERWISE, THERE IS MORE THAN SUFFICIENT RECORD EVIDENCE FOR A REASONABLE JURY TO DETERMINE DEFENDANT ACTED WITH ACTUAL MALICE Defendant’s next (and, again, quite remarkable) argument is that Ms. Giuffre somehow will be unable to establish actual malice in this case. One would think that a sex trafficker calling one of her victims a liar would be a quintessential example of actual malice. Defendant’s spurious case citations and misplaced argument do not detract from this core fact. Though Defendant does not mention the legal standard for actual malice until she is 48 pages into her 68-page brief,” the legal definition of actual malice, as defined by the United 4 Though perhaps a scrivener’s error, Defendant errantly cites to two Supreme Court cases ~ Gerts v. Robert Welch, Inc., 418 U.S. 323 (1974) and Philadelphia Newspapers, Inc. v. Hepps, 475 U.S. 767 (1986) — that arose out of the laws of Illinois and Pennsylvania, respectively, to support a proposition concerning New York law. Defendant also cites to Harte-Hanks Commc'ns, Inc. v. Connaughton, 491 U.S. 657, 109 S, Ct. 2678, 105 L. Ed. 2d 562 (1989), wherein the ruling was not at summary judgment, and the plaintiff in the defamation case was a judicial candidate in a public election. 49

Case 18-2868, Document 280, 08/09/2019, 2628232, Page58 of 74 States Supreme Court, and reiterated by the Second Circuit, should be the light by which all of Defendant’s purported “facts” and argument should be viewed. “Actual malice” means that the statement was published with “knowledge that the statement was ‘false or with reckless disregard of whether it was false or not.’” Baiul v. Disson, 607 F. App'x 18, 20 (2d Cir. 2015), quoting New York Times Co. v. Sullivan, 376 U.S. 254, 280, 84 S. Ct. 710, 11 L.Ed.2d 686 (1964). Defendant argues that Ms. Giuffre is a limited purpose public figure. While Ms. Giuffre disputes that claim, the issue is entirely irrelevant here because Ms. Giuffre will prove at trial, with overwhelming evidence, that Defendant made her statement calling Ms. Giuffre a liar with malice, fully knowing — as a sex trafficker — that it was false. Put another way, Defendant knew that Ms. Giuffre was telling the truth when she described how Defendant recruited her for sex as an underage girl and then sexually trafficked her with her boyfriend Jeffrey Epstein. The Second Circuit instructs that, “[o]n a motion for summary judgment, a court cannot try issues of fact; it can only determine whether there are issues to be tried. If, as to the issue on which summary judgment is sought, there is any evidence in the record from any source from which a reasonable inference could be drawn in favor of the nonmoving party, summary judgment is improper.” Chambers v. TRM Copy Ctrs. Corp., 43 F.3d 29, 37 (2d Cir. 1994) (internal citations and quotations omitted). “As the moving party, Defendants have the burden of demonstrating an absence of clear and convincing evidence substantiating Plaintiffs’ claims.” De Sole v. Knoedler Gallery, LLC, 139 F. Supp. 3d 618, 640 (S.D.N.Y. 2015) (citing Chambers). Defendant fails to meet her burden of demonstrating an absence of clear and convincing evidence substantiating Ms. Giuffre’s claims that Defendant acted with actual malice. Ms. Giuffre will easily be able to meet any trial burden of clear and convincing evidence of actual 50

Case 18-2868, Document 280, 08/09/2019, 2628232, Page59 of 74 malice. Tellingly, Defendant does not even attempt to address the documentary evidence, nor the testimonial evidence showing she was a recruiter of girls for Epstein. As shown above, far beyond showing that a reasonable inference could be drawn in her favor, which is all that is required at this point to defeat Defendant’s motion, Ms. Giuffre will easily be able to meet her trial burden of clear and convincing evidence of actual malice. Of course, a plaintiff need only show “actual malice” on the part of a defendant if that plaintiff is a public figure or a limited public figure, which Ms. Giuffre is not, as explained infra. VII. THE COURT NEED NOT REACH THE ISSUE, AT THIS TIME, OF WHETHER MS. GIUFFRE IS A LIMITED PURPOSE PUBLIC FIGURE For the reasons just explained, Ms. Giuffre will easily be able to prove actual malice at the trial in this case. Defendant argues that Ms. Giuffre “is a public figure who must prove actual malice.” MSJ at 49. Given the overwhelming proof of the second part of that statement, the Court need not spend its time considering the first. If the Court wishes to nonetheless consider the issue at this time, it is not appropriate for disposition at the summary judgment stage of this case. The defendant bears the burden of demonstrating that the plaintiff is a limited purpose public figure. See Lerman v. Flynt Distrib. Co., 745 F.2d 123, 136-37 (2d Cir. 1984). Defendant correctly articulates the legal test for a finding that a plaintiff is a limited purpose public figure, but glosses over the fact that all prongs of the test must be met in order for a court to make that finding. See, e.g., Contemporary Mission, Inc. v. N.Y. Times Co., 842 F.2d 612, 617 (2d Cir. 1988) (“[T]his court set forth a four part test for determining whether someone is a limited purpose public figure” (emphasis added)); Herbert v. Lando, 596 F. Supp. 1178, 1186 (S.D.N.Y. 1984) (“The Second Circuit recently summarized the criteria” (emphasis added)), aff'd in part, rev'd in part, 781 F.2d 298 (2d Cir. 1986); cf: Nehls v. Hillsdale Coll., 178 F. Supp. 2d 771, 778 (E.D. Mich. 2001) (finding plaintiff Sl

Case 18-2868, Document 280, 08/09/2019, 2628232, Page60 of 74 was not a limited public figure for failing one element of the Lerman test and thus denying defendant’s motion for summary judgment) (“The defendant has proven all of the elements but the third ...”), aff'd, 65 F. App’x 984 (6th Cir. 2003). Of course, proof that Ms. Giuffre (or anyone else) is a limited purpose public figure requires proof of a set of facts from which Ms. Giuffre believes Defendant has not shown in satisfaction of the four-part test. Significantly this Court should pause here to note that the details of Jane Doe 3’s sexual exploitation and abuse, as anonymously set forth in her CVRA joinder motion, caused the Defendant to identify, with certainty, Jane Doe 3 as Ms. Giuffre. Yet, at her deposition, Defendant claimed to “barely remember her at all.”*” Defendant’s ability to immediately and positively identify the anonymous individual making claims of sexual abuse, if anything, shows that Defendant was intimately aware of Ms. Giuffre’s sexual exploitation. And, to be sure, Ms. Giuffre never asked to be sexually abused or trafficked by Defendant or convicted pedophile Jeffrey Epstein when she was a child — legally, she did not even have the capacity to consent. Defendant cannot recruit a minor child for sexual exploitation and then, afterwards, argue that her victim injected herself into the public controversy when coming forward about the abuse she suffered. Moreover, Defendant has not made a sufficient showing that Ms. Giuffre has “regular” and “continuing” access to the news media. The policy rationale behind this prong is that public figures generally enjoy significant access to the media. One reporter wrote some articles on Ms. Giuffre in 2011. Thereafter, it was not until 2015, that Ms. Giuffre spoke to someone in the news media about these issues, and that interview was granted after Defendant’s defamatory remarks. Such limited contacts precludes a finding that Ms. Giuffre is a limited public figure. See *” See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 44:23-45:4 (July 22, 2016) (“Q. You do remember Virginia, about that time back in the 2000s, giving Mr. Epstein massages? A. I barely remember her at all.”). 52

Case 18-2868, Document 280, 08/09/2019, 2628232, Page61 of 74 Hutchinson v. Proxmire, 443 U.S. 111, 99 S. Ct. 2675, 61 L.Ed.2d 411 (1979) (finding plaintiff maintained no regular and continuing access to the media and thus was not a public figure). It is also unclear how Defendant plans to show that Ms. Giuffre “successfully invited public attention to her views.” To be sure, Ms. Giuffre decided to start “Victims Refuse Silence,” a not-for-profit organization whose mission is “to change the landscape of the war on sexual abuse and human trafficking. Our goal is to undertake an instrumental role in helping survivors break the silence associated with sexual abuse. To fulfill this mission, we aim to enhance the lives of women who have been victimized.”** The website lists the National Trafficking Hotline, and provides a state-by-state resources for local organizations where victims can seek help. Unsurprisingly, Defendant cites no cases that hold that maintaining a website makes one a public figure. See Mitre Sports Int'l Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240, 252 (S.D.N.Y. 2014) (finding plaintiff was not a limited public figure and denying defendant’s motion for summary judgment) (“corporate policy denouncing child labor on its website ... do[es] not show that Mitre ... aimed to influence the public’s views on the controversy”). More important, Defendant does not explain how Ms. Giuffre was using the website to influence public views on whether she had been abused by Defendant — the subject at issue in this lawsuit. Interestingly, Defendant has spent $ 17,875“ on an expert witness to tell the Court and the jury that hardly anyone searches on the internet using search terms such as “victims refuse silence sex slave.” One of Defendant’s six briefs raising Daubert issues specifically argues that Dr. Anderson’s estimates on the cost of remediating Ms. Giuffre’s online reputation are improper because Dr. Anderson included nearly unused search phrases when evaluating internet content. Kent’s rebuttal report states: “. . . there seems no reason to believe that such a person would use “Shttp://www.victimsrefusesilence.org/our-mission. *® See McCawley Dec. at Exhibit 9, Kent Dep. Tr. at 25:16-26:6. 53

Case 18-2868, Document 280, 08/09/2019, 2628232, Page62 of 74 this term . . . Indeed, these are terms unlikely to be used by anyone unfamiliar with this litigation. . .. Why, for instance, would it be necessary to push down offending Web pages in the results that the search engines provide for the term victim’s refuse silence sex slave, when this term is likely never used . . .” See McCawley Dec. at Exhibit 25, Kent Report at 10, 33. Defendant cannot argue to the Court that Ms. Giuffre has “successfully” invited public attention to her views through her VRS website while simultaneously filing a Daubert motion that argues that search terms such as “victims refuse silence sex slave” are “likely never used,” thus making the website unsuccessful in inviting public attention. In any event, Defendant has failed to set forth with precision the allegedly undisputed fact — and supporting evidence — she uses to support her argument. Moreover, “[i]t is preferable to reduce the public figure question to a more meaningful context by looking to the nature and extent of an individual’s participation in the particular controversy giving rise to the defamation.” Greenberg v. CBS Inc., 69 A.D.2d 693, 704, 419 N.Y.S.2d 988, 995 (1979) (emphasis added), citing Gertz v. Robert Welch, Inc., 418 U.S. 323, 345, 352, 94 S. Ct. 2997, 41 L.Ed.2d 789. The context here is highly significant. Ms. Giuffre never chose to participate in Defendant and Epstein’s underage sex ring, a “controversy” that gave rise to Defendant’s defamation. In arguing that Ms. Giuffre thrust herself into the public spotlight, Defendant conveniently leaves out the fact that it is by her doing that Ms. Giuffre is in this controversy in the first place. No minor child willingly becomes a participant in sexual abuse, and it is perverse for the abuser to argue that her victim deliberately became a subject of public attention when speaking out about that abuse for the purpose of advancing justice and helping other victims. 54

Case 18-2868, Document 280, 08/09/2019, 2628232, Page63 of 74 For all these reasons, the Court should simply decline to decide the public figure issue at this juncture. But if it chooses to reach the issue, it should reject Defendant’s unsupported argument. VII. THE JANUARY 2015 STATEMENT WAS NOT “SUBSTANTIALLY TRUE,” AND MS. GIUFFRE HAS PRODUCED CLEAR AND CONVINCING EVIDENCE OF ITS FALSITY As a final argument, Defendant argues that her January 2015 statement was “substantially true.” Given that the statement argues that Ms. Giuffre lied when she said she was sexually trafficked by Defendant, the reader of Defendant’s motion might reasonably expect to see some evidence presented showing that Defendant was not a sex trafficker. Instead, the reader is treated to technical quibbles. For example, the lead argument to show the “substantial” truth of Defendant’s statement is the argument that Ms. Giuffre was not fifteen years old, but all of sixteen or seventeen years old when she was trafficked. As the Court knows (and can take judicial notice of), Florida law makes age eighteen the age of consent. Accordingly, it is no moment that Ms. Giuffre may have been mistaken about the exact year the sex trafficking started. Call this the “yes-I’m-a-sex-trafficker-but-only-of-sixteen-year-old-girls” defense. To even describe the defense is to show how meritless it is. More broadly, at issue are the statements Ms. Giuffre made regarding Defendant’s involvement in, and knowledge of, the sexual abuse and sex trafficking of Ms. Giuffre (and other minor girls) through a recruitment scheme executed by Defendant and Jeffrey Epstein. In response to those various statements, Defendant publicly claimed that, “the allegations made by (Ms. Giuffre) against Ghislaine Maxwell are untrue.” Defendant continued that Ms. Giuffre’s “claims are obvious lies and should be treated as such....” Defendant, through her statement 55

Case 18-2868, Document 280, 08/09/2019, 2628232, Page64 of 74 intended to convey that Ms. Giuffre was lying about everything she had said against Defendant — “the allegations.” In sum and essence, those statements made by Ms. Giuffre about which Defendant released a public statement to exclaim were “untrue” and “obvious lies” were: qd) Q) @) (4) (5) (6) op) (8) (9) That Defendant approached Ms. Giuffre while Ms. Giuffre was an underage minor working at the Mar-a-Lago Country Club, and recruited the then-minor Ms. Giuffre to go to the house of Jeffrey Epstein under the pretense of providing massage to Jeffrey Epstein for money; 2 That Ms. Giuffre followed Defendant’s instructions, and was driven to Jeffrey Epstein’s house, where she was greeted by Defendant and later introduced to Jeffrey Epstein; That Ms. Giuffre was lead upstairs to be introduced to Jeffrey Epstein in his bedroom, and that while there Defendant demonstrated how Ms. Giuffre should provide a massage to Jeffrey Epstein; That Defendant and Epstein converted the massage into a sexual experience, requesting that Ms. Giuffre remove her clothing, after which time a sexual encounter was had; That Defendant and Epstein expressed approval for Ms. Giuffre, and offered her money in exchange for this erotic massage turned full sexual encounter; That Defendant and Epstein offered Ms. Giuffre the promise of money and a better life in exchange for Ms. Giuffre acting sexually compliant and subservient to their demands; 4 at Ms. Giuffre, after that first encounter, was repeatedly requested to service pstein and/or Defendant sexually and/or others; les] That Ms. Giuffre was taken on Epstein’s private planes on numerous occasions and trafficked nationally and internationally for the purpose of servicing Epstein and others, including Defendant, sexually; That Defendant was Epstein’s primary manager of the recruitment and training of females who Epstein paid for sexual purposes; (10) That Defendant participated in sexual encounters with females, including Ms. Giuffre; and (11) That Ms. Giuffre and other recruited females were encouraged by Defendant and Epstein to bring other young females to Epstein for the purpose of servicing him sexually. 56

Case 18-2868, Document 280, 08/09/2019, 2628232, Page65 of 74 Defendant, by way of her January 2015 statement, declared that Ms. Giuffre lied about each and every one of these allegations regarding Defendant. In fact, Defendant clarified further this position in her deposition when she said repeatedly that everything Ms. Giuffre said about Defendant was totally false.*° The clarification in her deposition is identical in intention to the reasonable interpretation of her statement that Defendant made publicly, which has formed the basis of this defamation action—that Ms. Giuffre was lying about everything she said about Defendant, and that Defendant was not at all involved in the activity she was accused of engaging in. While her public statement could not have been more clear, as her deposition testimony further underscored, Defendant intended the world to believe that nothing Ms. Giuffre said about Defendant was true, and that Defendant was not at all involved with any of the things she was accused of, Defendant has decided in this motion to minutely dissect the nuance of Ms. Giuffre’s various statements to cause the Court to reach a far-fetched conclusion that Defendant’s insidiously false statement was somehow “substantially true.” Ironically, this repositioning amounts to nothing more than an admission by Defendant of the defamatory nature of her statement. A. When Ms. Giuffre Initially Described Her Encounters With Defendant and Epstein, She Mistakenly Believed the First Encounter Occurred During the Year 1999, Discovery has resulted in the production of records, including Ms. Giuffre’s employment records from Mar-a-Lago, which she did not possess at the time she was recounting her interactions with Defendant. Those records establish that the initial encounter wherein Defendant recruited Ms. Giuffre occurred during the year 2000 and not during 1999. Ms. Giuffre was * See McCawley Dec. at Exhibit 11, Maxwell 4-22-2016 Dep. Tr. at 135:3-4; 178:15-178:24; 179:20-180:7; 228:7229:10. s7

Case 18-2868, Document 280, 08/09/2019, 2628232, Page66 of 74 sixteen years old before August 9, 2000, and turned seventeen on that date. It is unclear from the limited records available whether Defendant approached and recruited Ms. Giuffre before or just after Ms. Giuffre’s 17th birthday. However, what has now been established through numerous witnesses is that Defendant approached and recruited a minor child for the purposes of enticing that minor over to the house of Jeffrey Epstein, a currently-registered sex offender.*! The exact lure of Ms. Giuffre by Defendant - enticement of being paid money to give a billionaire a massage at his mansion - was used by Epstein and his many associates and employees to recruit dozens and dozens of other underage girls. There is no doubt that the crux of Ms. Giuffre’s statement on this point is that Defendant recruited her when she was only a minor child unable to consent to sex, not precisely how far under the age of consent she was. Defendant’s public claim that Ms. Giuffre’s account of this approach, and recruiting element, was “untrue” and “obvious lies” is not “substantially true,” but is itself an obvious lie — as Ms. Giuffre will prove to the jury at trial. B. Defendant’s January 2015 Statement Claiming as “Untrue” and an “Obvious Lie” the Allegation That She Regularly Participated in Epstein’s Sexual Exploitation of Minors and That the Government Knows Such Fact is Not Substantially True But Instead Completely False. Defendant next argues that she “accurately denied that [she] ‘regularly participate[d] in Epstein’s sexual exploitation on minors’ and that ‘the Government knows such fact.’”” MSJ at 58. It is not clear whether Defendant is nitpicking this statement by contesting whether she “regularly” participated in Epstein’s sexual exploitation or whether she did participate, but the Government was unaware of the extent of her involvement. Call this the “yes-I’m-a-sextrafficker-but-only-on-Tuesdays-and-Thursdays” defense — here again, to simply recount the claim is to see its absurdity. *! See McCawley Dec. at Exhibit 1, 5, Alessi Dep. Tr. at 94:24-95:2; Giuffre Dep. Tr. at 111:12-111:21; 116:19117:12. 58

Case 18-2868, Document 280, 08/09/2019, 2628232, Page67 of 74 Contrary to Defendant’s misleading, cherry-picked fragments of information she has chosen to use to support her point, there is an abundance of evidence clearly linking Defendant to Epstein’s sexual exploitation of minors. As the Court is aware, numerous message pads were recovered from Epstein’s home indicating Defendant’s involvement in and knowledge of Epstein’s illegal exploitation. oe Additionally, numerous employees and others have testified about Defendant’s high-ranking position in the hierarchal structure of the sexual exploitation scheme. ™ In fact, multiple individuals, in addition to the Ms. Giuffre, have testified about Maxwell’s involvement in the exploitation of minors, including Ms. Giuffre.** Defendant also argues that one government investigator, Palm Beach, Florida, Detective Recarey, may not have been aware of her involvement in the sex trafficking. Defendant fails to cite another passage in Detective Recarey’s deposition, where he noted that he was aware of Defendant’s involvement with Epstein and the sexual exploitation of children.** But even assuming Recarey was unaware (which Ms. Giuffre strongly disputes), Defendant would have, at most, a “‘yes-I’m-a-sex-trafficker-but-I-successfully-hid-it-from-one-of-the-cops” defense — again, not a likely claim. More broadly, Ms. Giuffre’s statement about what the “Government” knew about sex trafficking was made in pleadings filed in a federal Court case attacking the decision of the U.S. Attorney’s Office for the Southern District of Florida to offer Jeffrey Epstein immunity from prosecution for federal sex trafficking crimes. Accordingly, to present an even arguable claim for summary judgment, Defendant would have to show that the U.S. Attorney’s Office (and its See, e.g., McCawley Dec at Exhibit 28 (message pad excerpts), GIUFFRE 001412, 001418, 001435, 001446, 001449, 001453, 001454. See McCawley Dec. at Exhibit 21, 1, Rodriguez Dep. Tr. at 169:1-169:4; Alessi Dep. Tr. at 23:11-23:20; 34:1935:3; 98:5-98:12; 104:15-104:23. » See McCawley Dec. at Exhibit 16, 4, Sjoberg Dep. Tr. at 13; Figueroa Dep. Tr. at 96-97; 103; 200:6-18; 228:2329:21. %§ See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 29:16-29:20; 45:13-25; 83:3-83:15. 59

Case 18-2868, Document 280, 08/09/2019, 2628232, Page68 of 74 investigators from the FBI) did not know about Defendant’s sex trafficking. This proof would need to include, for example, evidence that the FBI did not learn about Defendant’s sex trafficking when (among other things) Ms. Giuffre told FBI agents about it when she met with them in Australia in 2011. Here again, Defendant has no evidence to even begin making such a showing. c Defendant’s January 2015 Statement Claiming as “Untrue” or an “Obvious Lie” That Maxwell and Epstein Converted Ms. Giuffre Into a Sexual Slave is Not Substantially True. Defendant next argues that she accurately disputed Ms. Giuffre’s statement that Defendant held her as a “sex slave.” Relying on dictionary definitions of “slave” that define the term to refer to a “confined” person who is the “legal property” of another (MSJ at 59, citing Merriam-Webster, etc.), Defendant claims Ms. Giuffre was not confined or the property of Defendant. Call this the “yes-I’m-a-sex-trafficker-but-I-didn’t-use-chains” defense. And, once again, to even describe the defense is to refute it. Defendant does not explain why the jury would be required to use the held-in-chains definition of “slave” in evaluating her statement. Merriam-Webster (11" ed. 2006) also defines “slave” as “one that is completely subservient to a dominating influence” — a definition that fits Ms. Giuffre’s circumstances to a tee. As Ms. Giuffre has explained in detail, she was recruited as a minor child by Defendant, who then dominated her and used for sexual purposes. That testimony alone creates a genuine issue of fact on this point. From the context of all of Ms. Giuffre’s statements about Defendant, Ms. Giuffre has never said or implied that she was physically placed in a cage. Instead, she has described the vast disparity of power and the influence of Defendant and Epstein, the fear of disobedience, the typical locations of the abuse being in a private plane, in huge mansion manned with Epstein employed servants, a private island, or some inescapable place abroad in the presence of 60

Case 18-2868, Document 280, 08/09/2019, 2628232, Page69 of 74 Defendant, in addition to the continued — and fraudulent — promise of a better future, as those things that kept her retained in a situation of sexual servitude. While not physical chained, Ms. Giuffre was groomed as minor and trained, and these factors became her invisible chains. Indeed, as Ms. Giuffre’s expert on sex trafficking, Professor Coonan, has explained: Popular understandings of the term “sex slave” might still connote images of violent pimps, white slavery, or of victims chained to a bed in a brothel in the minds of some people. To call Ms. Giuffre a victim of sex trafficking would however very accurately convey the reality that she along with a great many other victims of contemporary forms of slavery are often exploited by the “invisible chains” of fraud and psychological coercion. See McCawley Dec. at Exhibit 23, Coonan Expert Report at 20. If the Court takes as true, which it must for the purpose of this motion, that Ms. Giuffre was trafficked and used exclusively for sexual purposes by Defendant and Epstein, then the Court must also reach the conclusion at this stage that Maxwell’s assertion — that Ms. Giuffre’s description of being a sex slave is “untrue” or “obvious lies” — is not substantially true. There undoubtedly remains a genuine issue of material fact on this point, and in fact, Defendant’s position taken in this motion is tantamount to an admission of the truth of Plaintiff's statement about Defendant on this point. D. Any Statement of Misdirection Regarding Professor Alan Dershowitz is Nothing More Than an Irrelevant Distraction to The Facts of This Case and Matters Not on the Defense of Whether Defendant’s Statement Was Substantially True. Defendant next contends that she accurately recounted that Alan Dershowitz had denied having sex with Ms. Giuffre. MSJ at 60. Call this the “yes-I’m-a-sex-trafficker-but-she-was-nottrafficked-to-the-professor” defense. While it is accurate that Ms. Giuffre made allegations against Professor Dershowitz, those allegations are not at issue in this case. Defendant, in her defamatory statement, claimed that “the allegations made by [Ms. Giuffre] against Ghislaine Maxwell are untrue.” See McCawley Dec. at Exhibit 26, GM_00068. In her deposition, 61

Case 18-2868, Document 280, 08/09/2019, 2628232, Page70 of 74 Defendant maintained the position that she “cannot speculate on what anybody else did or didn’t do.” See McCawley Dec. at Exhibit 11, Maxwell 4-22-2016 Dep. Tr. at 180:3-180:4. In fact, regarding Ms. Giuffre’s claims about others, Defendant unequivocally stated, “I can only testify to what she said about me, which was 1000 percent false.” See McCawley Dec. at Exhibit 11, Maxwell 4-22-2016 Dep. Tr. at 228:10-228:12. Defendant Maxwell makes additional misstatements about Dershowitz’s production in a defamation action filed against him in her desperate attempt to have Dershowitz to jump aboard and help bail out her sinking canoe. While Ms. Giuffre can — and, if necessary, will — refute Dershowitz’s claim he was not a beneficiary of Epstein and Defendant’s sex trafficking, that is not relevant at this stage. Whatever may or may not have happened with Dershowitz (and Ms. Giuffre’s sworn statements that he sexually abused her is alone enough to create disputed facts on the issue of whether Defendant’s statements about him were “substantially true”) has no bearing whatsoever on the truth or falsity of the statements Ms. Giuffre made about Defendant. This case is not about whether Ms. Giuffre has ever made untruthful allegations against anyone, which she contends she has not, but about whether her allegations about Defendant were true, or whether those specific allegations were “untrue,” “obvious lies” as Defendant publicly proclaimed. These issues are disputed and must go to the jury. E. Contrary to Defendant’s Position, There is a Genuine Issue of Material Fact as to Whether She Created or Distributed Child Pornography, or Whether the Government Was Aware of Same. Defendant next argues that she did not create child pornography and that the Government knew this. Call this the “until-you-find-the-photos-I’ m-innocent” defense. Of course, as noted earlier, Defendant’s claim requires that she show that “the Government” — in context, the FBI and the U.S. Attorney’s Office for the Southern District of Florida — “knew” that she had no 62

Case 18-2868, Document 280, 08/09/2019, 2628232, Page71 of 74 child pornography. Yet Defendant has offered no such evidence — much less evidence so powerful as to warrant summary judgment on this point. This point is disputed from the simple fact that Ms. Giuffre herself testified that Defendant took many photograph of her naked. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 232:3-9; 233:7-9. This is consistent with the Palm Beach butler’s, Alfredo Rodriguez’s, testimony that he personally saw photos of naked children on Defendant’s computer. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at 150:10-17; 306:1-306:24. Another housekeeper, Juan Alessi also saw photos of young nude females on Defendant’s computer, although he wasn’t sure whether to consider it pornography. See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 175:5-175:24. Finally, Detective Recarey found a collage of nude photos of young females in Epstein’s closet, and turned the photos over to the FBI and U.S. Attorney’s office.*° While the U.S. Attorney’s office will not share the photos obtained from Recarey’s investigation, it is thus undisputed that the government possesses photos of nude, young females confiscated from Epstein’s Palm Beach mansion. Indeed, the police video disclosed through a FOIA request shows naked images of women throughout the house, including a full nude of the Defendant.*’ At a minimum, there is a clear genuine issue of material fact in this regard. F. Defendant Did Act as a “Madame” For Epstein to Traffic Ms. Giuffre to The Rich and Famous. Defendant next argues that she did not act as a “Madame” for Epstein. MSJ at 63. The gist of the argument seems to be that Defendant believes trafficking one girl to Epstein does not a Madame make. Call this the “yes-I-was-Virginia’s-Madame-but-no-one-else’s” defense. This argument fails linguistically on the very dictionary definitions that Defendant cites elsewhere — * See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 73:19-73:24; 74:2-74:7. *” See McCawley Dec. at Exhibit 44, FOIA CD GIUFFRE 007584. 63

Case 18-2868, Document 280, 08/09/2019, 2628232, Page72 of 74 but not here. See Merriam-Webster (1 1" ed. 2006) (defining “madam” as “the female head of a house of prostitution”). Once again, Defendant conceals the relevant facts on this issue. First, multiple witnesses have testified to Defendant’s recruiting, maintaining, harboring, and trafficking girls for Epstein.** In fact, Defendant herself was unable to deny procuring Ms. Giuffre for Epstein.” While Defendant has attempted to fumble her way through explaining some plausible reason for bringing a sixteen or seventeen year old to Epstein, her explanations are, to put it blandly, unpersuasive. As with other issues, the jury will have to decide who to believe. One of the individuals Ms. Giuffre was trafficked to was Prince Andrew — trafficking that took place in Defendant’s own townhouse in London. There exist flight logs evidencing Ms. Giuffre flying to London alongside Defendant and Epstein on Epstein’s private plane, and a photo of Ms. Giuffre, Defendant, and the Prince, without Defendant ever offering a legal reasonable explanation for that photo being taken, or for traveling with a year old girl overseas. Defendant begins to meander somewhat aimlessly on this point, shifting Plaintiff's burden to substantiate Plaintiff's claim that Defendant was Epstein’s Madame, which is a point at issue, into whether or not Plaintiff has conclusively proven the identities and accurate job titles of the other men to whom Plaintiff was lent for sex by Epstein. No matter how hard Defendant tries to reframe this case, drag other people in, or split hairs, she is unable to contest the facts — facts showing she was more than a Madame but a full-fledged sex trafficker. Ms. Giuffre told the truth when she said that Defendant recruited her as a minor, under the pretense of giving a ** See McCawley Dec. at Exhibit 16, 1, 18, 2, Sjoberg Dep. Tr. at 13; Alessi Dep. Tr. at 34; GIUFFRE000105 at 5758; GIUFFRE000241-242 at p. 212-213; Austrich Dep. Tr. at 34-35, 100-101, 127-128; Alessi Dep. Tr. at 34:1935:3; 98:5-98:12; 104:15-104:23. * See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 214:14-215:3. 64

Case 18-2868, Document 280, 08/09/2019, 2628232, Page73 of 74 massage, and converted her into a traveling sex slave, consistent with Defendant and Epstein’s pattern and practice. As the Court astutely acknowledged early on, “at the center of this case is the veracity of a contextual world of facts more broad than the allegedly defamatory statements . . . either transgression occurred or it did not. Either Maxwell was involved or she was not.” If Defendant was involved, then her January 2015 statement was defamatory. Ms. Giuffre will prove to the jury, through overwhelming evidence, her prior allegations about Defendant’s involvement. The Court should give Ms. Giuffre that opportunity, and deny Defendant’s motion for summary judgment. Ix. CONCLUSION For the foregoing reasons, this Court should deny Defendant’s motion for summary judgment in all respects. Dated: January 31, 2017 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 65

Case 18-2868, Document 280, 08/09/2019, 2628232, Page74 of 74 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-5202 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 31, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10" Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmflaw.com jpagliuca@hmflaw.com /s/ Sigrid S. McCawley Sigrid S. McCawley © This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. 66

Case 18-2868, Document 281, 08/09/2019, 2628234, Pagel of 66 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. SOUTHERN DISTRICT OF NEW YORK LOCAL RULE 56.1 PLAINTIFF’S STATEMENT OF C STED FACTS AND PLAINTIFF’S UNDISPUTED FACTS DEFENDANT’S PURPORTED FACTS A Ms. Maxwell’s response to publications of Ms. Giuffre’s false allegations: the March 2011 statement. In early 2011 Ms. Giuffre in two British tabloid interviews made numerous false and defamatory allegations against Ms. Maxwell. In the articles, Ms. Giuffre made no direct allegations that Ms. Maxwell was involved in any improper conduct with Jeffrey Epstein, who had pleaded guilty in 2007 to procuring a minor for prostitution. Nonetheless, Ms. Giuffre suggested that Ms. Maxwell worked with Epstein and may have known about the crime for which he was convicted. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre denies that the allegations she made against Ms. Maxwell are false. Furthermore, Ms. Giuffre did give an interview to journalist, Sharon Churcher, in which Ms. Giuffre accurately and truthfully described Defendant Maxwell's role as someone who recruited or facilitated the recruitment of young females for Jeffrey Epstein. See McCawley Dec. at Exhibit 34, GIUFFRE003678. Ms. Giuffre was also interviewed by the FBI in 2011 and she discussed Defendant’s involvement in the sexual abuse. See McCawley Dec. at Exhibit 31, FBI Redacted 302, FIUFFRE001235-1246. Those statements were not "false and defamatory," but instead truthful and accurate.

Case 18-2868, Document 281, 08/09/2019, 2628234, Page2 of 66 DEFENDANT’S PURPORTED FACTS 2. In the articles, Ms. Giuffre alleged she had sex with Prince Andrew, “a well-known businessman,” a “world-renowned scientist,” a “respected liberal politician,” and a “foreign head of state.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre does not contest this fact, but believes that it is irrelevant. DEFENDANT’S PURPORTED FACTS 3. In response to the allegations Ms. Maxwell’s British attorney, working with Mr. Gow, issued a statement on March 9, 2011, denying “the various allegations about [Ms. Maxwell] that have appeared recently in the media. These allegations are all entirely false.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre denies that Mr. Barden, “issued a statement.” Instead it appears to have the contact as Ross Gow and a reference to Devonshire Solicitors. DEFENDANT’S PURPORTED FACTS 4. The statement read in full: Statement on Behalf of Ghislaine Maxwell By Devonshires Solicitors, PRNE Wednesday, March 9, 2011 London, March 10, 2011 - Ghislaine Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are all entirely false. It is unacceptable that letters sent by Ms. Maxwell’s legal representatives to certain newspapers pointing out the truth and asking for the allegations to be withdrawn have simply been ignored. In the circumstances, Ms. Maxwell is now proceeding to take legal action against those newspapers. “T understand newspapers need stories to sell copies. It is well known that certain newspapers live by the adage, “why let the truth get in the way of a good story.” However, the allegations made against me are abhorrent and entirely untrue and I ask that they stop,” said Ghislaine Maxwell. “A number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name,” she said.

Case 18-2868, Document 281, 08/09/2019, 2628234, Page3 of 66 Media contact: Ross Gow Acuity Reputation Tel: +44-203-008-7790 Mob: +44-7778-755-251 Email: ross@acuityreputation.com Media contact: Ross Gow, Acuity Reputation, Tel: +44-203-008-7790, Mob: +44-7778-755-251, Email: ross at acuityreputation.com GIUFFRE001067-68 MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS The document speaks for itself although it is unclear if the original included the italics that are inserted by the Defendant above. DEFENDANT’S PURPORTED FACTS 5. Ms. Giuffre’s gratuitous and “lurid” accusations in an unrelated action. In 2008 two alleged victims of Epstein brought an action under the Crime Victims’ Rights Act against the United States government purporting to challenge Epstein’s plea agreement. They alleged the government violated their CVRA rights by entering into the agreement. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS While we would stipulate to the statement in this paragraph starting with the words “In 2008” , we do not stipulate to the opening sentence fragment Maxwell places in bold. DEFENDANT’S PURPORTED FACTS 6. Seven years later, on December 30, 2014, Ms. Giuffre moved to join the CVRA action, claiming she, too, had her CVRA rights violated by the government. On January 1, 2015, Ms. Giuffre filed a “corrected” joinder motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Agreed. DEFENDANT’S PURPORTED FACTS 7. The issue presented in her joinder motion was narrow: whether she should be permitted to join the CVRA action as a party under Federal Rule of Civil Procedure 21, specifically, whether she was a “known victim[] of Mr. Epstein and the Government owed them CVRA duties.” Yet, “the bulk of the [motion] consists of copious factual details that [Ms. Giuffre] and [her co-movant] ‘would prove . . . if allowed to join.”” Ms.

Case 18-2868, Document 281, 08/09/2019, 2628234, Page4 of 66 Giuffre gratuitously included provocative and “lurid details” of her alleged sexual activities as an alleged victim of sexual trafficking. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre denies that the issues presented in here joinder motion were narrow. The issues presented by the joinder motion and related pleadings were multiple and complex, requiring numerous details about Ms. Giuffre’s sexual abuse and the perpetrators of her abuse. In a pleading explaining why the motion was filed, Ms. Giuffre’s lawyers specifically listed nine separate reasons why Jane Doe 3’s allegations that Dershowitz had sexually abused her were relevant to the case and appropriately included in the relevant filings: 1. To establish that Jane Doe 3 had been sexually abused by Jeffrey Epstein and his co-conspirators (including co-conspirator Alan Dershowitz), which would make her a “victim” of a broad sex trafficking conspiracy covered by the federal Crime Victims’ Rights Act, 18 U.S.C. § 3771, and therefore entitled to participate in the case; 2. To support then-pending discovery requests that asked specifically for information related to contacts by Dershowitz with the Government on behalf of Jeffrey Epstein; 3. To support the victims’ allegation that the Government had a motive for failing to afford victims with their rights in the criminal process — specifically, pressure from Dershowitz and other members of Epstein’s legal defense team to keep the parameters of the non-prosecution agreement (NPA) secret to prevent Jane Doe 3 and other victims from objecting to and blocking judicial approval of the agreement; 4. To establish the breadth of the NPA’s provision extending immunity to “any potential co-conspirators of Epstein” and the scope of the remedy that the victims (including not only Jane Doe 3 but also other similarly-situated minor victims who had been sexually abused by Dershowitz) might be able to obtain for violations of their rights; 5. To provide part of the factual context for the scope of the “interface” between the victims, the Government, and Epstein’s defense team — an interface that was relevant under Judge Marra’s previous ruling that the Government was entitled to raise “a fact-sensitive equitable defense which must be considered in the factual context of the entire interface between Epstein, the relevant prosecutorial authorities and the federal offense victims . . .”;

Case 18-2868, Document 281, 08/09/2019, 2628234, Paged of 66 6. To prove the applicability of the “crime/fraud/miscon duct” exception to the attorney-client privilege that was being raised by the Government in opposition to the victims’ motion for production of numerous documents; 7. To bolster the victims’ argument that their right “to be treated with fairness,” 18 U.S.C. § 3771(a)(8), had been violated through the Government’s secret negotiations with one of their abusers; 8. To provide notice and lay out the parameters of potential witness testimony for any subsequent proceedings or trial — i.e., the scope of the testimony that Jane Doe 3 was expected to provide in support of Jane Doe | and Jane Doe 2, the already-recognized Ms. Giuffre in the action; and 9. To support Jane Doe 3’s argument for equitable estoppel to toll the sixyear statute of limitations being raised by the Government in opposition to her motion to join — i.e., that the statute was tolled while she was in hiding in Australia due to the danger posed by Epstein and his powerful friends, including prominent lawyer Alan Dershowitz. Jane Does #1 and #2 v. United States, No. 9:08-cv-80736, DE 291 at 18-26 & n.17 (S.D. Fla. 2015). Ms. Giuffre’s lawyers had attempted to obtain a stipulation from the Government on point #1 above (“victim” status), but the Government had declined. Judge Marra’s ruling concluded that certain allegations were not necessary “at this juncture in the proceedings.” DE 324 at 5. Judge Marra specifically added, however, that “Jane Doe 3 is free to reassert these factual details through proper evidentiary proof, should Petitioners demonstrate a good faith basis for believing that such details are pertinent to a matter presented for the Court’s consideration.” DE 324 at 6. The CVRA litigation continues and no trial has been held as of the filing of this brief. As such, the extent to which these factual details will be used at trial has not yet been determined. See Docket Sheet, Jane Does #1 and #2 v. U.S., No. 9:08-cv-80736. DEFENDANT’S PURPORTED FACTS 8. At the time they filed the motion, Ms. Giuffre and her lawyers knew that the media had been following the Epstein criminal case and the CVRA action. While they deliberately filed the motion without disclosing Ms. Giuffre’s name, claiming the need for privacy and secrecy, they made no attempt to file the motion under seal. Quite the contrary, they filed the motion publicly.

Case 18-2868, Document 281, 08/09/2019, 2628234, Page6 of 66 MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. DEFENDANT’S PURPORTED FACTS 9. As the district court noted in ruling on the joinder motion, Ms. Giuffre “name[d] several individuals, and she offers details about the type of sex acts performed and where they took place.” The court ruled that “these lurid details are unnecessary”: “The factual details regarding whom and where the Jane Does engaged in sexual activities are immaterial and impertinent . . ., especially considering that these details involve nonparties who are not related to the respondent Government.” Accordingly, “[t]hese unnecessary details shall be stricken.” /d. The court then struck all Ms. Giuffre’s factual allegations relating to her alleged sexual activities and her allegations of misconduct by non-parties. The court said the striking of the “lurid details” was a sanction for Ms. Giuffre’s improper inclusion of them in the motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. DEFENDANT’S PURPORTED FACTS 10. The district court found not only that the “lurid details” were unnecessary but also that the entire joinder motion was “entirely unnecessary.” Ms. Giuffre and her lawyers knew the motion with all its “lurid details” was unnecessary because the motion itself recognized that she would be able to participate as a fact witness to achieve the same result she sought as a party. The court denied Ms. Giuffre’s joinder motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. DEFENDANT’S PURPORTED FACTS 1d, One of the non-parties Ms. Giuffre “named” repeatedly in the joinder motion was Ms. Maxwell. According to the “lurid details” of Ms. Giuffre included in the motion, Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by Epstein: = Ms. Maxwell “approached” Ms. Giuffre in 1999 when Ms. Giuffre was “fifteen years old” to recruit her into the scheme. = Ms. Maxwell was “one of the main women” Epstein used to “procure under-aged girls for sexual activities.” = Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme.

Case 18-2868, Document 281, 08/09/2019, 2628234, Page7 of 66 = She “persuaded” Ms. Giuffre to go to Epstein’s mansion “in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children.” = At the mansion, when Ms. Giuffre began giving Epstein a massage, he and Ms. Maxwell “turned it into a sexual encounter.” = Epstein “with the assistance of’ Ms. Maxwell “converted [Ms. Giuffre] into...a “sex slave.’” Jd. Ms. Giuffre was a “sex slave” from “about 1999 through 2002.” = Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.” = Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea agreement, because the immunity protected her from prosecution “for the crimes she committed in Florida.” = Ms. Maxwell “participat[ed] in the sexual abuse of [Ms. Giuffre] and others.” = Ms. Maxwell “took numerous sexually explicit pictures of underage girls involved in sexual activities, including [Ms. Giuffre].” /d. She shared the photos with Epstein. = As part of her “role in Epstein’s sexual abuse ring,” Ms. Maxwell “connect[ed]” Epstein with “powerful individuals” so that Epstein could traffic Ms. Giuffre to these persons. = Ms. Giuffre was “forced to have sexual relations” with Prince Andrew in = “[Ms. Maxwell’s] apartment” in London. Ms. Maxwell “facilitated” Ms. Giuffre’s = sex with Prince Andrew “by acting as a ‘madame’ for Epstein.” = Ms. Maxwell “assist[ed] in internationally trafficking” Ms. Giuffre and “numerous other young girls for sexual purposes.” = Ms. Giuffre was “forced” to watch Epstein, Ms. Maxwell and others “engage in illegal sexual acts with dozens of underage girls.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. Ms. Giuffre contests the reference to “lurid details”. Moreover, the testimony from numerous witnesses corroborates the statements Ms. Giuffre made in her joinder motion. See below. e See McCawley Dec. at Exhibit 16, Sjoberg’s May 18, 2016 Dep. Tr. at 8-9, 13, 33-35, 142-143 e See McCawley Dec. at Exhibit 4, Figueroa June 24, 2016 Dep. Tr. Vol. 1 at 96-97 and 103 e See McCawley Dec. at Exhibit 14, Rinaldo Rizzo’s June 10, 2016 Dep. Tr. at 52-60 e See McCawley Dec. at Exhibit 12, Lynn Miller’s May 24, 2016 Dep. Tr. at 115 e See McCawley Dec. at Exhibit 13, Joseph Recarey’s June 21, 2016 Dep. Tr. at 29-30

Case 18-2868, Document 281, 08/09/2019, 2628234, Page8 of 66 See McCawley Dec. at Exhibit 15, David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36 Exhibit 2 Excerpted Rodgers Dep. Ex. | at flight #s 1433-1434, 1444-1446, 1464-1470, 1478-1480, 1490-1491, 1506, 1525-1526, 1528, 1570 and 1589 See McCawley Dec. at Exhibit 10, Marcinkova Dep. Tr. at 10:18-21; 12:11-15; etc. See McCawley Dec. at Exhibit 8, Kellen Dep. Tr. at 15:13-18; 20:12-16; etc. Epstein Dep. Tr. at 116:10-15; 117:18-118:10; ete. See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 28, 52-54 See McCawley Dec. at Exhibit 30, U.S. Attorney Victim Notification Letter GIUFFRE002216-002218 See McCawley Dec. at Exhibit 33, July 2001 New York Presbyterian Hospital Records GIUFFRE003258-003290 J See McCawley Dec. at Exhibit 38, Judith Lightfoot psychological records GIUFFRE00543 1-005438 See McCawley Dec. at Exhibit 28, Message Pad evidencing Defendant arranging to have underage girls and young women come to Epstein’s home GIUFFRE001386-001571 See McCawley Dec. at Exhibit 29, Black Book in which Defendant and other household staff maintained a roster of underage girls includin, i i a. who were minors at the time the Palm Beach Police’s Investigation of Jeffrey Epstein GIUFFRE001573-00669 See McCawley Dec. at Exhibit 40, Sex Slave books Epstein ordered from Amazon.com at GIUFFRE006581 See McCawley Dec. at Exhibit 32, the folder Defendant sent to Thailand with Ms. Giuffre bearing Defendant’s phone number GIUFFRE003191-003192

Case 18-2868, Document 281, 08/09/2019, 2628234, Page9 of 66 e See McCawley Dec. at Exhibit 39, the Palm Beach Police Report showing that Epstein used women and girls to collect underage girls for his abuse GIUFFRE005614-005700 e See McCawley Dec. at Exhibit 41, Epstein’s Flight Logs showing that Defendant flew with Ms. Giuffre 23 times GIUFFRE007055-007161 DEFENDANT’S PURPORTED FACTS 12. In the joinder motion, Ms. Giuffre also alleged she was “forced” to have sex with Harvard law professor Alan Dershowitz, “model scout” Jean Luc Brunel, and “many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Response to Point #7 and 11, above. DEFENDANT’S PURPORTED FACTS 13. Ms. Giuffre said after serving for four years as a “sex slave,” she “managed to escape to a foreign country and hide out from Epstein and his co-conspirators for years.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Agreed that Ms. Giuffre made this statement and has since discovered evidence that indicates she was mistaken on the exact timeframe of her abuse and was with Defendant and Jeffrey Epstein from the years 2000 — 2002. DEFENDANT’S PURPORTED FACTS 14. Ms. Giuffre suggested the government was part of Epstein’s “conspiracy” when it “secretly” negotiated a non-prosecution agreement with Epstein precluding federal prosecution of Epstein and his “co-conspirators.” The government’s secrecy, Ms. Giuffre alleged, was motivated by its fear that Ms. Giuffre would raise “powerful objections” to the agreement that would have “shed tremendous public light on Epstein and other powerful individuals. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre did not suggest that the Government was part of Epstein's conspiracy to commit sex offenses. The CVRA case deals with whether the Government failed in their responsibilities to the victims to inform the victims that the Government was working out a NPA,

Case 18-2868, Document 281, 08/09/2019, 2628234, Page10 of 66 and it is Ms. Giuffre's belief that the Government did fail to so inform the victims, and intentionally did not inform the victims because the expected serious objection from many of the victims might prevent the Government from finalizing a NPA with Epstein. See McCawley Dec. at Exhibit 50, Joinder Motion (GIUFFRE00319-00333). DEFENDANT’S PURPORTED FACTS 15. Notably, the other “Jane Doe” who joined Ms. Giuffre’s motion who alleged she was sexually abused “many occasions” by Epstein was unable to corroborate any of Ms. Giuffre’s allegations. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This is untrue. The other Jane Doe could corroborate many of Ms. Giuffre's allegations based on a similar pattern of abuse that she suffered by Epstein. She did not know Ms. Giuffre though. a. who was deposed in this case, and who was a minor, corroborates the same pattern of abuse. See McCawley Dec. at Exhibit 7, ef Dep. Tr. at 54:25-57:5. DEFENDANT’S PURPORTED FACTS 16. Also notably, in her multiple and lengthy consensual interviews with Ms. Churcher three years earlier, Ms. Giuffre told Ms. Churcher of virtually none of the details she described in the joinder motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This is untrue. Furthermore, Defendant does not offer any citation or evidence on this point. Defendant's statement here is knowingly false. Having read the articles and taken Ms. Giuffre's deposition, Defendant knows that Ms. Giuffre did reveal details in 2011 consistent with those in the joinder motion. See McCawley Dec. at Exhibit 31, GIUFFRE003678, FBI Redacted 302, GIUFFRE001235-1246. DEFENDANT’S PURPORTED FACTS 17. Ms. Maxwell’s response to Ms. Giuffre’s “lurid” accusations: the January 2015 statement. As Ms. Giuffre and her lawyers expected, before District Judge Marra in the

Case 18-2868, Document 281, 08/09/2019, 2628234, Page11 of 66 CVRA action could strike the “lurid details” of Ms. Giuffre’s allegations in the joinder motion, members of the media obtained copies of the motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. DEFENDANT’S PURPORTED FACTS 18. At Mr. Barden’s direction, on January 3, 2015, Mr. Gow sent to numerous representatives of British media organizations an email containing “a quotable statement on behalf of Ms. Maxwell.” The email was sent to more than 6 and probably less than 30 media representatives. It was not sent to non-media representatives. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Defendant falsely claims that “[a]t Mr. Barden’s direction, on January 3, 2015, Mr. Gow sent to numerous representatives of British media organizations an email containing ‘a quotable statement on behalf of Ms. Maxwell.’” This is a blatant falsehood about the document that is at the heart of this litigation. Record evidence shows that Gow sent that email at Defendant’s direction, not at Mr. Barden’s direction. Indeed, on the evening before his deposition, Mr. Gow produced an email exchange he had with Defendant in which Defendant directs Mr. Gow to send the press statement. It is as follows: From: G Maxwell <GMax1@elimax.com> Date: Fri, 2 Jan 2015 20:14:53 +0000 To: Ross Gowcross@acuityreputation.com> Ce: Philip Barden<philip.barden@devonshires.co.uk> Subject: FW: URGENT - this is the statement Jane Doe 3 is Virginia Roberts so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts that Alan Derschwitz is involved in having Sexual relations with her, which he denies Ms Roberts claims are Obvious lies and should be treated as such and not publicised as news, as they are defamatory.

Case 18-2868, Document 281, 08/09/2019, 2628234, Page12 of 66 Chronologically, this email comes at the end of various other email exchanges between Defendant and Gow that discuss issuing a press release. The subject line of this email that Defendant wrote to Gow states “URGENT ~ this is the statement,” thereby instructing Gow to release this statement to the press. Shortly after Defendant sent this email to Gow directing him to release the statement, Gow distributed the statement to multiple media outlets. Neither Defendant nor Gow have produced any email in which Barden directed Gow to issue this press release (nor can they). Despite sending it herself, and despite it being responsive to six court-ordered search terms, Defendant failed to produce this email. Her press agent, Gow, produced this the evening before his deposition on November 17, 2016. At the deposition, Mr. Gow authenticated this email and confirmed that Defendant authorized the statement: Q. When you sent that email were you acting pursuant to Ms. Maxwell's retention of your services? A. Yes, I was. ae (Exhibit 9 was marked for identification.) Q. This also appears to be an email chain with you and Ms. Maxwell; is that correct? A. It does appear to be so. Q. Did you send the top email of the chain that says "Okay, G, going with this"? A. I did. Q. And did you receive from Ms. Maxwell, the bottom email of that chain? A. I believe so. Well, I believe -- yes, yeah, it was forwarded from Ms. Maxwell, yes. MR. DYER: Sorry, I don't quite understand that answer. THE WITNESS: I misspoke that. I did receive it from Ms. Maxwell. MR. DYER: Okay. Q. The subject line does have “FW” which to me indicates it’s a forward. Do you know where the rest of this email chain is? A. My understanding of this is: It was a holiday in the UK, but Mr. Barden was not necessarily accessible at some point in time, so this had been sent to him originally by Ms. Maxwell, and because he was unavailable, she forwarded it to me for immediate action. I therefore respond, “Okay, Ghislaine, I’ll go with this.” It is my understanding that this is the agreed statement because the subject of the second one is “Urgent, this is the statement” so I take that as an instruction to send it out, as a positive command: “This is the statement.”

Case 18-2868, Document 281, 08/09/2019, 2628234, Page13 of 66 See McCawley Decl. at Exhibit 6, November 18, 2016, Ross Gow Dep. Tr. at 14:15-17; 44:645:13. Together, the email and Gow’s testimony unequivocally establish that Defendant — not Barden — directed and “command{ed]” Gow to publish the defamatory statement. Accordingly, the first sentence of Defendant’s Paragraph 18 is false. The second sentence — “This email was sent to more than 6 and probably less than 30 media representatives” — omits the fact that not only did Gow admit to emailing the statement to the press, but he also read it to over 30 media representatives over the phone: Q. Do you recall ever reading the statement to the press or the media over the phone? A. It's very possible that I would have done so, yes. See McCawley Decl. at Exhibit 6, Gow Dep. Tr. at 66:2-25. Q. Do you -- do you remember discussing that with The Guardian? A. No, I don't. I'm not saying I didn't but I can't recall. You have to bear in mind, if you'd be so kind, that I've been speaking to over 30 journalists and media outlets about this, and I can't recall every single -- the detail of every single conversation. See McCawley Decl. at Exhibit 6, Gow Dep. Tr. at 64:8-14 (emphasis added). Thus, the second sentence of Defendant’s Paragraph 18 is also false. DEFENDANT’S PURPORTED FACTS 19. | Among the media representatives were Martin Robinson of the Daily Mail; P. Peachey of The Independent; Nick Sommerlad of The Mirror; David Brown of The Times; and Nick Always and Jo-Anne Pugh of the BBC; and David Mercer of the Press Association. These representatives were selected based on their request—after the joinder motion was filed—for a response from Ms. Maxwell to Ms. Giuffre’s allegations in the motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre agrees to the first sentence. The second sentence is a false. Accordingly, there is no record evidence that Gow (or anyone else) “selected” journalists “for a response,” or that there was any selection process whatsoever. To the contrary, Gow testified that anyone who inquired received a reference to the January 2015 defamatory response: 13

Case 18-2868, Document 281, 08/09/2019, 2628234, Page14 of 66 Q. To the extent you can recall or could estimate, how many other emails do you believe you sent bearing that statement that's in Exhibit 2? A. I really can't remember but certainly more than six and probably less than 30, somewhere in between. Any time there was an incoming query it was either dealt with on the telephone by referring them back to the two statements of March 2011 and January 2015 or someone would email them the statement. So no one was left unanswered, broadly, is the -- is where we were. But I can't remember every single person we reached out to. See McCawley Dec at Exhibit 6 Gow Dep. Tr. at 67:15-68:1 (emphasis added). DEFENDANT’S PURPORTED FACTS 20. The email to the media members read: To Whom It May Concern, Please find attached a quotable statement on behalf of Ms. Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts—so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by Ms. Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms. Roberts claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory. Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS

Case 18-2868, Document 281, 08/09/2019, 2628234, Page15 of 66 While Defendant cropped the body text of the email that was sent to news media representatives, she completely omitted the headings and metadata. Ms. Giuffre has put an image of the email below in Ms. Giuffre’s Paragraph. See GM_00068. From; <ross@acuityreputation, com> Date: 2 January 2015 at 20:38 Subject: Ghislaine Maxwell To: Rossacuity Gow <ross@acuityreputation.com> bcc: martin.robinson@mailonline.co.uk, P.Pea in indent.co.uk, nick.sommertad@mirror.co.uk, david brown @thetimes.co.uk, nic bi u! To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 Roberts - so not a new individual. The allegations made by, a Roberts agaiMstGhislaine Maxwell are untrue. The original allegations are not newand have been fully responded to and shown to be untrue. Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts that Alan Derschowitz is involved in having sexual relations with her, which he denies, Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory, Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. Sent from my BlackBerry® wireless device DEFENDANT’S PURPORTED FACTS 15

Case 18-2868, Document 281, 08/09/2019, 2628234, Page16 of 66 21. Mr. Barden, who prepared the January 2015 statement, did not intend it as a traditional press release solely to disseminate information to the media. So he intentionally did not pass it through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Defendant states: “Mr. Barden, who prepared the statement, did not intend it as a traditional press release solely to dissemination information to the media.” Ms. Giuffre contests this statement, and all statements regarding Mr. Barden’s beliefs and purposes, and the like. Further, as stated in detail in Ms. Giuffre’s Opposition Defendant’s Motion for Summary Judgment, this Court should not even consider the Barden Declaration. Additionally, there is absolutely no record evidence of Barden’s intent and the Court should not consider it. The next sentence states, “So he intentionally did not pass it [the press release] through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation.” Again, there is zero record evidence to support any assertion of Barden’s intent. To the extent that this sentence claims that Barden did not give the statement to Gow, Ms. Giuffre does not dispute it; as described above, Defendant gave the statement to Gow with instructions to publish it. See McCawley Dec. at Exhibit 48, RG(UK)_000009, imaged in full at paragraph 81, supra. To the extent that this sentence claims that the statement did not pass “through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation,” Ms. Giuffre disputes that statement. Record documentary evidence and testimony establish that this statement was disseminated through a public relations firm, namely, Ross Gow’s firm, Acuity Reputation. See McCawley Dec. at Exhibit 6, Gow Dep. Tr. at 109:4-6 (“Q. Approximately how long have you been providing such services? A. Acuity was set up in 2010.”). DEFENDANT’S PURPORTED FACTS

Case 18-2868, Document 281, 08/09/2019, 2628234, Page17 of 66 ie) Nv The January 2015 statement served two purposes. First, Mr. Barden intended that it mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of Ms. Giuffre’s false allegations. He believed these ends could be accomplished by suggesting to the media that, among other things, they should subject Ms. Giuffre’s allegations to inquiry and scrutiny. For example, he noted in the statement that Ms. Giuffre’s allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicized as news.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre objects to this paragraph in its entirety. She disputes that the January 2015 statement “served two purposes,” as this statement is wholly unsupported by the record, which Defendant again neglects to cite. Ms. Giuffre also contests the second sentence in which Defendant claims that “Mr. Barden intended that it mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of Ms. Giuffre’s false allegations.” First, Ms. Giuffre disputes any statement of Barden’s intent as explained above. Second, Ms. Giuffre disputes that there was any “republication” by the press as a matter of law, as explained in her memorandum of law opposing summary judgment, as the press did not “republish” the press statement under New York law. Third, Ms. Giuffre disputes that her allegations are “false,” and cites to the following non-exhaustive sampling of evidence to corroborate her allegations against Defendant: e See McCawley Dec. at Exhibit 16, Sjoberg’s May 18, 2016 Dep. Tr. at 8-9, 13, 33-35, 142-143 e See McCawley Dec. at Exhibit 4, Figueroa June 24, 2016 Dep. Tr. Vol. 1 at 96-97 and 103 e See McCawley Dec. at Exhibit 14, Rinaldo Rizzo’s June 10, 2016 Dep. Tr. at 52-60 e See McCawley Dec. at Exhibit 12, Lynn Miller’s May 24, 2016 Dep. Tr. at 115 e See McCawley Dec. at Exhibit 13, Joseph Recarey’s June 21, 2016 Dep. Tr. at 29-30 e See McCawley Dec. at Exhibit 15, David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36

Case 18-2868, Document 281, 08/09/2019, 2628234, Page18 of 66 Exhibit 2 Excerpted Rodgers Dep. Ex. | at flight #s 1433-1434, 1444-1446, 1464-1470, 1478-1480, 1490-1491, 1506, 1525-1526, 1528, 1570 and 1589 See McCawley Dec. at Exhibit 10, Marcinkova Dep. Tr. at 10:18-21; 12:11-15; etc. See McCawley Dec. at Exhibit 8, Kellen Dep. Tr. at 15:13-18; 20:12-16; etc. Epstein Dep. Tr. at 116:10-15; 117:18-118:10; ete. See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 28, 52-54 See McCawley Dec. at Exhibit 42, Photographs including GIUFFRE007162-007182. See McCawley Dec. at Exhibit 30, U.S. Attorney Victim Notification Letter GIUFFRE002216-002218 See McCawley Dec. at Exhibit 33, July 2001 New York Presbyterian Hospital Records GIUFFRE003258-003290 See McCawley Dec. at Exhibit 38, Judith Lightfoot psychological records GIUFFRE00543 1-005438 See McCawley Dec. at Exhibit 28, Message Pad evidencing Defendant arranging to have underage girls and young women come to Epstein’s home GIUFFRE001386-001571 See McCawley Dec. at Exhibit 29, Black Book in which Defendant and other household staff maintained a roster of underage girls including i a. who were minors at the time the Palm Beach Police’s Investigation of Jeffrey Epstein GIUFFRE001573-00669 See McCawley Dec. at Exhibit 40, Sex Slave books Epstein ordered from Amazon.com at GIUFFRE006581 See McCawley Dec. at Exhibit 32, the folder Defendant sent to Thailand with Ms. Giuffre bearing Defendant’s phone number GIUFFRE003191-003192

Case 18-2868, Document 281, 08/09/2019, 2628234, Page19 of 66 e See McCawley Dec. at Exhibit 39, the Palm Beach Police Report showing that Epstein used women and girls to collect underage girls for his abuse GIUFFRE005614-005700 e See McCawley Dec. at Exhibit 41, Epstein’s Flight Logs showing that Defendant flew with Ms. Giuffre 23 times GIUFFRE007055-007161 Next, Defendant states, “He [Barden] believed these ends could be accomplished by suggesting to the media that, among other things, they should subject Ms. Giuffre’s allegations to inquiry and scrutiny.” Ms. Giuffre disputes any statement as to Barden’s “belief” (supra). Ms. Giuffre disputes that the harm to Defendant’s reputation could be mitigated by the media’s inquiry into and scrutiny of Ms. Giuffre’s allegations, because a deeper inquiry would only reveal additional evidence corroborating Ms. Giuffre’s allegations, such as the evidence put forth in Ms. Giuffre’s opposition memorandum of law and detailed in the bulleted citations, supra. Defendant then states, “For example, he [Barden] noted in the statement that Ms. Giuffre’s allegations changed dramatically over time, suggesting that they are ‘obvious lies’ and therefore should not be ‘publicized as news.”” First, Ms. Giuffre disputes that Barden noted anything in the statement, as that is unsubstantiated by the record evidence. Not to do Defendant’s work for her, but the closest evidence Defendant has for such a statement is testimony from the Gow deposition wherein Gow speculates that Barden “had a hand in” drafting the press statement, an opinion which may or may not be based on first-hand knowledge. See McCawley Dec. at Exhibit 6, Gow Dep. Tr. at 45:14-17 (Q. Okay. A. And I say, “Thanks, Philip” because I’m aware of the fact that he had a hand, a considerable hand in the drafting.”) This is wholly insufficient to show who drafted the passages quoted by Defendant above. Regardless of those passages’ original author, it is ultimately Defendant who “noted” anything because it is her statement and she directed that it be sent to the media and public.

Case 18-2868, Document 281, 08/09/2019, 2628234, Page20 of 66 Second, Ms. Giuffre disputes that her allegations have changed over time, “dramatically” or otherwise. Third, Ms. Giuffre disputes that the press release “suggest[ed]” that her allegations are “obvious lies,” because Defendant’s press release affirmatively, unambiguously stated that her allegations are “obvious lies” — there is no subtlety, suggestion, or statement of opinion here. See Giuffre v. Maxwell, 165 F. Supp.3d 147, 152 (S.D.N.Y. 2016) (“. . . these statements (as they themselves allege), are capable of being proven true or false, and therefore constitute actionable fact and not opinion.” DEFEN T’S PURPORTED FACTS 23. Second, Mr. Barden intended the January 2015 statement to be “a shot across the bow” of the media, which he believed had been unduly eager to publish Ms. Giuffre’s allegations without conducting any inquiry of their own. Accordingly, in the statement he repeatedly noted that Ms. Giuffre’s allegations were “defamatory.” In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of Ms. Giuffre’s obviously false allegations and the legal indefensibility of their own conduct. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This paragraph is another purported statement of Defendant’s counsel’s “intent.” Defendant states: “Second, Mr. Barden intended the January 2015 statement to be a ‘shot across the bow’ of the media, which he believed had been unduly eager to publish Ms. Giuffre’s’ allegations without conducting any inquiry of their own.” Not only does Defendant once again refer to Mr. Barden’s intent, but she also mischaracterizes the statement as a “shot across the bow” of the media. The press release did not threaten or give warning to the media in any way whatsoever. See McCawley Dec. at Exhibit 26, GM_00068, full image copied in Ms. Giuffre’s Paragraph 18, supra. Next, Ms. Giuffre disputes the sentence, “Accordingly, in the statement he repeatedly noted that Ms. Giuffre’s allegations were ‘defamatory.’” Barden did not “note” anything in the statement, nor does Defendant cite to any record evidence that he does. Furthermore, Ms. Giuffre 20

Case 18-2868, Document 281, 08/09/2019, 2628234, Page21 of 66 denies that any of her allegations are defamatory in the slightest, as they are all true and substantiated by record evidence (supra). Ms. Giuffre also disputes the sentence, “In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of Ms. Giuffre’s obviously false allegations and the legal indefensibility of their own conduct.” First, Ms. Giuffre objects to any statement of Barden’s intent, as articulated above. Second, Defendant’s conventional press release was in no way any type of “cease and desist letter.” There is no record evidence in support of this claim, and Defendant unsurprisingly cites to none. Third, Ms. Giuffre disputes that any media-recipients would be given to understand “the seriousness with which Ms. Maxwell considered the publication of Ms. Giuffre’s obviously false allegations and the legal indefensibility of their own conduct” by Defendant’s self-serving press release, as that is unsupported by the record. Finally, Ms. Giuffre rejects that her allegations are "obviously false,” a claim which is completely unsupported by record evidence. DEFENDANT’S PURPORTED FACTS 24. Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms. Maxwell” (emphasis supplied). The statement was intended to be a single, one-timeonly, comprehensive response—quoted in full—to Ms. Giuffre’s December 30, 2014, allegations that would give the media Ms. Maxwell’s response. The purpose of the prefatory statement was to inform the media-recipients of this intent. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS 21

Case 18-2868, Document 281, 08/09/2019, 2628234, Page22 of 66 Ms. Giuffre disputes that any part of Defendant’s press release is “consistent with those two [of Barden’s] purposes.” Indeed, Ms. Giuffre disputes this and any statement relating to Barden’s “purposes,” as explained above. Next, Ms. Giuffre disputes that, “The statement was intended to be a single, one-timeonly, comprehensive response — quoted in full — to Ms. Giuffre’s December 30, 2014, allegations that would give the media Ms. Maxwell’s response.” First, Ms. Giuffre disputes this and any statement relating to Barden’s “intent” as explained above. Second, Ms. Giuffre disputes that anyone intended the press release to be a one-time-only, comprehensive response. The record evidence says otherwise: Gow repeatedly issued this statement via email and over the phone for months on end. Next, Defendant states, “The purpose of the prefatory statement was to inform the mediarecipients of this intent.” First, Ms. Giuffre disputes this and any statement relating to Barden’s purpose as explained above. Second, Ms. Giuffre disputes that the press release was to inform the media of anything. Defendant issued a press release, instructed them to publish it (by telling them it was “quotable”), see McCawley Dec. at Exhibit 48, RG(UK)_000009 (supra), and hired a press agent to feed it to the press: Q. Did Ms. Maxwell retain the services of you or your firm? A. Yes, she did. ae Q. Is it your belief that that agreement was in effect on January 2nd, 2015? A. Yes. Q. Do you recall the terms of that agreement? A. Well, it was a re-establishment of an existing agreement so if we go back to the original agreement, it was to provide public relations services to Ms. Maxwell in the matter of Giuffre and her activities. 22

Case 18-2868, Document 281, 08/09/2019, 2628234, Page23 of 66 See McCawley Dec. at Exhibit 6 Gow Dep. Tr. at 12:19-21; 13:9-16. The record evidence shows that Defendant’s intent was for the press to publish her press release: any other interpretation is not only contrary to logic, but unsupported by the record. DEFENDANT’S PURPORTED FACTS 25. Ms. Giuffre’s activities to bring light to the rights of victims of sexual abuse. Ms. Giuffre has engaged in numerous activities to bring attention to herself, to the prosecution and punishment of wealthy individuals such as Epstein, and to her claimed interest of bringing light to the rights of victims of sexual abuse. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Agreed to the portion of Defendant’s assertion in bold font. Ms. Giuffre has not engaged in activities to bring attention to herself, rather she has taken action to aid in the prosecution of her abusers, and she seeks to bring light to the rights of victims of sexual abuse. DEFENDANT’S PURPORTED FACTS 26. Ms. Giuffre created an organization, Victims Refuse Silence, Inc., a Florida corporation, directly related to her alleged experience as a victim of sexual abuse. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre created Victims Refuse Silence, Inc., in order to help other sexually trafficked victims find the resources they need to recover and heal. See www.victimsrefusesilence.org. DEFENDANT’S PURPORTED FACTS 27. The “goal” of Victims Refuse Silence “was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse.” Toward this end, Ms. Giuffre has “dedicated her professional life to helping victims of sex trafficking.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Agreed. 23

Case 18-2868, Document 281, 08/09/2019, 2628234, Page24 of 66 DEFENDANT’S PURPORTED FACTS 28. Ms. Giuffre repeatedly has sought out media organizations to discuss her alleged experience as a victim of sexual abuse. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Denied. Ms. Giuffre was approached by numerous media outlets and refused to speak to most of them. Media organizations sought her out; she did not seek them out. See McCawley Dec. at Exhibit 35, GIUFFRE003690, email from Sharon Churcher seeking to interview Ms. Giuffre. DEFENDANT’S PURPORTED FACTS 29. On December 30, 2014, Ms. Giuffre publicly filed an “entirely unnecessary” joinder motion laden with “unnecessary,” “lurid details” about being “sexually abused” as a “minor victim[]” by wealthy and famous men and being “trafficked” all around the world as a “sex slave.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Paragraph 7, supra, listing multiple reasons why details were, in fact, necessary. DEFENDANT’S PURPORTED FACTS 30. The Ms. Giuffre’s alleged purpose in filing the joinder motion was to “vindicate” her rights under the CVRA, expose the government’s “secretly negotiated” “non-prosecution agreement” with Epstein, “shed tremendous public light” on Epstein and “other powerful individuals” that would undermine the agreement, and support the CVRA Ms. Giuffre’s’ request for documents that would show how Epstein “used his powerful political and social connections to secure a favorable plea deal” and the government’s “motive” to aid Epstein and his “co-conspirators.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Paragraph 7, supra, listing multiple purposes of Ms. Giuffre’s lawyers’ filing of the motion. 24

Case 18-2868, Document 281, 08/09/2019, 2628234, Page25 of 66 DEFENDANT’S PURPORTED FACTS 31. Ms. Giuffre has written the manuscript of a book she has been trying to publish detailing her alleged experience as a victim of sexual abuse and of sex trafficking in Epstein’s alleged “sex scheme.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Paragraph 52, infra, explaining that the context of this statement is misleading. DEFENDANT’S PURPORTED FACTS 32. Republication alleged by Ms. Giuffre. Ms. Giuffre was required by Interrogatory No. 6 to identify any false statements attributed to Ms. Maxwell that were “‘published globally, including within the Southern District of New York,’” as Ms. Giuffre alleged in Paragraph 9 of Count I of her complaint. In response, Ms. Giuffre identified the January 2015 statement and nine instances in which various news media published portions of the January 2015 statement in news articles or broadcast stories. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre objects to this paragraph in its entirety, starting with the bolded heading (“Republication alleged by Ms. Giuffre”). There is no “republication” as a matter of law in this case, as explained in Ms. Giuffre’s memorandum of law. Accordingly, Ms. Giuffre is not and has not alleged republication. As noted in her objection that, it is Defendant who possesses the knowledge as to where the defamatory statements were published; unsurprisingly, Defendant failed to comply with Ms. Giuffre’s discovery requests on the same. As Defendant already knows, Ms. Giuffre provided a sampling of Defendant’s defamatory statements published by the news media, as “identification of an exhaustive responsive list would be unduly burdensome.” This, of course, is because Defendant caused her statement to be published in an enormous number of media outlets. Ms. Giuffre’s full response to Interrogatory No. 6 is below. As the Court can see, these nine instances were a good-faith effort to provide some samples (as it would be virtually impossible to provide all of them), below. Ms. 25

Case 18-2868, Document 281, 08/09/2019, 2628234, Page26 of 66 Giuffre has also put forth an exhaustive expert report and expert testimony from Jim Jansen regarding the dissemination of Defendant’s defamatory press release. Ms. Giuffre objects because the information interrogatory above is in the possession of Defendant who has failed to comply with her production obligations in this matter, and has failed to comply with her production obligations with this very subject matter. See Document Request No. 17 from Ms. Giuffre’s Second Request for Production of Documents to Defendant Ghislaine Maxwell. Maxwell has not produced all “URL or Internet addresses for any internet version of such publication” that she directed her agent, Ross Gow, to send. Ms. Giuffre further objects because the information requested above is in the possession of Defendant’s agent, who caused the false statements to be issued to various media outlets. Ms. Giuffre has not had the opportunity to depose Maxwell’s agent Ross Gow; therefore, this answer remains incomplete. Consequently, Ms. Giuffre reserves the right to modify and/or supplement her responses, as information is largely in the possession of the Defendant and her agent. Ms. Giuffre objects to this interrogatory in that it violates Rule 33 as its subparts, in combination with the other interrogatories, exceed the allowable twenty-five interrogatories. Ms. Giuffre objects to this request because it is in the public domain. Ms. Giuffre also objects in that it seeks information protected by the attorney-client/work product privilege, and any other applicable privilege stated in the General Objections. Notwithstanding such objections, Ms. Giuffre has already produced documents supplements such responsive documents with the following list of publications. While the identification of an exhaustive responsive list would be unduly burdensome, in an effort to make a good faith effort towards compliance, Ms. Giuffre provides the following examples, which are incomplete based on the aforementioned reasons: 26

Case 18-2868, Document 281, 08/09/2019, 2628234, Page27 of 66 Nature Publishing Statement/URL January 2, 2015 Internet Ross Gow Jane Doe 3 is Virginia Roberts - so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms. Roberts that Alan Dershowitz is involved in having sexual relations with her, which he denies. ‘Ms. Roberts's claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. January 2, 2015 Bolton News http://www. theboltonnews.co.uk/news/national/ 11700192 -Palace denies Andrew sex_case_claim/ January 3, 2015 Telegraph ‘http://www. telegraph.co.uk/news/uknews theroyalfamily/ 11323872/Prince-Andrew-denies-having-relations-withsex-slave-girl html January 3, 2015 Daily Mail ‘http://www. dailymail.co.uk/news/article-2895366/PrinceAndrew-lobbied-government-easy-Jeffrey-EpsteinPalace-denies-claims-royal-tried-use-influence-helpbillionaire-paedophile-2008-police-probe. html January 3, 2015 Internet Huffington Post ‘http://www. huffingtonpost.co.uk/2015/01/03/duke-ofyork-sex-abuse-claims n_6409508.html January 4, 2015 Internet Express ‘http://www. express. co.uk/news/world/550085/GhislaineMaxwell-Jeffrey-Epstein-not-madam-paedophile-Floridacourt-case-Prince-Andrew January 4, 2015 Intemet Jewish News http://www. jewishnews.co.uk/dershowitz-nothing-pri andrews-sex-scandal/ January 5, 2015 Internet’ Broadcast NY Daily News ‘Attp://www_.nydailynews.com/news world/allegedmadame-accused-supplying-prince-andrew-article1.2065505 January 5, 2015 Intemet/ Broadcast AOL UK http://www.aol.co.uk/video/ghislaine-maxwell-declinesto-comment-on-prince-andrew-allegations-518587500. Iwo newest articles 0) https: //www.thesun. co.uk/archives/news/6754 prince-andrews-pal-ghislaine-groped-teen-girls’ 2] http://www. mirror.co.uk/news/uk-news’prince-andrews-pal-ghislaine-maxwell-5081971 27

Case 18-2868, Document 281, 08/09/2019, 2628234, Page28 of 66 DEFENDANT’S PURPORTED FACTS 33. In none of the nine instances was there any publication of the entire January 2015 statement. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS While there may be certain publications who did not print every word of Defendant’s lengthy press release, most publications quoted the most salient, to-the-point parts of Defendant’s statement that call Ms. Giuffre a liar. In each of the nine articles listed above, the defamatory statement, as articulated by the Complaint and as identified by the Court as actionable, is published. See Giuffire v. Maxwell, 165 F. Supp.3d 147, 152 (S.D.N.Y. 2016) (“statements that Giuffre’s claims ‘against [Defendant] are untrue,’ have been ‘shown to be untrue,’ and are ‘obvious lies’ have a specific and readily understood factual meaning: that Giuffre is not telling the truth about her history of sexual abuse and Defendant’s role, and that some verifiable investigation has occurred and come to a definitive conclusion proving that fact. Second, these statements (as they themselves allege), are capable of being proven true or false, and therefore constitute actionable fact and not opinion”). Ms. Giuffre also put forth extensive evidence of the mass distribution of Defendant’s defamatory statement to over 66 million viewers through her expert witness Jim Jansen. See McCawley Dec. at Exhibit 24, Expert Report of Jim Jansen. DEFENDANT’S PURPORTED FACTS 34. Ms. Maxwell and her agents exercised no control or authority over any media organization, including the media identified in Ms. Giuffre’s response to Interrogatory No. 6, in connection with the media’s publication of portions of the January 2015 statement. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre disputes this statement in its entirety, as it is completely devoid of record evidence. In fact, the record establishes the contrary. First, Defendant hired Gow because his 28

Case 18-2868, Document 281, 08/09/2019, 2628234, Page29 of 66 position allowed him to influence the press to publish her defamatory statement. A sampling of Gow’s testi imony establishes just that: Did Ms. Maxwell retain the services of you or your firm? Yes, she did. Is it your belief that that agreement was in effect on January 2nd, 2015? Yes. Do you recall the terms of that agreement? Well, it was a re-establishment of an existing agreement so if we go back to the original agreement, it was to provide public relations services to Ms. Maxwell in the matter of Giuffre and her activities. You can answer -- to the extent that anything you testify to is not protected by a privilege. Ms. Roberts first came to my attention on or around March 2011 when I was called into a meeting with Philip Barden and Ms. Maxwell at Devonshires law office, that sete ub POPO>ZOD * *¥ * CrP Pe she had made -- Ms. Giuffre had made extremely unpleasant allegations about Maxwell's private life. We were -- Acuity Reputation, my firm was called in to protect Ms. Maxwell's reputation, and to set the record straight. That was -- and work commenced on or around March of 2011. Does this document fairly depict pages from your -- from Acuity Reputation's website? It does. Do you see where it says "We manage reputation and forge opinion through lic relations, strategic communications and high level networking"? I do. Is that a true statement? Say it again. Sorry. Is that a true statement? It is, yes. I wrote that statement. Okay. Do you see where your website claims that your company has "excellent relationships with the media"? I do. Is that a true statement? 29

Case 18-2868, Document 281, 08/09/2019, 2628234, Page30 of 66 A. That is true, yeah. oe Q. Is it correct that you advertise your “excellent relationships with the media" because your services often include giving communications to the media on behalf of your clients? A. Yes. See McCawley Dec. at Exhibit 6 Gow Dep. Tr. at 13:9-16; 15:18-16:3; 109:12-22; 110:16-21; 111:3-7. In addition to testimonial evidence, the proof is also in the result. By using Gow to issue her press release, Defendant caused her statement to be published by numerous major news organizations with wide readership all over the globe. Accordingly, the record evidence shows that Ms. Maxwell, through her agent, had immense control and authority over the media, convincing major news outlets to publish her words based on nothing more than a single email from Gow. DEFEN. T’S PURPORTED FACTS 35. Ms. Giuffre’s defamation action against Ms. Maxwell. Eight years after Epstein’s guilty plea, Ms. Giuffre brought this action, repeating many of the allegations she made in her CVRA joinder motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Agreed, but noting that the defamation cause of action against Defendant did not accrue until Defendant defamed her in January of 2015, the same year Ms. Giuffre filed suit against Defendant for defamation. DEFENDANT’S PURPORTED FACTS 36. The complaint alleged that the January 2015 statement “contained the following deliberate falsehoods”: (a) That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.” (b) That the allegations have been “shown to be untrue.” (c) That Giuffre’s “claims are obvious lies.” 30

Case 18-2868, Document 281, 08/09/2019, 2628234, Page31 of 66 MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Agreed. However, in discovery, Defendant was finally forced to produce the complete press release she issued. See McCawley Dec. at Exhibit 26, GIUFFRE00068. DEFENDANT’S PURPORTED FACTS 37. Ms. Giuffre lived independently from her parents with her fiancé long before meeting Epstein or Ms. Maxwell. After leaving the Growing Together drug rehabilitation facility in 1999, Ms. Giuffre moved in with the family of a fellow patient. There she met, and became engaged to, her friend’s brother, James Michael Austrich. She and Austrich thereafter rented an apartment in the Ft. Lauderdale area with another friend and both worked at various jobs in that area. Later, they stayed briefly with Ms. Giuffre’s parents in the Palm Beach/ Loxahatchee, Florida area before Austrich rented an apartment for the couple on Bent Oak Drive in Royal Palm Beach. Although Ms. Giuffre agreed to marry Austrich, she never had any intention of doing so. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre did not voluntarily live independently from her parents with her fiancé, rather Ms. Giuffre was a troubled minor child who was not truly engaged prior to meeting Defendant and Epstein. Where Ms. Giuffre lived, and who she lived with, are not relevant to the issues being decided in this action. Again, this is merely a transparent distraction from the case that is actually at issue, and is being used for the sole purpose of inserting conjecture in an effort to distract the Court and ultimately the jury. Although Austrich testified that he proposed to Ms. Giuffre on Valentine’s Day, see Austrich at p. 19, Ms. Giuffre was a troubled teen who could not realistically be considered a fiancé in the true sense of the word, nor was she of legal age to marry. In fact, as accurately described by Defendant, Ms. Giuffre never had any intention of marrying Austrich. Giuffre Dep. Tr. at 127:22-128:21. Given that Ms. Giuffre was a child with limited legal capacity at this point, and that she did not have any intention of marrying Austrich, a reasonable person could not assert that Ms. Giuffre was engaged. 31

Case 18-2868, Document 281, 08/09/2019, 2628234, Page32 of 66 DEFENDANT’S PURPORTED FACTS 38. Ms. Giuffre re-enrolled in high school from June 21, 2000 until March 7, 2002. After finishing the 9th grade school year at Forest Hills High School on June 9, 1999, Ms. Giuffre re-enrolled at Wellington Adult High School on June 21, 2000, again on August 16, 2000 and on August 14, 2001. On September 20, 2001, Ms. Giuffre then enrolled at Royal Palm Beach High School. A few weeks later, on October 12, 2001, she matriculated at Survivors Charter School. Id. Survivor’s Charter School was an alternative school designed to assist students who had been unsuccessful at more traditional schools. Ms. Giuffre remained enrolled at Survivor’s Charter School until March 7, 2002. She was present 56 days and absent 13 days during her time there. Id. Ms. Giuffre never received her high school diploma or GED. Ms. Giuffre and Figueroa went “back to school” together at Survivor’s Charter School. The school day there lasted from morning until early afternoon. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre denies this statement. Either Defendant is blatantly misleading this Court or Defendant simply does not understand how to interpret Ms. Giuffre’s school records. The record produced by Defendant (GM0888) is specifically titled “A07. Assignment History,” which reflects semester start and end dates per each 180 day school year, not dates that Ms. Giuffre physically enrolled or withdrew from school. See McCawley Dec. at Exhibit 27, GM0888. PANEL: AO7, ASSIGNMENT HISTORY YEAR: 16 723400 Monday May 23, 2016 9:04 am STDT: 12870606 ROBERTS, VIRGINIA L SCHL: 3390 GR: 10 ST: I A ENTRY WITHDRAWAL P E c CD DATE OD CD DATE R PP SY CL DS SCHL DESC GR PRS ABS UNX ¥ RO2 101201 . W26 030702 N__ 02 01 __ 3390 SURVIVORS 10 56°31 __—So¥ ~ RO2 092001 _ WO2 101101 N02 01 _ 2331 ROYAL PALM HIG 10 13 1 _ ~ RAL 081401 _ W32 092001 2 02 Al 2192 WLLNGTN HS ADL 30 ~ BAL 081600 _ w47 081301 Z_ O1 Al __ 2192 WLLNGTN HS ADL 30 CY ~ BAl 062100 _ W47 081500 2 _ OO Al _ 2192 WLLNGTN HS ADL 30 CY ~ BO1 081699 _ W03 081699 N 00 01 __ 2331 ROYAL PALM HIG 10 a ese ~ BOL 081998 _ Wo2 060999 P99 01 0581 FOREST HILL HI 09 155 25 ¥ ~ B01 082097 _ WO1 061098 R_ 98 01 _ 2331 ROYAL PALM HIG 09 147 33 Y¥ EQ1 082097 _ W22 082097 N_ 98 01 _ 2191 WELLINGTON BIG 09 * R03 040797 _ WO2 061197 P _ 97 01 1691 CRESTWOOD MID 08 40 5 ¥ ~ B01 082294 __ DNE 082294 N 95 01 _ 1703 ROYAL PINES sc 06 ~ B01 082393 _ WO2 061094 P _ 94 01 _ 1901 LOXAHATCHEE EL 05 167 13 ¥ ~ E01 082592 _ WO1 061193 P 93 01 1901 LOXAHATCHER EL 04176 4 ¥ 32

Case 18-2868, Document 281, 08/09/2019, 2628234, Page33 of 66 While “Grade 30” indicates adult education, Ms. Giuffre’s attendance records indicate that she was not present in school between 6/21/00-09/20/01 (see withdrawal codes W32 and W47). WITHDRAWAL COD ADULT JDENTS e =W26 - Any student who withdraws from school to enter the adult education program prior to completion of graduation requirements. « =W32 - Any adult student who left the class/program to enter another training program. « W47 - Any adult student who is procedurally withdrawn at the end of the term or school year who will continue in the class/program the next term or school year. http://www. fldoe.org/core/fileparse.php/886 1 /urlt/0094063-appendb.pdf More importantly, Ms. Giuffre’s school transcripts clearly indicate “NO COURSES TAKEN” for the 1999-2000 and 2000-2001 school years. (See McCawley Dec. at Exhibit 27, GM_00893.) Ms. Giuffre’s attempt to work and resume school at Survivor’s Charter School as a 10" grader in the 2001-2002 school year was limited to a portion of the school year (10/20/0103/07/02), and further substantiates Ms. Giuffre’s testimony that she attempted to get away from Epstein’s abuse, along with the following testimony by Figueroa: Q: Was there a period of time between 2001 and when she left in 2002 here she was not working for Jeffrey? Yes. What period of time was that? It was pretty much, like, when she was actually working as a server. Like, basically because we were trying to not have her go back there. Like, she did not want to go back there. And we were trying to just work without needing his money, you know.” POP See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 92-93 Q: So the thing that Virginia was tired of ... What was it that Virginia was trying to get away from and stop with respect to working at Jeffrey Epstein's house? A: To stop being used and abused. See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 248 33

Case 18-2868, Document 281, 08/09/2019, 2628234, Page34 of 66 Even still, if the records are correct, which Ms. Giuffre does not concede, the records indicate that Ms. Giuffre’s attendance was poor, with 69 days present and 32 days absent out of a required 180 day school year and that she was not enrolled at the end of the school year (emphasis added). DISTRICT: 50 SCHOOL: 3390 NO COURSES TAKEN YBAR; 1999-2008 GRADS LEVEL: NA GPA QTY PTS GPA QTY PTS 21.4286 5.06 CUM: 3.5429 27.00 STATR-TERM: 1.4286 5.00 CUM: 1.5429 27.00 1995-2000 ANNUAL DAYS- PRESENT: 0 ABSENT: 9 SUMMER TERMS DAYS- PRESENT: QO ABSENT: 0 PROMOTION STATUS NOT APPLICABLE DISTRICT: 50 SCHOOL: 3390 NO COURSES TAKEN YEAR: 2000-2001 GRADE LEVEL: NA GPA QTY PTS GPA QTY PTS DISTRLICT-TERM: 1.4286 3.00 COM: 1.5429 27.00 STATE-TERM;: 1.4286 5.00 COM: 2000-2001 ANNUAL DAYS-PRESENT = 0 ABSENT: o SUMMER TERMS DAYS-PRESENT: 0 ABSENT: PROMOTICH STATUS NOT APPLICABLE DISTRICT: 50 SCHOOL: 3330 SURVIVORS CHARTER SCHOOL YRAR: 2001-2002 GRADE LEVEL: 10 SUBJECT CRSEG AO CREDIT T COURSR# COURSE TITLE AREA FLAG R CN ATT. /EKARN 1 0500530 PERS,CAR,SCH DEV 4 EL © 2N 0.50 0.50 1 1001440 BUS ENG I EN J B ZW 9.50 0.50 1 1205370 CONSUMER MATH MA OC Cc 2N 0.50 0.50 1 8300310 WORKPLACE ESSENTIAL VO B ZW 0.50 9.50 1 8301610 WORK EXP 1 wo ¥ 2N 0.50 0.00 1 9301650 WORK EXP-OJT vo F 2N1.00 0.00 CREDIT, TERM: 3.50 2.00 GPA QTY PTs GPA QTY PTs DISTRICT-TERM: STATS-TERM: : 1.4286 5.00 CUM: 1,5429 27.00 71,4286 5.00 CUM: 1.5429 27.00 2001-2002 ANNUAL DAYS-PRESENT: 69 ABSENT: 32 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: ° NOT ENROLLED IN DISTRICT K-12 AT END OF SCHOOL YEAR 34

Case 18-2868, Document 281, 08/09/2019, 2628234, Page35 of 66 See McCawley Dec. at Exhibit 27, GM_00893. Ms. Giuffre’s obvious gap in her school attendance, her presence verified by Epstein’s pilot on flight logs, and an abundence of witness testimony all corroborate her story that she was that Ms. Giuffre was flying domestic and internationally with Epstein at least 32 times between 12/11/00-07/28/01 and 06/21/02-08/21/02 (Defendant traveling with Ms. Giuffre on 23 of the flights). See McCawley Dec. at Exhibits 15 and 41, Pilot, David Rodgers’ Dep. Tr. 96:12-166; Rodger’s Dep. Ex. 1 (Ms. Giuffre flight dates: 12/11/00; 12/14/00 (GIUFFRE007095); 01/26/01; 01/27/01; 01/30/01 (GIUFFRE007096); 03/05/01: 03/06/01; 03/08/01 x’s 2; 03/09/01; 03/11/01 x’s 2 (GIUFFRE007097); 03/27/01; 03/29/01; 03/31/01 (GIUFFRE007098); 04/09/01 x’s 2; 04/11/01; 04/16/01; 05/03/01; 05/05/01 (GIUFFRE007099); 05/14/01(GIUFFRE007 100); 06/03/01 06/05/01; 07/04/01; 07/08/01; 07/11/01 (GIUFFRE007101); 07/16/01; 07/28/01; (GIUFFRE007102); 06/21/02 (GIUFFRE007111); 08/18/02; 08/21/02 (GIUFFRE0071 12); See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 104: 9-14 (Q: Do you know how long Virginia had been coming over to the house before she started traveling on an airplane with Ghislaine and Jeffrey? THE WITNESS: Not too long. I don't think it was too long after that); See McCawley Dec. at Exhibit 37, GIUFFRE004721 (passport application). DEFENDANT’S PURPORTED FACTS 39. During the year 2000, Ms. Giuffre worked at numerous jobs. In 2000, while living with her fiancé, Ms. Giuffre held five different jobs: at Aviculture Breeding and Research Center, Southeast Employee Management Company, The Club at Mar-a-Lago, Oasis Outsourcing, and Neiman Marcus. Her taxable earnings that year totaled nearly $9,000. Ms. Giuffre cannot now recall either the Southeast Employee Management Company or the Oasis Outsourcing jobs. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS 35

Case 18-2868, Document 281, 08/09/2019, 2628234, Page36 of 66 Ms. Giuffre disputes this statement. During 2000, Ms. Giuffre shared an apartment with her then boyfriend, James Michael Austrich and his friend, Mario. See McCawley Dec. at Exhibit 2, Austrich Dep. Tr. at p. 92. Although Austrich testified that he proposed to Ms. Giuffre on Valentine’s Day, see Austrich at p. 19, Ms. Giuffre was a troubled teen who could not realistically be considered a fiancé in the true sense of the word nor was she of legal age to marry. While Ms. Giuffre held various jobs in 2000, “[SSA] records do not show the exact date of employment (month and day) because [they] do not need this information to figure Social Security benefits.” See McCawley Dec. at Exhibit 46, GIUFFRE009176). The reason that Ms. Giuffre cannot recall two companies listed on her SSA records (Southeast Employee Management Company or Oasis Outsourcing) is simply because they were not her employers. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 470-472. Had Defendant bothered to run a simple google search, she could have ruled them out as being payroll and benefit administration companies. See http://www.oasisadvantage.com/west-palm-beach-peo; http://www.progressiveemployer.com/; http://www.businesswire.com/news/home/2006050100615 1/en/Progressive-Employer-ServicesPurchases-Southeast-Employee-Management. Ms. Giuffre has testified that she believes she worked at Taco Bell, at an aviary, then Mar-a-Lago (See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at p. 53, 470). Austrich also testified that Ms. Giuffre worked with him at Taco Bell, as well as a pet store for “over a month” before working at Mar-a-Lago (See McCawley Dec. at Exhibit 5, Austrich Dep. Tr. at p. 16, 30, 98). Neither Taco Bell nor the pet store are listed on Ms. Giuffre’s SSA records because they were most likely paid through payroll companies. See McCawley Dec. at Exhibit 46, GIUFFRE009178. Ms. Giuffre also testified that she volunteered at an aviary where they 36

Case 18-2868, Document 281, 08/09/2019, 2628234, Page37 of 66 eventually put her on their payroll, but paid her very little. Giuffre Dep. Tr. at p. 52; Aviculture Breeding and Research Center taxable earnings for 2000 is $99.48, See McCawley Dec. at Exhibit 46, GIUFFRE009178. DEFEN. T’S PURPORTED FACTS 40. Ms. Giuffre’s employment at the Mar-a-Lago spa began in fall 2000. Ms. Giuffre’s father, Sky Roberts, was hired as a maintenance worker at the The Mar-a-Lago Club in Palm Beach, Florida, beginning on April 11, 2000. Mr. Roberts worked there year-round for approximately 3 years. After working there for a period of time, Mr. Roberts became acquainted with the head of the spa area and recommended Ms. Giuffre for a job there. Mar-a-Lago closes every Mother’s Day and reopens on November 1. Most of employees Mar-a-Lago, including all employees of the spa area such as “spa attendants,” are “seasonal” and work only when the club is open, i.e., between November | and Mother’s Day. Ms. Giuffre was hired as a “seasonal” spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she had turned 17. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre disputes this statement. Defendant cannot simply infer Ms. Giuffre’s employment history and claim it to be undisputed. The Mar-a-Lago Club produced 177 pages of records in response to Defendant’s subpoena. However, not one page indicated Ms. Giuffre’s actual dates of employment, nor whether she was a full-time or seasonal employee. In fact, the only significant record produced was a single, vague chart entry indicating that Ms. Giuffre was terminated in 2000. MAR-A-LAGO 0173, 0176. TERMINATIONS Box #1 1998 terms LAST NAME FIRST NAME en a toe a 1200 tenis ire ee Box #5 2000 terms Box #6 2001 terms MAR-A-LAGO 0176 MAR-A-LAGO 0173 37

Case 18-2868, Document 281, 08/09/2019, 2628234, Page38 of 66 Job postings and job descriptions produced by Mar-a-Lago from 2002 and later are irrelevant to Ms. Giuffre’s employment because they are from after she worked there. Ms. Giuffre testified that Mar-a-Lago was a summer job. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. 56, 550. In fact, her father, Sky Roberts, testified that he referred his daughter for employment, and she did not get the job through a posting (See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 72); he drove his daughter to and from work consistent with his full time schedule (See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 74); he believes the spa — like the kitchen/dining room - was open to local guests in the summer (See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. 138-139); and that his daughter was not attending school when she worked at Mar-a-Lago (See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. 134). In addition, Juan Alessi testified that it was “Summer” when Defendant approached Ms. Giuffre at Mar-a-Lago because he specifically remembered “that day I was sweating like hell in the -- in the car, waiting for Ms. Maxwell to come out of the massage.” See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 94:24-95:2. DEFENDANT’S PURPORTED FACTS Al. Ms. Giuffre represented herself as a masseuse for Jeffrey Epstein. While working at the Mar-a-Lago spa and reading a library book about massage, Ms. Giuffre met Ms. Maxwell. Ms. Giuffre thereafter told her father that she got a job working for Jeffrey Epstein as a masseuse. Ms. Giuffre’s father took her to Epstein’s house on one occasion around that time, and Epstein came outside and introduced himself to Mr. Roberts. Ms. Giuffre commenced employment as a traveling masseuse for Mr. Epstein. Ms. Giuffre was excited about her job as a masseuse, about traveling with him and about meeting famous people. Ms. Giuffre represented that she was employed as a masseuse beginning in January 2001. Ms. Giuffre never mentioned Ms. Maxwell to her then-fiancé, Austrich. Ms. Giuffre’s father never met Ms. Maxwell. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre denies Defendant’s false and factually unsupported narrative. In Florida, a person cannot work as a masseuse unless she is “at least 18 years of age or has received a high 38

Case 18-2868, Document 281, 08/09/2019, 2628234, Page39 of 66 school diploma or high school equivalency diploma.” Fla. Stat. § 480.041. Ms. Giuffre was a minor child, under the age of 18, when she was working at Mar-a-Lago as a spa attendant. Giuffre Dep. Tr. at 61:9-61:24. She was approached by Defendant, who told her she could make money as a masseuse, a profession in which Ms. Giuffre had no experience. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 111:12-111:21; 116:19-117:12. (Sky Roberts, Ms. Giuffre father, verified Ms. Giuffre’s account that Defendant recruited his daughter to “learn massage therapy.” See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 80:7-19; 84:18 85:1). Ms. Giuffre’s father drove her to Jeffrey Epstein’s house, the address of which was given to her by Defendant. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 117:20-118:1. Ms. Giuffre was lead into the house, and was instructed by Defendant on how to give a massage, during which Epstein and Defendant turned the massage into a sexual encounter, and offered Ms. Giuffre money and a better life to be compliant in the sexual demands of Defendant and Epstein. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 198:20-199:3; 199:15-199:18. The minor Ms. Giuffre then began travelling with Defendant and Epstein on private planes and servicing people sexually for money—working not as a legitimate masseuse, but in a position of sexual servitude. See McCawley Dec. at Exhibits 5, 1, Giuffre Dep. Tr. at 193:22-194:16; 201:24; 204:24:205:5; Alessi Dep. Tr. at 104:9-104:14. Epstein’s house manager, Juan Alessi, described Defendant’s methodical routine of how she prepared a list of places ahead of time, then drove to each place for the purpose of recruiting girls to massage Epstein. See McCawley Dec. at Exhibit 18, Alessi Dep. Tr. at 34; GIUFFRE000105 at 57-58; GIUFFRE000241-242 at p. 212-213. Alessi also stated that on multiple occasions he drove Defendant to pre-planned places while she recruited girls for 39

Case 18-2868, Document 281, 08/09/2019, 2628234, Page40 of 66 massage. /d. He furthered testified that he witnessed Ms. Giuffre at Epstein’s house on the very same day that he witnessed Defendant recruit Ms. Giuffre from Mar-a-Lago. See McCawley Dec. at Exhibit 18, Alessi Dep. Tr. at 96-98; GIUFFRE000102-103 at p. 48-49. Johanna Sjoberg, through her sworn testimony, demonstrated that Defendant recruited her in a similar fashion by driving to the college campus where she attended school and approached her to work at Epstein’s home answering phones. See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 8-9. Sjoberg testified that she answered phones for one day before Defendant propositioned her to rub feet for $100.00 an hour. See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 13. The following day, Sjoberg was paired with Defendant’s assistant, Emmy Taylor, who provided her with massage training on Epstein. Sjoberg at 13-15. Ms. Giuffre’s then-boyfriend, Austrich, testified that he could not recall the name of the person who recruited Ms. Giuffre. However, he did say that she was recruited by someone to work for Epstein as a massage therapist, but that Ms. Giuffre did not have any experience. See McCawley Dec. at Exhibit 2, Austrich Dep. Tr. at 34-35, 100-101, 127-128. Neither Ms. Giuffre nor Sjoberg were licensed or trained in massage, but were invited soon after being recruited to travel with Epstein on his private plane to massage him. See McCawley Dec. at Exhibit 16, Giuffre Dep. Tr. at 16-17; Sjoberg Dep. Tr. at 13-15; Austrich Dep. Tr. at 109-110; Alessi Dep. Tr. at 104. DEFENDANT’S PURPORTED FACTS 42. Ms. Giuffre resumed her relationship with convicted felon Anthony Figueroa. In spring 2001, while living with Austrich, Ms. Giuffre lied to and cheated on him with her high school boyfriend, Anthony Figueroa. Ms. Giuffre and Austrich thereafter broke up, and Figueroa moved into the Bent Oak apartment with Ms. Giuffre. When Austrich returned to the Bent Oak apartment to check on his pets and retrieve his belongings, Figueroa in Ms. Giuffre’s presence punched Austrich in the face. Figueroa and Ms. Giuffre fled the scene before police arrived. Figueroa was then a convicted felon and a drug abuser on probation for possession of a controlled substance. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS 40

Case 18-2868, Document 281, 08/09/2019, 2628234, Page41 of 66 This entire statement is wholly irrelevant to the case being tried, and is improperly being inserted to tarnish the record. Ms. Giuffre’s dating history as a young teen bears no relation to the allegations made within Ms. Giuffre’s complaint against Defendant. As previously stated, Defendant is attempting to muddy the record with nonsensical teen drama in an effort to detract from her salacious sexual abuse of a minor child. Such statements bear no relation to the issues presented through her motion for summary judgment, and should be given weight reflecting the same. As specifically set forth in Ms. Giuffre’s objections to designated testimony, the alleged information would be excluded by multiple rules of evidence, and contested by Ms. Giuffre. See McCawley Dec. at Exhibit 5, Virginia Dep. Tr., passim. Moreover, it was the Defendant who solicited Anthony Figueroa to recruit high school aged girls for Epstein. See McCawley Dec. at Exhibit 4 Figueroa Tr. at 200 and 228-229. DEFENDANT’S PURPORTED FACTS 43. Ms. Giuffre freely and voluntarily contacted the police to come to her aid in 2001 and 2002 but never reported to them that she was Epstein’s “sex slave.” In August 2001 at age 17, while living in the same apartment, Ms. Giuffre and Figueroa hosted a party with a number of guests. During the party, according to Ms. Giuffre, someone entered Ms. Giuffre’s room and stole $500 from her shirt pocket. Ms. Giuffre contacted the police. She met and spoke with police officers regarding the incident and filed a report. She did not disclose to the officer that she was a “sex slave.” A second time, in June 2002, Ms. Giuffre contacted the police to report that her former landlord had left her belongings by the roadside and had lit her mattress on fire. Again, Ms. Giuffre met and spoke with the law enforcement officers but did not complain that she was the victim of any sexual trafficking or abuse or that she was then being held as a “sex slave.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This statement is misleading in several respects and irrelevant. The fact that Ms. Giuffre did contact police on two occasions for two specific purposes and did not take that opportunity to also inform the police of everything else that was going on in her life at the time is immaterial. Defendant implies that anytime someone calls the police for one thing they should tell the police 41

Case 18-2868, Document 281, 08/09/2019, 2628234, Page42 of 66 about every other crime regardless of the relevance to the crime to which the police responded and regardless to the threat to herself should she report on these powerful people. Moreover, as Professor Coonan explained: Popular understandings of the term “sex slave” might still connote images of violent pimps, white slavery, or of victims chained to a bed in a brothel in the minds of some people. To call Ms. Giuffre a victim of sex trafficking would however very accurately convey the reality that she along with a great many other victims of contemporary forms of slavery are often exploited by the “invisible chains” of fraud and psychological coercion. See McCawley Dec. at Exhibit 23, Coonan Expert Report at 20. Ms. Giuffre specifically testified that she was fearful of Defendant and Epstein, and, accordingly, she would not have reporter her abusers. She also knew that Epstein had control over the Palm Beach Police. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 240:3-241:2. DEFENDANT’S PURPORTED FACTS 44. From August 2001 until September 2002, Epstein and Maxwell were almost entirely absent from Florida on documented travel unaccompanied by Ms. Giuffre. Flight logs maintained by Epstein’s private pilot Dave Rodgers evidence the substantial number of trips away from Florida that Epstein and Maxwell took, unaccompanied by Ms. Giuffre, between August 2001 and September 2002. Rodgers maintained a log of all flights on which Epstein and Maxwell traveled with him. Epstein additionally traveled with another pilot who did not keep such logs and he also occasionally traveled via commercial flights. For substantially all of thirteen months of the twenty-two months (from November 2000 until September 2002) that Ms. Giuffre lived in Palm Beach and knew Epstein, Epstein was traveling outside of Florida unaccompanied by Ms. Giuffre. During this same period of time, Ms. Giuffre was employed at various jobs, enrolled in school, and living with her boyfriend. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS The flight logs produced in this matter provide substantive evidence of Ms. Giuffre’s travel while in the control of Defendant and Epstein, but are clearly incomplete. Moreover, Ms. Giuffre also was flown by Defendant on commercial flights. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 155:5-11. Ms. Giuffre disputes Defendant’s statement to the contrary, as reliance upon incomplete records to prove that Ms. Giuffre was not in fact in the presence of 42

Case 18-2868, Document 281, 08/09/2019, 2628234, Page43 of 66 Defendant and Epstein is insufficient. Ms. Giuffre incorporates additional details contained in Response #38 and #46 herein. Ms. Giuffre’s obvious gap in her school records, her presence verified by Epstein’s pilot on flight logs, and witness testimony, corroborate her story that she was traveling with Defendant and Epstein. In fact, flight logs and pilot testimony clearly prove that Ms. Giuffre was flying domestic and internationally with Epstein at least 32 times between 12/11/00-07/28/01 and 06/21/02-08/21/02 (Defendant traveling with Ms. Giuffre on 23 of the flights). As Defendant acknowledges in her own statement #44, flight records are incomplete. There were several pilots and co-pilots that flew Epstein and Maxwell (Lawrence “Larry” Visoski, David (Dave) Rodgers, Bill Hammond, Pete Rathgeb, Gary Roxburgh, and Bill Murphy) in multiple aircrafts (JEGE, Inc. Aircraft # N908JE — Type B-727-31, and Hyperion Air, Inc. Aircraft # N909JE — Type G-1159B). Yet, only one pilot, David Rodger’s produced flight records. See McCawley Dec. at Exhibit 41, David Rodger’s Flight Log, GIUFFRE007055- GIUFFRE007161. In addition, many of the girls recruited by Defendant routinely traveled on commercial flights for the purposes of providing massages to Epstein or guests at Epstein’s New York, New Mexico, or U.S. Virgin Island homes. See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 27. As thoroughly depicted below, Ms. Giuffre’s passport application, travel records and witness testimony clearly demonstrate flight logs are incomplete because only one pilot kept a log, and Ms. Giuffre also flew commercially while she worked for Defendant and Epstein. For example, on December 11, 2000, while underage, Ms. Giuffre appears on Rodger’s flight log (flight #1433) traveling with Epstein, Maxwell and Emmy Taylor from PBI (Palm Beach, FL) to TEB (Teterboro, NJ) then on December 14, 2001 (#1434) continues traveling with Epstein and 4B

Case 18-2868, Document 281, 08/09/2019, 2628234, Page44 of 66 Maxwell to TIST (U.S. Virgin Islands); however, there is no flight records of Ms. Giuffre’s return to Palm Beach. See McCawley Dec. at Exhibit 15, see McCawley Dec. at Exhibit 41, Rodger’s Dep. Ex. 1 at GIUFFRE007095; see also Rodger’s Dep. Tr. 96-98 (“Q: And do you know how Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, and Virginia get off of St. Thomas or leave the island? A: No. I do not. Probably a charter, I'm guessing.”). wl «| jesse [tes NB SRM RIN 44 ri Nt | yes TSy 3 S61 69, BE, arezepr Wy iw ul Tisy PBI =ry us| RPO OE PSL TAS sae |) MW PBE PBS | huadtps ceessepeagraw On January 12, 2001, at Defendant’s directive, Ms. Giuffre applied for a Passport to travel with them internationally. See McCawley Dec. at Exhibit 37, GIUFFRE004721, passport application listing travel plans to London; flight logs subsequently lists Ms. Giuffre traveling to London with Defendant, Epstein and others). On January 26, 2001, while underage, Ms. Giuffre appears on Rodger’s flight log (flight #1444) traveling with Epstein, Maxwell and Emmy Taylor from TEB (Teterboro, NJ) to PBI (Palm Beach, FL); however, there is no flight record indicating how Ms. Giuffre got to New York. On January 27, 2001 (#1445) continues traveling with Epstein, Maxwell and Emmy Taylor from PBI (Palm Beach) to TIST (U.S. Virgin Islands) returning from TIST (U.S. Virgin 44

Islands) four days Case 18-2868, Document 281, 08/09/2019, 2628234, Page45 of 66 Ex. | at GIUFFRE007096; Rodger’s Dep. Tr. at 100-102. ater on January 30, 2001. See McCawley Dec. at Exhibit 15, Rodger’s Dep. ey [MINA errmipe | | yyy soy sper Lew Boi a Jes ¢ PRE yay SE, M65, RRC Robes 3 C\I2 | wyauby | pat LMA CHL VOUT Pere SonerSoN ‘ nV LNPy Lea BVA cLeshye MSOSLS \4 u | Lce Co Lee OD ee RT y \ \« M moo [typ 22 \G\\S46 | NGogw| PBF tris __ finns] 56 GMy GT, VzRCzpEA RoGxeH 32 \ Mt TrisT_| Par rsa SEEM ETVRarDo Rotews | ee rine ates Tn = = On March 5, 2001 Ms. Giuffre, Maxwell, Epstein, Emmy Taylor traveled aaa: internationally (flight #1464) leaving PBI (West Palm Beach) to CYJT (Stephenville, Canada); then on March 6, 2001 (#1465) they continued on to LFPB (Paris, France) with a layover for three days. On March 8, 2001, other passengers, including one unidentified female, joined them on flights # 1466-1467 (from LFPB (Paris, France) - LGGR (Granada, Spain) eventually landing in EGGW (London, England) on March 11, 2001, where she was then introduced to and lent out to Prince Andrew. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007097; Rodger’s Dep. Tr. at 104-114. a = z Frown) No. | Ma ceatinte 21 [Brno [pamed [Dew [pew m oe ie anne gee zl csnuunsee | cn | mera rms os ern zal ve ve ” <e sc oa, aaa 4, 2B a 216 INaeseml new Tans etlaar Gfceos toe bet 23 re Avs Ons JONAS sine S10, rc) ae rz. ah TIE, wae s = a ea Paeaptf ee ree ook DASCean’ 8 aie ES ieee 3 « te { aL | PBE KUSIT ROM «cers, 00 SiGe |w9qoqt [PRL “betsy (yu|TSIC AES, VERE ED ROBERT COT G W u Cysy [Lerg hasbeen res, VR Cis Git " LRG LEER UU We GM, CT, VR ALEMOL CDP pant, - 4 Veet Berries, Arete LGeoteprp CT gz \ LEGR IGMTT. BOT EM ET IG, CLO Lorn Pome 4 ut ua Grs¥ [Ecow (UBPeIO7V IVE RR M a wt EGGW | BGR (yer SR Ror] MW s ir 7 ul BGR TEs (und JE/GM, ET, VR RGR

Case 18-2868, Document 281, 08/09/2019, 2628234, Page46 of 66 See also photo of Ms. Giuffre, Maxwell and Prince Andrew in London. GIUFFRE007167; see also Figueroa Dep. Tr. at 251. Ms. Giuffre, Epstein, Maxwell, and Taylor remained in London for three days until departing on March 11, 2001 (#1469), stopping in BGR (Bangor, Maine) before departing (#1470) back to TEB (Teterboro, NJ); however, there is no flight record of Ms. Giuffre’s return to Palm Beach. See Rodger’s Dep. Ex. 1 at GIUFFRE007097; Rodger’s Dep. Tr. at 104-114. 2 IG s49 Nao leer Hee 2a Yi Tem [SAF ay iw 4 she [POT + al w leer [Lee On March 27, 2001, while underage, Ms. Giuffre, Maxwell, Epstein, Emmy Taylor, two unidentified females and others traveled together (#1478) from PBI (Palm Beach) to TEB (Teterboro, NJ); then three days later, on March 29, 2001, continued on (#1479) to SAF (Santa Fe, NM), returning to PBI (Palm Beach, FL) with Nadia Bjorlin (#1480) on March 31, 2001. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007098; Rodger’s Dep. Tr. at 119-125. 46

Case 18-2868, Document 281, 08/09/2019, 2628234, Page47 of 66 A few glaring examples of how Ms. Giuffre’s travel records are incomplete is that Ms. Giuffre traveled from ADS (Addison, Texas) on May 3, 2001 (#1501) to SAT (San Antonio, Texas); then departs SAT (San Antonio, Texas) on May 5, 2001 (#1502) to PBF (Pine Bluff, AR) but there is no record produced that explains how Ms. Giuffre arrived in Addison, Texas or how she returned to Palm Beach from Pine Bluff, AR. Although Epstein’s plane appears to have to originated from Palm Beach on April 23, 2001, Ms. Giuffre’s name doesn’t not appear on the log. See Rodger’s Dep. Ex. 1 at GIUFFRE007099; Rodger’s Dep. Tr. at 130-132 (“Q: Do you know how Virginia Roberts got to Addison, Texas? A: No. ... Q: Went to Addison and picked up Virginia Roberts? A: It looks like it.”). Another prime example of how incomplete Ms. Giuffre’s travel records are is on on May 14, 2001. While Ms. Giuffre appears on flight #1506 with Epstein, Maxwell, Emmy Taylor and others (including one unidentified female) from TIST (U.S. Virgin Islands) to TEB (Teterboro, NJ), there is no record produced explaining how Ms. Giuffre arrived to the U.S. Virgin Islands or where she stayed when she landed in New York. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007100; Rodger’s Dep. Tr. at 132-133 (“Q: What were the other possible avenues back in those days for Jeffrey Epstein, Ghislaine Maxwell to travel to the Virgin Islands? A: They could have done a charter, possibly.”) (/d. at 134-135 “Q: All right. So at some point in time, between May 7th and May 14th — A: Uh-huh. Q: -- somebody flies the Gulfstream to the Virgin Islands. A: Correct. Q: And who would that be? A: Larry Visoski and I don't know who the other person would have been.”); /d. at 136 (“Q. Do you know where Virginia Roberts went during that time after she landed in Teterboro on the 14th? A. I do not.”) LAYSHIS0 [NGbege [vere new | ledfPORETBRE Teeam — 47

Case 18-2868, Document 281, 08/09/2019, 2628234, Page48 of 66 On June 3, 2001, Ms. Giuffre travels from PBI (Palm Beach) to TIST (U.S. Virgin Islands) on flight #1510 for three days; then, on June 5, 2001, continues on flight #1511 to TEB (Teterboro, NJ); however, there is no record of Ms. Giuffre returning to Palm Beach. See Rodger’s Dep. Ex. 1 at GIUFFRE007101; Rodger’s Dep. Tr. at 136-137. 2 wt pm ee say Ca [Game [Nose [Tes She, Wane OSES OBS i is ee WZ 3% vt vb [eax THST oo TAY cue Z Ss ee Vest | yes SINS = Ne 2) * “ [tes fe al REED OR BES nach nay, Datum" \z % " CQL - Reaves rirav(AP Bez gat Deer) ‘fj “ a eB yf SE 55] SE CAROL 15 | TEC Wy SDR DAN, CO RELA NW, \ eee NS te ve i i PBs 8 Soe Gey \EEMONE AS (sy A au}. ay Ten | Lepo \sv] ZS ey REN AGS WOSRS, | 7 | Bi \e ae Leo | Léewn WH [IEO™) eemore \ 4 25 \ ” Lenn | LEM hezo [Ma 1GM, \ feemate” \ 2b Me \ "| Leme_| Ler6 s2\| Toyo {7 af ow | it LPB | LPAD | |\culdecr. es, ep TIE WA 2s 1 vw LeAZ Tet sz J3E,GM <1) GO WrNe aye ww I TST PCE TE) AP, VIR, |) Gamete UL 7 Me ear | Ts i525] SUSI ST, AP, VE /SRatID OW CHT Xe [yes CPS Isp emer, VR Reedite n Then, on July 4, 2001, Ms. Giuffre reappears on flight #1524 with Epstein and an unidentified female leaving TIST (U.S. Virgin Islands) to return to PBI (Palm Beach); however, there is no flight record that reflects how Ms. Giuffre got to the U.S. Virgin Islands. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007101; Rodger’s Dep. Tr. at 138-139 (“Q. And do you know how Virginia Roberts got to the Virgin Islands? A: No. Q. Is there any -- is it possible that the Cessna took her or the Boeing took her? Or any other aircraft that is owned by Jeffrey? A: No, I would -- if I had to guess, I would guess the airlines.”) Again, on July 8, 2001, Ms. Giuffre appears on flight #1525 with Epstein, Maxwell, Emmy Taylor and others including an unidentified female departing PBI (Palm Beach) to TEB 48

Case 18-2868, Document 281, 08/09/2019, 2628234, Page49 of 66 (Teteboro, NJ). Four days later, on July 11, 2001, Ms. Giuffre, Epstein and Maxwell continue on (#1526) to CPS (Cahokia-St. Louis, Illinois) which was a stop due to a mechanical delay on the way to Sante Fe, NM; however, there is no flight record that reflects how Ms. Giuffre returned home to Palm Beach. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. | at GIUFFRE007101; Rodger’s Dep. Tr. 139-141 (“Q: And then three days later, you leave out of Teterboro to CPS? A: Yes. Q: Where is that? A: That is St. Louis, actually it is Cahokia, Illinois, across the river from St. Louis. Q. Who are your passengers? A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Virginia Roberts. We were actually en route to Santa Fe. We had a mechanical problem. We had to go into there for maintenance.”) On July 16, 2001, Ms. Giuffre appears on flight #1528 with Epstein, Maxwell and Emmy Taylor from SAF (Santa Fe, NM) to TEB (Teteboro, NJ); however, Ms. Giuffre’s flight to Santa Fe, NM is missing from the records. In addition, on July 28, 2001, Ms. Giuffre reappears on the flight log (#1531) returning with Epstein from TIST (U.S. Virgin Islands) to PBI (Palm Beach); however, there is no record of Ms. Giuffre’s flight to the U.S. Virgin Islands. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007102; Rodger’s Dep. Tr.142. ACO From [> | 7” Wleime [mavaze [eps [sae PITTA TOE LEE 1b e vw | 59¢ JER ~ JPRCM VR Gees 2 Ve \e | PaE ly E5r /OWGURy Lewas . 2% ” Wi 355 8 sk [i531 TE, VILE LPIA Robeky | On June 21, 2002, Ms. Giuffre appears on flight #1570 with Epstein, Maxwell, Sarah Kellen, Cindy Lopez and Jean Luc Brunel from PBI (Palm Beach, FL) to MYEF (George Town, Bahamas); however, there is no record of Ms. Giuffre returning to Palm Beach. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007111; Rodger’s Dep. Tr. 161-162 (“Q: 49

Case 18-2868, Document 281, 08/09/2019, 2628234, Page5S0 of 66 Virginia Roberts was taken to the Bahamas. Do you know where she went from there? A. Ido not.”) Zoek ; S| 1715314 sere Exow [seK S'S SEK | PRL ZIG -Ns4s asaae Poe Tres IYI BATA Naowse | Bos WE} ve vw — I TLS Wy [PEiSK caver Corer LAuRe res \ le vt TEST € [FES SL ory (o52, LR \4 IG SB [NAc [PRL hy] Reorire7 ane. M4 {v4 ve TER PBL Weg FP EVE, CEnOy LoPET ai] a ged VEE | hen SIEMER GL Ten? We fawn, ee a MYEr | PBC isa] RePisrsar BLY ge PEE [myer se] Reh isrsraw ZN Mower | Tee [ henlteunoneh avers 24| iV w TER eBEe Iny| REMI eG NS46 [sess [P Gr fT MVY 13] 3S \ EAM | i MY EO sey | SOy) FEL yw “ BED TER 5 [Fr 1 FE MLE Ss AC TE8 SRE lise TE) Sk, & REMILG \ & leyiaxe |[wasise [AEG [Acc eee 3 G |2e6L3 _L HAW | Toto AGG 4S [BN-318]) Naot SAX [aay | ltag|eee ecto nr ver doen |, je] Sax [POL | lta [RETRW Chom C~ehece Ge ta! G \S4-8, B, ee SAC *é8 1G, GM SE, Cenor Lone VEte ws Rabe (Hye \g u \ CB PBL \s40| veeber xP Robern, | Kemer On August 17, 2002, Ms. Giuffre appears on flight #1589 with Epstein, Maxwell, Sarah Kellen, Cindy Lopez and others from SAF (Santa Fe, NM) to TEB (Teterboro, NJ); Ms. Giuffre returns to PBI (Palm Beach, FL) on August 18, 2002 with Epstei in and one unidentified female (#1590). See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. | at GIUFFRE0071 12; Rodger’s Dep. Tr. 165 (“Q: Do you know how Virginia Roberts got to Santa Fe? A: No.”) 50

Case 18-2868, Document 281, 08/09/2019, 2628234, Page51 of 66 From September 29, 2002 through October 19, 2002, Defendant and Epstein sent Ms. Giuffre on a commercial flight to Thailand for massage training and provided her with all accommodations. See McCawley Dec. at Exhibit 43, Giuffre00741 1-Giuffre007432. DEFENDANT’S PURPORTED FACTS 45. Ms. Giuffre and Figueroa shared a vehicle during 2001 and 2002. Ms. Giuffre and Figueroa shared a ’93 white Pontiac in 2001 and 2002. Ms. Giuffre freely traveled around the Palm Beach area in that vehicle. In August 2002, Ms. Giuffre acquired a Dodge Dakota pickup truck from her father. Figueroa used that vehicle in a series of crimes before and after Ms. Giuffre left for Thailand. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre and Tony Figueroa did not share a vehicle during 2001 and 2002. Instead, Figueroa borrowed Ms. Giuffre’s car while she was traveling with Defendant and Epstein. Figueroa testified that he “got to take the car, because she was going somewhere else in the world and did not need it, so...” Figueroa Dep. Tr. At 89-90. In fact, Ms. Giuffre was frequently traveling with Defendant and Epstein. See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 9-14 (stating that Virginia started traveling on an airplane with Ghislaine and Jeffrey “not too long” after she started going over to the house). Figueroa further testified that Virginia “would normally go about two weeks out of every month” with Epstein. Figueroa Dep. Tr. at 90. He further stated, “Pretty much every time I took her there, it was always to his mansion. I picked her up one time -- maybe it was a couple of times --from the jet stream place. But pretty much every single time it was at the hou- -- at the mansion.” Jd. Moreover, Ms. Giuffre testified she purchased a car from the $10,000 payment she received from Epstein after she was forced to have sex with Prince Andres in London at Defendant’s home when Ms. Giuffre was a minor. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 120:1-20. 51

Case 18-2868, Document 281, 08/09/2019, 2628234, Page52 of 66 DEFENDANT’S PURPORTED FACTS 46. Ms. Giuffre held a number of jobs in 2001 and 2002. During 2001 and 2002, Ms. Giuffre was gainfully employed at several jobs. She worked as a waitress at Mannino’s Restaurant, at TGIFriday’s restaurant (aka CCI of Royal Palm Inc.), and at Roadhouse Grill. She also was employed at Courtyard Animal Hospital (aka Marc Pinkwasser DVM). MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This statement is laughable. Ms. Giuffre was hardly gainfully employed during a time period in which she was trying to escape from the grip Epstein and Maxwell had on Ms. Giuffre. While Social Security provides that she earned nominal amounts of earning statements for 2001 and 2002, the records do not indicate the month or quarter of the year’s work. See McCawley Dec. at Exhibit 46, GIUFFRE009176. For a brief period, Ms. Giuffre attempted to go back to school to earn her GED, and tried unsuccessfully to hold down waitressing jobs. See McCawley Dec. at Exhibit 27, GIUFFRE009179. For example, in 2001, Ms. Giuffre earned $212.00 as a waitress working “briefly” at Mannino’s Restaurant. (See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 472). In 2002, Ms. Giuffre earned $403.64 at CCI of Royal Palm Beach working there (TGI Fridays) for a “short time period.” (See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 473). Then, Ms. Giuffre worked at Roadhouse grill until about March 2002 earning $1,247.90 (See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 474). EMPLOYER NUMBER: 65-0241353 MANNINOS INC MANNINOS RESTAURANT 12793 B W FOREST HILL BLVD WEST PALM BEACH FL 33414-4749 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 2001 $212.00 52

Case 18-2868, Document 281, 08/09/2019, 2628234, Page53 of 66 EMPLOYER NUMBER: 06-1587035 CCI OF ROYAL PALM INC % ROBERT FURR TTEE 2255 GLADES RD STE 337-W BOCA RATON FL 33431-7379 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 2002 $403.64 EMPLOYER NUMBER: 65-0367604 ROADHOUSE GRILL INC ROBERT C FURR TTEE IN BANKRUPTCY 2255 GLADES RD STE 337W BOCA RATON FL 33431-7379 YEAR 1st QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 2002 $1,247.90 EMPLOYER NUMBER: 65-0915938 MARC PINKWASSER DVM PA 13860 WELLINGTON TRCE STE 31 WELLINGTON FL 33414-8541 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 2002 $1,561.75 « GIUFFRE009179.§, According to Dr. Pinkwasser’s records, Ms. Giuffre’s also received payroll checks for weeks ending 04/22/02-06/04/02 earning a total of $1,561.75. (See McCawley Dec. at Exhibit 47, GIUFFRE009203). 4/22/02 Courtyard Animal Hospital 5/6/02 Courtyard Animal Hospital 5/6/02 Courtyard Animal Hospital 5/20/02 Courtyard Animal Hospital 6/4/02 Courtyard Animal Hospital Not long after Ms. Giuffre losing her job at Courtyard Animal Hospital, GIUFFRE00009211, flight records show that Ms. Giuffre was soon back under Epstein’s control traveling with Maxwell to the Bahamas, Santa Fe, New Mexico then New York, see McCawley Dec. at Exhibit 47, GIUFFRE007111-GIUFFRE007112. DEFENDANT’S PURPORTED FACTS 47. In September 2002, Ms. Giuffre traveled to Thailand to receive massage training and while there, met her future husband and eloped with him. Ms. Giuffre traveled 53

Case 18-2868, Document 281, 08/09/2019, 2628234, Page54 of 66 to Thailand in September 2002 to receive formal training as a masseuse. Figueroa drove her to the airport. While there, she initially contacted Figueroa frequently, incurring a phone bill of $4,000. She met Robert Giuffre while in Thailand and decided to marry him. She thereafter ceased all contact with Figueroa from October 2002 until two days before Mr. Figueroa’s deposition in this matter in May 2016. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre did travel to Thailand to receive massage training in September 2002. However, Defendant has inaccurately told only part of the story. Defendant has conveniently left out certain key facts, which includes the fact that Ms. Giuffre was given an assignment from Defendant and Epstein that she had to recruit another underage girl from Thailand, and bring that young girl back to Epstein. See McCawley Dec. at Exhibit 43, GIUFFRE 003191. The document Ms. Giuffre was give directs her to “call Ms. Maxwell.” See McCawley Dec. at Exhibit 32, GIUFFRE003191. It is not disputed by Defendant or Epstein, that Ms. Giuffre was expected to return to Epstein and Maxwell upon completion of her massage training and assignment. It is undisputed by Ms. Giuffre that she did not return to Defendant and Epstein, but instead escaped clear across the world to Australia where she remained in hiding from Defendant and Epstein for several years. DEFENDANT’S PURPORTED FACTS 48. Detective Recarey’s investigation of Epstein failed to uncover any evidence that Ms. Maxwell was involved in sexual abuse of minors, sexual trafficking or production or possession of child pornography. Joseph Recarey served as the lead detective from the Palm Beach Police Department charged with investigating Jeffrey Epstein. That investigation commenced in 2005. Recarey worked only on the Epstein case for an entire year. He reviewed previous officers’ reports and interviews, conducted numerous interviews of witnesses and alleged victims himself, reviewed surveillance footage of the Epstein home, participated in and had knowledge of the search warrant executed on the Epstein home, and testified regarding the case before the Florida state grand jury against Epstein. Detective Recarey’s investigation revealed that not one of the alleged Epstein victims ever mentioned Ms. Maxwell’s name and she was never considered a suspect by the government. None of Epstein’s alleged victims said they had seen Ms. Maxwell at Epstein’s house, nor said they had been “recruited by her,” nor paid any money by her, nor told what to wear or how to act by her. Indeed, none of Epstein’s alleged victims ever reported to the government they had met or spoken to Ms. Maxwell. Maxwell was not 54

Case 18-2868, Document 281, 08/09/2019, 2628234, Page55 of 66 seen coming or going from the house during the law enforcement surveillance of Epstein’s home. The arrest warrant did not mention Ms. Maxwell and her name was never mentioned before the grand jury. No property belonging to Maxwell, including “sex toys” or “child pornography,” was seized from Epstein’s home during execution of the search warrant. Detective Recarey, when asked to describe “everything that you believe you know about Ghislaine Maxwell’s sexual trafficking conduct,” replied, “I don’t.” He confirmed he has no knowledge about Ms. Maxwell sexually trafficking anybody. Detective Recarey also has no knowledge of Ms. Giuffre’s conduct that is subject of this lawsuit. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This statement is false. Detective Recarey knew that Maxwell was involved in the illegal sexual activities at Epstein's house. He wanted to speak to her, but Maxwell did not return his calls. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 28:23-29:10. Detective Recarey concluded that Defendant’s role was to procure girls for Epstein. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 29:16-29:20. In the execution of the search warrant, stationary was found in the home bearing Maxwell's name, and notes were written by house staff to Maxwell. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 45:13-25; Jd. at 83:3-83:15; see also Message Pads, GIUFFRE 001412, 001418, 001435, 001446, 001449, 001453, 001454. A key piece of evidence in the investigation were message pads uncovered in trash pulls, and from inside the residence during the search warrant. Those message pads revealed numerous calls left at the house for Maxwell, indicating she was staying in the house during the days when Epstein was engaging in illegal sex acts with minors. Additionally, a walk through video taken during the execution of the search warrant revealed photos of topless females at the home, and there was even a photograph of Maxwell naked hanging in the home. The house staff who were deposed in the civil cases each testified to Maxwell being the boss in charge of everyone in the house. See McCawley Dec. at Exhibits 1, 55:

Case 18-2868, Document 281, 08/09/2019, 2628234, Page56 of 66 19, 21, Banasiak Dep. Tr. at 8:21-9:16; 14:20-15:6; Alessi Dep. Tr. at 23:11-23:20; Rodriguez Dep. Tr. at 169:1-169:4. Rodriguez, the house butler from 2004 through 2005, a time period that revealed daily sexual abuse of underage females, testified that Maxwell kept a list of the local girls who were giving massages at her desk, and that Maxwell kept nude photos of girls on her computer. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at 238:4-238:22; 302:19-303:10; 306:1306:24. Recarey testified that when the search warrant was executed, the house had been sanitized and the computers removed from the home. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 72:25-73:15. Banaziak testified that the computers were removed by Adriana Ross, another employee who answered to Maxwell. See McCawley Dec. at Exhibit 19, Banaziak Dep. Tr. at 54:7-22. The record is replete with testimony demonstrating that Maxwell recruited Virginia, and recruited other females, who in turn recruited other females, all who were sexually abuse by Epstein; meaning, it is undisputed that Maxwell started the top of the pyramid of local Palm Beach girls who were all eventually identified as victims. See, e.g., McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 34:19-35:3; 98:5-98:12; 104:15-104:23. The co-conspirator who maintained direct contact with the many underage victims was Sarah Kellen, whose sole responsibility was to schedule underage girls to visit Epstein for sex. Sarah reported directly to Maxwell. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at 26:10-26:20. On the day when the search warrant was executed, the house maid, Ruboyo was scheduled to report to the house that day at 8 am; however, she received a call from Maxwell telling her not to go. See McCawley Dec. at Exhibit 20, Rabuyo Dep. Tr. at 81:20-82:25. Maxwell orchestrated and ran the entire sex 56

Case 18-2868, Document 281, 08/09/2019, 2628234, Page57 of 66 trafficking scheme from a high level, and insulated herself from most of the underage girls who were being paid for sex. Tony Figueroa, Ms. Giuffre's ex-boyfriend, did testify that Maxwell personally requested that he find and bring girls to Epstein for sex once Ms. Giuffre had escaped, and that when he brought the girls Maxwell interacted with them. See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 200:6-18; 228:23-229:21. Rodriguez testified unequivocally that Maxwell was "the boss" and that she knew everything that was going on. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. 169:1-169:4. DEFENDANT’S PURPORTED FACTS 49. No nude photograph of Ms. Giuffre was displayed in Epstein’s home. Epstein’s housekeeper, Juan Alessi, “never saw any photographs of Virginia Roberts in Mr. Epstein’s house.” Detective Recarey entered Epstein’s home in 2002 to install security cameras to catch a thief and did not observe any “child pornography” within the home, including on Epstein’s desk in his office. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This is false. Nude photographs were displayed throughout Epstein’s home. Furthermore, Alfredo Rodriguez testified to Maxwell having pornography on her computer. Rodriguez Dep. Tr. 150:10-17; 306:1-306:24. He also testified to there being a collage of nude photos in Epstein's closet. Jd. 253:14-254:18. That collage was eventually taken into evidence by Detective Recarey, who testified to that fact in his deposition. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 73:19-73:24. And those photos are still in the possession of the FBI or US Attorney's Office. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 74:2-74:7. Numerous other people have testified about nude photographs being on display in the home including Ronaldo Rizzo, who visited the home on numerous occasions and who was reprimanded by Maxwell herself for looking at the nude photos. See McCawley Dec. at Exhibit 14, Rizzo Dep. Tr. at 25:19-26:20. Additionally, the search warrant video, taken at a time when 57

Case 18-2868, Document 281, 08/09/2019, 2628234, Page58 of 66 the house had already been sanitized, revealed photographs of nudity displayed, including a photograph of Maxwell herself in the nude. See McCawley Dec. at Exhibit 44, Search Warrant Video attached to the Deposition of Recarey. Johanna Sjorberg testified that the Defendant bought her a camera for the specific purpose of her taking nude photos of herself. See McCawley Dec. at Exhibit 16 Sjoberg Tr. at 150. Finally, Virginia Giuffre testified that there was a nude photograph of her at the house. See McCawley Dec. at Exhibit 5 Virginia Giuffre Tr. at 232 and 333. DEFENDANT’S PURPORTED FACTS 50. Ms. Giuffre intentionally destroyed her “journal” and “dream journal” regarding her “memories” of this case in 2013 while represented by counsel. Ms. Giuffre drafted a “journal” describing individuals to whom she claims she was sexually trafficked as well as her memories and thoughts about her experiences with Epstein. In 2013, she and her husband created a bonfire in her backyard in Florida and burned the journal together with other documents in her possession. Jd. Ms. Giuffre also kept a “dream journal” regarding her thoughts and memories that she possessed in January 2016. To date, Ms. Giuffre cannot locate the “dream journal.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS The dream journal contained memories of Ms. Giuffre’s dreams. While Ms. Giuffre has looked for this journal, which is wholly irrelevant to this case, she has been unable to locate it. Ms. Giuffre also wrote in a personal journal some of her experiences with Maxwell and Epstein, which were harmful and painful. In an effort to relieve herself of those past painful experiences, Ms. Giuffre followed the advice of a therapist, and burned the journal as a form of cathartic release at a time when she was under no obligation to maintain the personal memorialization of personal and painful experiences. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 205:13206:10. 58

Case 18-2868, Document 281, 08/09/2019, 2628234, Page59 of 66 DEFENDANT’S PURPORTED FACTS 51. Ms. Giuffre publicly peddled her story beginning in 2011. Ms. Giuffre granted journalist Sharon Churcher extensive interviews that resulted in seven (7) widely distributed articles from March 2011 through January 2015. Churcher regularly communicated with Ms. Giuffre and her “attorneys or other agents” from “early 2011” to “the present day.” Ms. Giuffre received approximately $160,000 for her stories and pictures that were published by many news organizations. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Defendant's statement misrepresents history. In 2011, Ms. Giuffre was still in hiding from Epstein and Maxwell in Australia. Ms. Giuffre was not looking to sell anything or even speak with anyone about what had happened to her in her previous life from which she dramatically escaped. Journalist, Sharon Churcher, located Ms. Giuffre and impressed the importance of Ms. Giuffre standing up to those who had harmed her and speak with Federal authorities, which Ms. Giuffre did in 2011. See McCawley Dec. at Exhibit 31, Redacted 302 GIUFFRE001235-01246. In addition, Churcher impressed the importance of bringing the abuse of Defendant and Epstein to public light to prevent their continued abuse of others. See McCawley Dec. at Exhibit 35, Giuffre003690. After much deliberation, Ms. Giuffre agreed to be interviewed by Churcher, and was compensated for sharing her story, which came at a heavy price of being publicly scrutinized. DEFENDANT’S PURPORTED FACTS 52. Ms. Giuffre drafted a 144-page purportedly autobiographical book manuscript in 2011 which she actively sought to publish. In 2011, contemporaneous with her Churcher interviews, Ms. Giuffre drafted a book manuscript which purported to document Ms. Giuffre’s experiences as a teenager in Florida, including her interactions with Epstein and Maxwell. Ms. Giuffre communicated with literary agents, ghost writers and potential independent publishers in an effort to get her book published. She generated marketing materials and circulated those along with book chapters to numerous individuals associated with publishing and the media. 59

Case 18-2868, Document 281, 08/09/2019, 2628234, Page60 of 66 MS. GIUFFRE’S STATE 'T CONTROVERTING DEFENDANT’S FACTS Defendant’s characterization of these activities are out of context and thus misleading. In 2008, Ms. Giuffre received a Victim Notification Letter from the United States Attorney’s office for the Southern District of Florida, see McCawley Dec. at Exhibit 30, GIUFFRE0010202, regarding her sexual victimization by Epstein. Thereafter, in 2011, she sought psychological counseling from a psychologist for the trauma she endured. Also that year, journalist Sharon Churcher sought her out, and traveled half way around the globe to interview her on painful subjects. Ms. Giuffre was interviewed by the FBI in 2011. See McCawley Dec. at Exhibit 31, FBI Redacted 302 GIUFFRE01235-1246. She was also getting psychological help. See McCawley Dec. at Exhibit 38, Lightfoot Records, GIUFFRE00543 1-005438. In that situation, Ms. Giuffre began to draft a fictionalized account of what happened to her. It was against this backdrop of her trauma being unearthed, her steps to seek psychological counseling for it, that she drafted this manuscript. Doing so was an act of empowerment and a way of reframing and taking control over the narrative of her past abuse that haunts her. “Writing ‘I’ has been an emancipatory project for women.” Perreault, Jeanne, “AUTOGRAPHY/ TRANSFORMATION/ ASYMMETRY,” Women, Autobiography, Theory A Reader edited by Sidonie Smith & Julia Watson. Indeed, scholars have written that the act of engaging in autobiography or even accounts loosely based on autobiography, is a process of taking control of one’s own narrative and one’s own self: “Thus a specific recitation of identity involves the inclusion of certain identity contents and the exclusion of others; the incorporation of certain narrative itineraries and internationalities, the silencing of others; the adoption of certain autobiographical voices, the muting of others.” Smith, Sidonie, PERFORMATIVITY, 60

Case 18-2868, Document 281, 08/09/2019, 2628234, Page61 of 66 AUTOBIOGRAPHICAL PRACTICE, RESISTANCE, Women, Autobiography, Theory A Reader edited by Sidonie Smith & Julia Watson. Indeed, even a cursory look at the manuscript penned by Ms. Giuffre informs the reader that she is trying to put forth a more palatable and more empowering narrative to over-write that powerlessness she felt when being abused by Defendant and Epstein. While Ms. Giuffre explored trying to publish her story to empower other individuals who were subject to abuse, she ultimately decided not to publish it. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. 249:1618; 250:19-251:3. DEFENDANT’S PURPORTED FACTS 53. Ms. Giuffre’s publicly filed “lurid” CVRA pleadings initiated a media frenzy and generated highly publicized litigation between her lawyers and Alan Dershowitz. On December 30, 2014, Ms. Giuffre, through counsel, publicly filed a joinder motion that contained her “lurid allegations” about Ms. Maxwell and many others, including Alan Dershowitz, Prince Andrew, Jean-Luc Brunel. The joinder motion was followed by a “corrected” motion and two further declarations in January and February 2015, which repeated many of Ms. Giuffre’s claims. These CVRA pleadings generated a media maelstrom and spawned highly publicized litigation between Ms. Giuffre’s lawyers, Edwards and Cassell, and Alan Dershowitz. After Ms. Giuffre publicly alleged Mr. Dershowitz of sexual misconduct, Mr. Dershowitz vigorously defended himself in the media. He called Ms. Giuffre a liar and accused her lawyers of unethical conduct. In response, attorneys Edwards and Cassell sued Dershowitz who counterclaimed. This litigation, in turn, caused additional media attention by national and international media organizations. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Paragraph 7, supra, explaining why the allegations were necessary and appropriate for multiple reasons. Ms. Giuffre disputes Defendant’s false characterization of these events, and, indeed, the media attention was caused by Defendant’s is suing her defamatory press release. 61

Case 18-2868, Document 281, 08/09/2019, 2628234, Page62 of 66 DEFENDANT’S PURPORTED FACTS 54. Ms. Giuffre formed non-profit Victims Refuse Silence to attract publicity and speak out on a public controversy. In 2014, Ms. Giuffre, with the assistance of the same counsel, formed a non-profit organization, Victims Refuse Silence. According to Ms. Giuffre, the purpose of the organization is to promote Ms. Giuffre’s professed cause against sex slavery. The stated goal of her organization is to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. Ms. Giuffre attempts to promote Victims Refuse Silence at every opportunity. For example, Ms. Giuffre participated in an interview in New York with ABC to promote the charity and to get her mission out to the public. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre did not form the non-profit Victims Refuse Silence to "speak out on a public controversy," but instead to simply help survivors of sexual abuse and sexual trafficking. In order to provide assistance to victims, Ms. Giuffre attempted to talk about the non-profit’s mission when she had the opportunity to do so. See www.victimsrefusesilece.org. MS. GIUFFRE’S STATEMENT OF UNDISPUTED FACTS 55. Virginia Roberts was born August 9, 1983. See McCawley Dec. at Exhibit 51, Driver’s License GIUFFRE009209. 56. Virginia Roberts turned 18 on August 9, 2001. 57. In 2000, Virginia's father Sky Roberts worked at the Mar-a-Lago. See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 72, 74. 58. Sky Roberts got Virginia a job at Mar-a-Lago in 2000, either months before or just after Virginia's 17th birthday. See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 72, 74; Giuffre Dep. Tr. at 25:19-25:21; 28:10-28:12. 59. The only year in which Virginia was employed at Mar-a-Lago was 2000. See McCawley Dec. at Exhibit 49, MAR-A-LAGO 0173, 0176. 62

Case 18-2868, Document 281, 08/09/2019, 2628234, Page63 of 66 60. Virginia worked at Mar-a-Lago as a spa bathroom attendant. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 61:9-61:24; Austrich Dep. Tr. at 100:3-12. 61. Virginia was not a masseuse at Mar-a-Lago as she had no massage experience. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 111:12-111:21; 116:19-117:12; Austrich Dep. Tr. at 34-35, 100-101, 127-128; Figueroa Dep. Tr. at 82:10-15; 168:24-169:1; Sky Roberts Dep. Tr. at 80:7-19; 84:18 -85:1. 62. Maxwell approached Virginia at Mar-a-Lago, and recruited her to come to Jeffrey Epstein's house. See McCawley Dec. at Exhibits 1, 5, and 17, Giuffre Dep. Tr. at 111:12-111:21; 116:19-117:12; Alessi Dep. Tr. at 94:24-95:2; Sky Roberts Dep. Tr. at 80:7-19; 84:18 -85:1. 63. At the time Maxwell recruited Virginia to Jeffrey Epstein's house, Virginia was either 16 or 17 years old, depending on whether this occurred just before or just after Virginia's birthday. See McCawley Dec. at Exhibit 49, MAR-A-LAGO 0173, 0176. 64. Virginia followed Maxwell's instructions and reported to Jeffrey Epstein's house on the night of the day when Maxwell approached Virginia at Mar-a-Lago. See McCawley Dec. at Exhibits 5 and 18, Giuffre Dep. Tr. at 117:20-118:1; Alessi Dep. Tr. at 96-98; GIUFFRE000102-103 at p. 48-49. 65. Maxwell told Virginia at Mar-a-Lago that Virginia could get paid for giving a massage to Jeffrey Epstein. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 111:12-111:21; 116:19-117:12. 66. When Virginia arrived at Epstein's house, she was taken upstairs to Epstein's bedroom, and instructed by Maxwell and Epstein how to give Epstein a massage. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 198:20-199:3; 199:15-199:18; Epstein Dep. Tr. at 74:3-14. 63

Case 18-2868, Document 281, 08/09/2019, 2628234, Page64 of 66 67. Epstein and Maxwell turned the massage into a sexual encounter. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 198:20-199:3; 199:15-199:18. 68. Virginia was not a professional masseuse, and was not old enough to be a masseuse in Florida even though Maxwell testified she only hired professional masseuses. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 61:9-61:24, 111:12-111:21, 116:19-117:12; Fla. Stat. § 480.041; Maxwell Dep. Tr. at 23:21-24:9; 31:6-18; 41:7-13; 220:13-221:2; 225:23226:20; 248:5-16; 310:6-17; 383:2-18. 69. Maxwell and Epstein promised Virginia money and a better life in exchange for complying with their sexual demands. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 198:20-199:3; 199:15-199:18. 70. Maxwell had sex with Virginia and other females. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 138:17-139:16; Maxwell 07-22-2016 Dep. Tr. at 86:25-87:9; 91:15-91:21. 71. Virginia was trafficked nationally and internationally for sexual purposes. See McCawley Dec. at Exhibits 5, 1, 41? GIUFFRE007055-007161 (Flight Logs); Giuffre Dep. Tr. at 193:22-194:16; 201:24; 204:24:205:5; Alessi Dep. Tr. at 104:9-104:14; Andrew Photo GIUFFRE007167; Spain Photo GIUFFRE007166. 72. Maxwell recruited other non-professionals under the guise of being a masseuse, but in reality only recruited girls for sexual purposes. See McCawley Dec. at Exhibits 5, 16, 4, 1, 18 Giuffre Dep. Tr. at 198:20-199:3; Sjoberg Dep. Tr. at 13-15; Figueroa Dep. Tr. at 88:12-22; Alessi Dep. Tr. at 34; GIUFFRE000105 at 57-58; GIUFFRE00024 1-242 at p. 212-213. 2. Maxwell was the boss of others whose job it was to recruit minor females for Epstein for sex, such as Sarah Kellen. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at 26:10-26:20. 64

Case 18-2868, Document 281, 08/09/2019, 2628234, Page65 of 66 74. Maxwell was a recruiter of underage girls and other young females for Epstein for sex, and was the boss in charge of those females. See McCawley Dec. at Exhibits 16, 4, 21, and 1, Sjoberg Dep. Tr. 8-9, 13-15, 27; Figueroa Dep. Figueroa Dep. Tr. at 200:6-18; 228:23-229:21; Rodriguez Dep. Tr. 169:1-169:4; Alessi Dep. Tr. at 104:15-104:23. Dated: January 31, 2017 By: 23:11-23:20; 34:19-35:3; 98:5-98:12; Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-5202! ' This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. 65

Case 18-2868, Document 281, 08/09/2019, 2628234, Page66 of 66 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 31, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10" Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmflaw.com jpagliuca@hmflaw.com /s/ Sigrid S. McCawley Sigrid S. McCawley 66

Case 18-2868, Document 282, 08/09/2019, 2628236, Pagel of 8 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS, v. Ghislaine Maxwell, Defendant. DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT AND UNDISPUTED FACTS I, Sigrid McCawley, declare that the below is true and correct to the best of my knowledge as follows: 1. Tam a Partner with the law firm of Boies, Schiller & Flexner LLP and duly licensed to practice in Florida and before this Court pursuant to this Court’s Order granting my Application to Appear Pro Hac Vice. 2. I respectfully submit this Declaration in Support of Plaintiff's Response to Defendant’s Motion for Summary Judgment and Undisputed Facts. 3. Attached hereto as Sealed Exhibit | are true and correct copies of Excerpts from June 1, 2016 Depositions of Juan Alessi. 4. Attached here to as Sealed Exhibit 2 is a true and correct copy of Excerpts from June 23, 2016, Deposition of James Austrich. 5. Attached hereto as Sealed Exhibit 3 is a true and correct copy of Excerpts from September 9, 2016, Deposition of Jeffrey Epstein. 6. Attached hereto as Sealed Exhibit 4 is a true and correct copy of Excerpts from June 24, 2016, Deposition of Tony Figueroa (Volumes I and II).

Case 18-2868, Document 282, 08/09/2019, 2628236, Page2 of 8 7. Attac Excerpts from May 3 8. Attac ed ed ereto as Sea ereto as Sea led Composite Exhibit 5 are true and correct copies of , 2016 and November 14, 2016, Deposition of Virginia Giuffre. led Exhibit 6 is a true and correct copy of Excerpts from November 18, 2016, Deposition of Ross Gow. oO: Attac ed ereto as Sea led Exhibit 7 is a true and correct copy of Excerpts from June 20, 2016, Deposition of i. 10. Attac January 25, 2017, De; 11. Attac ed ed ereto as Sea position of Sarah ereto as Sea led Exhibit 8 is a true and correct copy of Excerpts from Kellen. led Exhibit 9 is a true and correct copy of Excerpts from November 29, 2016, Deposition of Peter Kent. 12. Attac January 17, 2017, De; 13. Attacl ed ed ereto as Sea position of Nadia ereto as Sea Excerpts from April 22, 2016 and July 14. Attac ed ereto as Sea led Exhibit 10 is a true and correct copy of Excerpts from Marcinko. ied Composite Exhibit 11 are true and correct copies of 22, 2016, Depositions of Ghislaine Maxwell. led Exhibit 12 is a true and correct copy of Excerpts from May 24, 2016, Deposition of Lynne Trudy Miller 15. Attac ed ereto as Sea led Exhibit 13 is a true and correct copy of Excerpts from June 21, 2016, Deposition Joseph Recarey. 16. Attacl ed ereto as Sea led Exhibit 14 is a true and correct copy of Excerpts from June 10, 2016, Deposition of Rinaldo Rizzo. 17 Attac ed June 3, 2016, Deposition 18. Attac ed ereto as Sea of David Rod ereto as Sea led Exhibit 15 is a true and correct copy of Excerpts from gers. led Exhibit 16 is a true and correct copy of Excerpts from May 18, 2016, Deposition of Johanna Sjoberg.

Case 18-2868, Document 282, 08/09/2019, 2628236, Page3 of 8 19. Attached hereto as Sealed Exhibit 17 is a true and correct copy of Excerpts from May 20, 2016, Deposition of Sky Roberts. 20. Attached hereto as Sealed Composite Exhibit 18 are true and correct copies of Excerpts from September 8, 2009, Depositions of Juan Alessi (GIUFFRE000102-000103; GIUFFRE000105; GIUFFRE000241-000242). 21. Attached hereto as Sealed Exhibit 19 is a true and correct copy of Excerpts from February 16, 2010, Deposition of Janusz Banasiak (GIUFFRE00443 1-004432; GIUFFRE004437-004438; GIUFFRE004477). 22. Attached hereto as Sealed Exhibit 20 is a true and correct copy of Excerpts from October 20, 2009, Deposition of Louella Rabuyo (GIUFFRE004386). 23. Attached hereto as Sealed Composite Exhibit 21 is a true and correct copy of Excerpts from July 29, 2009 and August 7, 2009, Deposition of Alfredo Rodriguez (GIUFFRE000936-000937; GIUFFRE000942; GIUFFRE000953-000954; GIUFFRE000974; GIUFFRE000978; GIUFFRE000996; GIUFFRE000999-001000; GIUFFRE001003). 24. Attached hereto as Sealed Exhibit 22 is a true and correct copy of August 1, 2016, Defendant’s Privilege Log. 25. Attached hereto as Sealed Exhibit 23 is a true and correct copy of September 15, 2016, Expert Report of Professor Terry Coonan. 26. Attached hereto as Sealed Exhibit 24 is a true and correct copy of September 15, 2016, Expert Report of Doctor Bernard Jansen. 27. Attached hereto as Sealed Exhibit 25 is a true and correct copy of November 28, 2016, Expert Report of Peter Kent 28. Attached hereto as Sealed Exhibit 26 is a true and correct copy of January 2, 2015, Email Correspondence (GM_00068).

Case 18-2868, Document 282, 08/09/2019, 2628236, Page4 of 8 29. Palm Beach School County Records (GM_00888-00898). 30. Attached hereto as Sealed Exhibit 27 is a true and correct copy of Excerpts of Attached hereto as Sealed Exhibit 28 is a true and correct copy of Excerpts of Message Pads (GIUFFRE001388; GIUFFRE001409; GIUFFRE001412-4213; GIUFFRE001417-18, GIUFFRE001421; GIUFFRE001423; GIUFFRE001426-1428; GIUFFRE001432-1433; GIUFFRE001435; GIUFFRE001446; GIUFFRE001448-1449; GIUFFRE001452-1454; GIUFFRE001456; GIUFFRE001462; GIUFFRE001474; GIUFFRE001563). 31. Attached Black Book (GIUFFRE001573-GIUFFRE001669). 32. Attached 2008, U.S. Attorney Victim Notification Letter (GIUFFRE00221 33. Attached Federal Bureau of Investi; 34, Attached Note from Defendant. 35. Attached York Presbyterian Hospit: 36. Attached 2011, Email Corresponder 37. Attached 2011, Email Corresponde: 38. Attached 2011, Email Correspon 39; Attached hereto as Seal hereto as Seal hereto as Seal (GIUFFRE0031 ereto as Sea ereto as Sea hereto as Seal hereto as Seal led Exhibit 30 is a true an ed Exhibit 31 is a true an ed Exhibit 32 is a true an 91-003192). led Exhibit 33 is a true an al Records (GIUFFRE003258-003290). led Exhibit 34 is a true an ed Exhibit 35 is a true an ed Exhibit 36 is a true an ere to as Sealed Exhibit 29 is a true and correct copy of Epstein’s correct copy of September 3, 6-002218). correct copy of July 5, 2013, gation Interview (GIUFFRE001235-001246). correct copy of Handwritten correct copy of July 2001 New correct copy of a February 17, nce to Sharon Churcher (GIUFFRE003678). correct copy of February 13, nce to Sharon Churcher (GIUFFRE003690). correct copy of February 25, lence to Sharon Churcher (GIUFFRE003731).) hereto as Exhibit 37 is a true and correct copy of a Passport Application

Case 18-2868, Document 282, 08/09/2019, 2628236, Paged of 8 (GIUFFRE004721). 40. Attached hereto as Sealed Exhibit 38 is a true and correct copy of Judith Lightfoot Psychological Records (GIUFFRE00543 1-005438). Al. Attached hereto as Sealed Exhibit 39 is a true and correct copy of July 25, 2006, Palm Beach Police Department Incident Report (GIUFFRE005614-005700). 42. Attached hereto as Sealed Exhibit 40 is a true and correct copy of an Amazon Receipt (GIUFFRE006581). 43. Attached hereto as Sealed Exhibit 41 is a true and correct copy of David Rodger’s June 3, 2016, Deposition Exhibit 1, Flight Log, (GIUFFRE007055-007161). 44. Attached hereto as Sealed Exhibit 42 are true and correct copies of Photographs (GIUFFRE007162-7182). 45. Attached hereto as Sealed Exhibit 43 is a true and correct copy of Travel Documents to Thailand (GIUFFRE00741 1-GIUFFRE007432). 46. Attached hereto as Sealed Exhibit 44 is a true and correct copy of Walkthrough Video CD (GIUFFRE007584). 47. Attached hereto as Sealed Exhibit 45 is a true and correct copy of West Palm Beach Contact List (GIUFFRE007834-GIUFFRE007847). 48. Attached hereto as Sealed Exhibit 46 is a true and correct copy of October 23, 2016, Social Security Administration records (GIUFFRE009176-GIUFFRE009179). 49. Attached hereto as Sealed Exhibit 47 is a true and correct copy of November 7, 2016, Employment Records from Courtyard Animal Hospital (GIUFFRE009203). 50. Attached hereto as Sealed Exhibit 48 is a true and correct copy of January 2, 2015, Email Correspondence (RG (UK) _ 000009). 51. Attached hereto as Sealed Exhibit 49 are true and correct copies of Termination

Case 18-2868, Document 282, 08/09/2019, 2628236, Page6 of 8 Documents (MAR-A-LAGO 0173 & MAR-A-LAGO 0176). 52. Attached hereto as Sealed Exhibit 50 is a true and correct copy of January 2, 2015, Joinder Motion (GIUFFRE0003 19-000333). 53. Attached hereto as Sealed Exhibit 51 is a true and correect copy of Virginia Roberts Driver License (GIUFFRE009209). I declare under penalty of perjury that the foregoing is true and correct. /s/ Sigrid McCawley Sigrid McCawley, Esq.

Case 18-2868, Document 282, 08/09/2019, 2628236, Page7 of 8 Dated: January 31, 2017. Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-5202! ' This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation.

Case 18-2868, Document 282, 08/09/2019, 2628236, Page8 of 8 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 31st day of January, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10" Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmflaw.com jpagliuca@hmflaw.com /s/ Sigrid McCawley Sigrid McCawley

EXHIBIT 1 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page2 of 883 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS a a aE a EN ae ea x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. Bice oaesscsheseseestssieessessosssctesee es x June 1, 2016 9:12 a.m. CONFIDENTIAL Deposition of JOHN ALESSI, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. MAGNA® LEGAL SERVICES

10 LL 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page3 of 883 0 > 0 Page 9 JOHN ALESSI You're ready to start, correct? Yes. Can you tell us your current address? MEN 09208 Bech, Florida 33472. Q. A. Q. And your date of birth? And was there a time when you worked for a man named Jeffrey Epstein? A. Q. Yes. And can you tell us when you began working for Mr. Epstein? A. I began working for Mr. Epstein part-time. I cannot exactly tell you the date, but it was 1990/'91, probably. I worked a total of 13 years for him. Q. Okay. So you began in 1990 part-time, correct? A. Right. Q. And you stopped working for him when? A. I stopped working for him on December 31st, 2001. I was out -—- yes, 2001. Q. Okay. A. The end of 2001. I left the last day of MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page4 of 883 Page 10 1 JOHN ALESSI 2 the year. 3 Q. Okay. I know that it's been a long time. 4 A. It's been a long time. oD: Q. I know. So I'm going to ask that you 6 refer to the statement that you provided to the cl police November 21st, 2005, and please go to page 5. 8 I just want you to start reading at line 2 and 3, 9 and tell me if that refreshes your recollection as 10 to your time or duration of employment. 11 A. You're right. It was 2002, then. 2002. 12 Q. So sometime in 1990, you were a part-time 13 employee? 14 A. Uh-huh. 15 Q. And you worked until December 31st, 2002; 16 is that right? 17 As Yes. 18 Or Okay. And is it also correct that you 19 began full-time employment with Mr. Epstein on 20 January 1st, 1991, as stated in that report? 21 A, Yes. 22 QO. Prior to 1990, who did you work for? 23 A. Prior to 1990, I had a company, a 24 maintenance company, myself, my own company, Alessi 25) Maintenance. And before that, I worked for another MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page5d of 883 Page 11 1 JOHN ALESSI 2 family, the Radi family in Palm Beach. 3 Q. Did you ever work for a man named Les 4 Wexner? 3 A. I did some work for him in his mother's 6 house. oh Q. Where was that? 8 A. Palm Beach. What year? Before -- before 9 I came to work for Jeffrey. 10 0. Is that who recommended that you work for 1 Jeffrey Epstein? 12 A. I guess so. 13 Q. Okay. When you started with Jeffrey 14 Epstein, what were your job duties? 15 A. I was doing maintenance. I was doing 16 building and rebuilding and maintenance work AT basically. Because he just bought the house at that 18 time. And because of Mr. Wechsler knowing me, they 19 recommend me to go to the house and take a look at 20 the house. And we start tearing the house down, 21 basically, at the beginning of my job. 22 Q. Did you assist in the teardown? 23 A. Yes. 24 Q. Okay. So your job duties then was that of 25 a maintenance? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page6 of 883 Page 12 1 JOHN ALESSI 2 A. Maintenance, building. 3 Q. Got it. 4 And did you meet Mr. Epstein when you 3 were -- in 1990? 6 A. Yes, I met him. 7 0%. Okay. And in 1991, who made the decision 8 for you to become a full-time employee? 9 A. Jeffrey. 10 Q. And as a full-time employee initially, 1 what was your job? 12 A. I was basically maintenance, the same 13 thing as I was doing with -- I was exclusively 14 working for him. I was full-time working for him as 15 maintenance, because the house was still on 16 renovation, and he wanted me there. 17 Q. Okay. And how was your relationship with 18 Mr. Epstein back then, 1991? 19 A. Great. No problem. 20 Q It was good? 21 A, It was good. 22 Q Did he have a girlfriend back then, in 23 1991? 24 MR. PAGLIUSCA: Object to the form and 25 foundation. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page7 of 883 Page 13 1 JOHN ALESSI 2 You can answer the question. 3 Occasionally, I'll need to object for the 4 record in case we need to have a discussion 3 about this with the judge. And so that's just 6 me preserving those objections. 7 THE WITNESS: Yes, he had a girlfriend. 8 Her name was Dr. Andersson, Eva Andersson. And 9 she was there just for a few months after I 10 came to the house. 11 BY MR. EDWARDS: 12 Q. And how was your relationship with 13 Dr. Andersson? 14 A. Fine. 15 Q. Okay. And at the time when Mr. Epstein 16 was -- at the time when Dr. Andersson was Jeffrey 17 Epstein's girlfriend, did you see any other female 18 companions around the house? 19 A. Eventually -- they have a lot of guests, 20 too. They did have guests coming in. But I can't 21 remember exactly who. It's a socialite. So they 22 have friends. 23 Q. At the time when Dr. Andersson was 24 Mr. Epstein's girlfriend, was Mr. Epstein getting 25 massages? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page8 of 883 Page 14 1 JOHN ALESSI 2 MR. PAGLIUSCA: Object to the form and 3 foundation. 4 THE WITNESS: I think so. I was not 3 involved in the house, inside of the house that 6 much. But they always got massages. Always. 7 BY MR. EDWARDS: 8 Q. Okay. I'm talking about the time period 9 when Dr. Andersson was there. 10 A. Yes, they got massages. 11 Q. Okay. So do you remember other female 12 visitors when Dr. Andersson was Mr. Epstein's 13 girlfriend? 14 A. I don't remember. I remember people being 15 there, visitors, but I cannot remember that far. 16 Q. Okay. After -- did there come a point in 17 time when Dr. Andersson was no longer Mr. Epstein's 18 girlfriend? 19 A. Right. 20 0% Yes? 21 A. Yes. 22 Q. And did he -- did he have a new 23 girlfriend? 24 MR. PAGLIUSCA: Object to form and 25 foundation. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page9 of 883 Page 23 1 JOHN ALESSI 2 Q. All right. 3 Who was in charge of the Palm Beach house? 4 A. I was. 5 Q. All right. 6 Who was your direct supervisor? 7 A. Mr. Epstein. He would deal with me 8 directly, or if he was not available, Ms. Maxwell. 9 Q. Okay. I want you to go to Exhibit 3 and 10 page -- page 179, line 8. 11 A. Line 8, "QUESTION: And then Maxwell came 12 and she took over you as your immediate supervisor? 13 Yes. That's correct. Yes. She became 14 the supervisor not only for this house, but for all 15 the homes. 16 Q. Okay. So your immediate supervisor was 17 Ms. Maxwell? 18 A. Ms. Maxwell. But if Mr. Epstein was at 19 the house, I would never go to Ms. Maxwell; I would 20 go to him directly, or he would come to me. 21. Q. Okay. At some point in time towards the 22 end of your tenure, did you come to resent 23 Ms. Maxwell? 24 MR. PAGLIUSCA: Object to the form and 25 foundation. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page10 of 883 Page 28 1 JOHN ALESSI 2 Q. And where did the massage therapists -3 where did they come from? 4 A. Most, they came from Palm Beach. Palm 3 Beach County. 6 Q. And over the course of that 10-year period a of time while Ms. Maxwell was at the house, do you 8 have an approximation as to the number of different 9 females -- females that you were told were massage 10 therapists that came to the house? aa MR. PAGLIUSCA: Object to form and 12 foundation. 13 THE WITNESS: I cannot give you a number, 14 but I would say probably over 100 in my stay 15 there. 16 BY MR. EDWARDS: 17 Q. And many of the times would the females 18 come only one time and not return? 19 MR. PAGLIUSCA: Object to form and 20 foundation. 21 BY MR. EDWARDS: 22 Q.. Let me ask that a different way. 23 Were there times when some of these 24 females that would come to the house, and you were 25 told that they were massage therapists, would come MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page11 of 883 Page 30 1 JOHN ALESSI 2 BY MR. EDWARDS: 3 Q. Okay. And who would find the massage 4 therapist to bring to the house? 3 A. They would call me in my office, and they 6 would say, Get me a massage at 10:00 with this 7 person. 8 I have a list of the massage therapists, a 9 Rolodex, or a card, and I would call them for the 10 specific time they want a massage. And I would do 1: that. 12 O I don't think I asked the right -- the 13 question that I was looking to ask, so let me go 14 back. 15 Did you go out looking for the girls -16 A. No. Hr Q. -- to bring -18 A. Never. 19 Q. -- as the massage therapists? 20 A. Never. 21 Q. Who did? 22 A. Ms. Maxwell, Mr. Epstein and their 23 friends, because their friends relayed to other 24 friends they knew a massage therapist and they would 25 send to the house. So it was referrals. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page12 of 883 Page 34 1 JOHN ALESSI 2 foundation. Hold on. That misstates what is 3 happening in this deposition, because the word 4 "recruit" was introduced by the lawyers in this 3 deposition. So I object to your 6 characterization of the testimony. 7 BY MR. EDWARDS: 8 Q. I'll read for you the question and the 9 answer. 10 The question was: "QUESTION: When did 1 that role get transferred from you to Ms. Maxwell, 12 the role of looking after girls or calling the 13 girls? 14 "ANSWER: I didn't look after -- out for 15 girls. Ms. Maxwell was the one that recruit. I 16 remember one occasion or two occasions she would say 17 to me, John, give me a list of all the spas in Palm 18 Beach County, and I will drive her from one to the 19 other to PGA in Boca; and she would go in and drop 20 credit cards -- not credit cards but business cards 21 and she would come out. And then we'd go to -- she 22 will recruit the girls. Was never, never done by me 23 or Mr. Epstein or anyone else that I know of." 24 Is that truthful testimony? 25) A. It is truthful; however, I think MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page13 of 883 Page 35 1 JOHN ALESSI 2 "recruiting," for myself, for my point of view, is 3 hiring immediately and recruit the person. 4 I think she was looking for massage 3 therapists. She was looking for the best kind. She 6 went -- and you're right, I went one time with her, I or twice maybe, to different spas and different 8 clubs, great clubs, I mean, in Boca, in Fort 9 Lauderdale, in -- in Palm Beach. She was looking 10 for the best massage therapists available. 11 How she find these girls, I don't know. I 12 just drove there. I just was the driver. I never 13 was involved with any of the offerings or 14 negotiations or meeting these girls. Never. 15 Q. Okay. Ms. Maxwell was the one that would 16 meet the girls? 17 A. Yeah. 18 Q. Okay. Did you ever check any of the IDs 19 for any of these girls? 20 A. I was not -- that was not in my everyday 21 things to do. It was not. 22 Q. That was just not part of your job? 23 A. That was not my job. 24 Q. Did Ms. Maxwell take photographs while she 25 was at the Palm Beach house? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page14 of 883 Page 52 1 JOHN ALESSI 2. MR. PAGLIUSCA: Object to form and 3 foundation. 4 THE WITNESS: Himself. Himself. D BY MR. EDWARDS: 6 Q. And you do not know the ages of the 7 various massagists, right? 8 A. No. 9 C. Did you have occasion to clean up after 10 the massages? ae A. Yes. 12 Q. Okay. And that is after both a massage 13 for Jeffrey Epstein, as well as clean up after a 14 massage that Ghislaine Maxwell may have received? 15 A. Yes. 16 Q. And on occasion, after -- in cleaning up 17 after a massage of Jeffrey Epstein or Ghislaine 18 Maxwell, did you have occasion to find vibrators or 19 sex toys that would be left out? 20 MR. PAGLIUSCA: Object to form and 21 foundation. 22 THE WITNESS: Yes, I did. 23 BY MR. EDWARDS: 24 Q. Can you describe the types of vibrators or 25 sex toys that you found left out after a massage MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page15 of 883 Page 53 1 JOHN ALESSI 2 that Jeffrey Epstein had just received or Ghislaine 3 Maxwell had just received? 4 MR. PAGLIUSCA: Object to form and 3 foundation. 6 THE WITNESS: It was probably two to three 7 times, I would say. It was not all the time. 8 I would find things like a dildo, it's called a 9 double. I hate to say it because these ladies. 10 But I find these things, put my gloves on, took 11 it out and rinse it, and put it in 12 Ms. Maxwell's closet. 13 BY MR. EDWARDS: 14 Q. Why would you put the dildo or sex toy in 15 Ms. Maxwell's closet? 16 A. Because I knew that's where they were AT kept. 18 Or How did you know that the sex toys were 19 kept in Ms. Maxwell's closet? 20 As Because I know where everything was in 21 that house. Every single room, every single thing, 22 it was a place, it was placed by me, by the cleaning 23 lady or my wife. Every -- everything that happened 24 in that house, I knew it. 25 Q. Who showed you where the dildo or sex toys MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page16 of 883 Page 54 1 JOHN ALESSI 2 were kept in the house the first time? 3 MR. PAGLIUSCA: Object to form and 4 foundation. D THE WITNESS: Nobody. Nobody show me. 6 BY MR. EDWARDS: 7 0. You just saw it? 8 A. I saw it. 9 Q. So you knew where to put it back? 10 A. Yeah. We had to open the closet, clean 1 the closet, put the clothes in place, put the shoes 12 in place, put everything in place. So it was a 13 matter of tidying things up. 14 Q. Did you ever find any costumes? 15 A. I saw one shiny black costume, but I 16 didn't even know -17 Q. Where did you see it? 18 A The same place. 19 0% In Ms. Maxwell's closet? 20 A Yes. 21 Q And where was Ms. Maxwell's closet in the 22 house? 23 A. In the house? It was in the opposite side 24 of his bathroom. It was her bathroom in the master 25 bedroom. It was in the middle. So it was on the MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page17 of 883 Page 94 1 JOHN ALESSI 2 BY MR. EDWARDS: 3 Q. That demonstrates that she was, I believe, 4 terminated from her employment in 2000. 3: My question to you is: Do you remember 6 what time of year or what month it would have been, 7 whether spring, summer, fall, winter; January, 8 February, December? 9 A. Of what year? 10 Q. Of 2000, that you would have gone to the 11 Mar-a-Lago? 12 A. It wasn't 2000. 13 MR. PAGLIUSCA: Object to form and 14 foundation. 15 BY MR. EDWARDS: 16 Q. Okay. Do you think it was a different 17 year that you went to Mar-a-Lago? 18 A. Yes. 19 Q. Okay. What year do you believe that you 20 went to the Mar-a-Lago to pick Virginia up? 21 A. I think it was 2000 and -- I think it was 22 the summer of 2002. 23 Q. Okay. 24 A. Summer, because I remember that day that I 25 was sweating like hell in the -- in the car, waiting MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page18 of 883 Page 95 1 JOHN ALESSI 2 for Ms. Maxwell to come out of the massage. 3 Q. Okay. So what month of the summer do you 4 remember it being? 3 A. I think in June, July, maybe, 2001. 6 Ow 2000 and what? 7 A. 2001. 8 Q. June, July, 2001, that's when you believe 9 that it was? 10 A. Yes. 1. Q. Okay. And do you remember the month -12 A. No, sorry. Sorry. Not 2001. We left in 13 December 31st. It was 2000 -- the last year that I 14 was working for Jeffrey, when I met Virginia. 15 Q. Your recollection, as you sit here 16 today -17 A. It was 2002. 18 Os -- is that it was June or July of 2002 -19 A. 2002. 20 Q. -- when you met Virginia Roberts at the 21 Mar-a-Lago? 22 A. My recollection. 23 Q. Okay. And other than the fact that you 24 were sweating, what else tells you what month that 25 it was that you remember meeting her at the MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page19 of 883 Page 96 1 JOHN ALESSI 2 Mar-a-Lago? 3 A. It was -- I know it was summer of 2002, 4 and she spoke to -- far away. I wasn't -- I was in 3 the driveway, and she was far away talking to 6 Virginia. She spoke to her maybe five minutes. 7 QO. Okay. 8 A. And she came to the car, and we went home. 9 In the afternoon, about 4:00 or 5:00 in the 10 afternoon, the same day, Virginia came to the house. 11 Q. Who brought her to the house? 12 A. I don't know. She came to the back door, 13 I remember. And she was dressed differently. She 14 came to the house. 15 Q. When you first arrived to the Mar-a-Lago 16 with -- are you driving the car and Ms. Maxwell is 17 in the passenger seat? 18 A. Yes. 19 Q. And could you see Virginia Roberts from 20 the car? 21 A. Yes. 22 Q. Where was she sitting or standing? How 23 far away from the car? 24 A. She was standing right in front of the 25 driveway. This is the Mar-a-Lago, the house, and MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page20 of 883 Page 97 1 JOHN ALESSI 2 here is the spa, and the driveway that's here. I 3 was parked this way, and I would see her with 4 Ms. Maxwell, talking. 5 Q. Did you -6 A. I could not hear what they were saying, 7 but I did see it. 8 Q. Did you park the car or did you stop right 9 there and -10 A. I parked the car because we are not 1 allowed to go into Mar-a-Lago. 12 Q. Okay. Let me finish my question. 13 Did you park the car in a parking space in 14 the parking lot or did you just stop on the side of 15 the road and Ms. Maxwell got out? 16 A. Mar-a-Lago has a -- has a long wide 17 driveway, and on the right of the driveway is -- is 18 the parking spots like this or something. And I 19 parked in one of those spaces. And waiting for her, 20 I think it was over an hour that I wait for her. 21 Q. Okay. So did you watch her first talk 22 EQ: == 23 A. No. At the end. Right at the end, 24 before -- when she was leaving. 25 0. So Ms. Maxwell gets out of the car. And MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page21 of 883 Page 98 1 JOHN ALESSI 2 when you're pulling up to the Mar-a-Lago, could you 3 see Virginia Roberts then? 4 A. No. No. 5 Q. So after you wait an hour, Ms. Maxwell is 6 coming out? 7 A. And then she saw Virginia and she 8 stopped -- she went to her, she talked to her, she 9 came back to the car. 10 Q. And prior to that day, you had never seen 11 Virginia at the house? 12 A. Never. Never. 13 Q. Okay. Did Ms. Maxwell tell you that 14 Virginia's father worked at the Mar-a-Lago? 15 A. I don't think so. I think it was -- I 16 think we find out later, after the -- she says, My 17 father works -- I think it was from Virginia, that 18 she says her father works at Mar-a-Lago. 19 It is information from her. I don't think 20 it was Ms. Maxwell that told me anything. She don't Al. have to -- she don't have to talk to me. I mean, 22 Ms. Maxwell will not go and talk to me about this -23 these people's family. I don't know. She never 24 did. 25 Q. Okay. I only have to go by what I have. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page22 of 883 Page 103 1 JOHN ALESSI 2 I don't remember that day, how she got 3 home. I don't know. I can't remember. 4 Q. After that day, do you recall that she 3 started coming to the house more frequently? 6 A. Yes, she did. 7 0. In fact, did she start coming to the house 8 approximately three times a week? 9 A. Yes, probably. 10 Q. And at times, would you go pick her up? 1. A. Yes. This happened maybe twice, three 12 times. 13 Q. And at times, would you take her home? 14 A. Yes. 15 Q. And did there come a point in time where 16 Virginia starting bringing other girls with her? AT MR. PAGLIUSCA: Object to form and 18 foundation. 19 THE WITNESS: That was maybe two weeks 20 before we left. I saw her bringing some 21 friends with her to the house. And I cannot 22 remember how many times, but I was at the end 23 of our stay. 24 BY MR. EDWARDS: 25 0. At the end of her [sic] stay, you saw when MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page23 of 883 Page 104 1 JOHN ALESSI 2 she would come over to the house, she would bring 3 certain friends who were girls -4 MR. PAGLIUSCA: Object to form and 3 foundation. 6 BY MR. EDWARDS: 7 0. -- to the house, right? 8 A. Yes, females, yes. 9 Q. Do you know how long Virginia had been 10 coming over to the house before she started 11 traveling on an airplane with Ghislaine and Jeffrey? 12 MR. PAGLIUSCA: Object to foundation. 13 THE WITNESS: Not too long. I don't think 14 it was too long after that. 15 BY MR. EDWARDS: 16 Q. Would you drive her to the airport with 1.7 them? 18 A. Occasionally, I think so, yes. I would 19 drive everybody to the airport. My wife would drive 20 the chefs, the service people, the luggage to Jet 21 Aviation. 22 Q. Is that where Mr. Epstein kept his plane, 23 Jet Aviation? 24 A. Yes. 25 QO. At some point did Ghislaine Maxwell become MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page24 of 883 Page 141 1 JOHN ALESSI 2 MR. PAGLIUSCA: Seven. 3 MR. EDWARDS: Seven? 4 (The referred-to document was marked by 3 the court reporter for Identification as 6 Deposition Exhibit 7.) 7 MR. EDWARDS: I apologize, Jeff. I just 8 can't find a copy right now. 9 MR. PAGLIUSCA: I have it. 10 MR. EDWARDS: Okay. 11 BY MR. EDWARDS: 12 Os So this is a composite exhibit. It is 13 four pages. The first one that you're looking at 14 should be -- do you have SAO 01456? 15 MR. PAGLIUSCA: Yes. 16 MR. EDWARDS: Okay. 17 BY MR. EDWARDS: 18 Q. Does the format of this look familiar to 19 you? 20 A. Yes. It looks like the books that we used 21 to have that has -- the message books. 22 0... How would that work? How would that 23 process work? 24 Ais Somebody called, you write it down, and 25 you take the -- you leave the copy in the -- in the MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page25 of 883 Page 175 1 JOHN ALESSI 2 many things? 3 A. Yes, she did. 4 Q. Interesting buildings? 3 A. No. She -- she liked -- she had a dog, 6 and she took a lot of photographs of her dog. And 7 us. And she took photographs of the cars and the 8 house. Everything inside. She had an album full of 9 photographs of people, young girls, girls. And I 10 remember that she had. Like a hobby. 11 Q. Right. 12 You never saw any pictures that were very 13 upsetting to you, though, correct? 14 A. No. No. 15 Q. Okay. And the pictures that you saw were 16 sort of -- would you describe them as being artistic 17 kind of pictures? 18 MR. EDWARDS: Objection, counsel 19 testifying. 20 THE WITNESS: I think so. I don't think 21 they were pornographic. I don't think it was 22 any vaginal or things, you know, female parts 23 showing. It was some girls were topless, 24 taking the sun. It was a beautiful house, it 25) was a beautiful setting, so she took a lot of MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page26 of 883 Page 236 1 JOHN ALESSI 2. CERTIFICATE OF OATH 3 STATE OF FLORIDA ) 4 COUNTY OF MIAMI-DADE ) 5 I, the undersigned authority, certify 6 that JOHN ALESSI personally appeared before me and was duly sworn. - WITNESS my hand and official seal this lst day of June, 2016. 8 9 Kelli Ann Willis, RPR, CRR 10 Notary Public, State of Florida Commission FF928291, Expires 2-16-20 1 heb che poe a ch oR: op ee a See ti oe 12 CERTIFICATE 13 STATE OF FLORIDA 14 COUNTY OF MIAMI-DADE 15 I, Kelli Ann Willis, Registered Professional Reporter and Certified Realtime 16 Reporter do hereby certify that I was authorized to and did stenographically report the 17 foregoing deposition of JOHN ALESSI; that a review of the transcript was not requested; and that the 18 transcript is a true record of my stenographic notes. 19 I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any 20 of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected 21. with the action, nor am I financially interested in the action. 22 Dated this 1st day of June, 2016. 23 24 KELLI ANN WILLIS, RPR, CRR 25 MAGNA® LEGAL SERVICES

EXHIBIT 2 (Filed Under Seal)

b N w oy a x © co 10 11 12 13 14 15 16 ly 18 19 20 21 22 23 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page28 of 883 UNITED STATES DISTRICT COURT for the SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, vs. GHISLAINE MAXWELL Defendant. VIDEO-DEPOSITION OF: TAKEN BY: REPORTED BY: DATE AND TIME: PLACE: APPEARANCES: JAMES MICHAEL AUSTRICH Defendant Karla Layfield, RMR Stenographic Court Reporter Notary Public State of Florida at Large June 23, 2016; 9:03 a.m. Owen & Associates Court Reporters 108 N. Magnolia Avenue, Suite 501 Ocala, Florida Laura A. Menninger, Esquire HADDON, MORGAN & FOREMAN, PC 150 East 10th Avenue Denver, Colorado 80203 Attorney for Defendant Brad Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, FISTOS & LEHRMAN, PL 425 Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Attorney for Plaintiff Also Present: Kenneth Sarsony, Videographer Virginia Giuffre Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w a wo a ~ © Oo 10 11 12 13 14 15 16 ly 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page29 of 883 16 A Yes. Qo Was it is a franchise, if you know? A I know when I first started there, they were corporate, but then they were a franchise. They were bought out. But I'm not sure if when I got there they were a franchise or not. Q Got it. Do you know if Ms. Roberts had any previous employment before she worked at Taco Bell? A I think by the apartment, she worked for KFC for a little while. MS. MENNINGER: Are you looking at Ms. Roberts? THE WITNESS: I'm thinking. I can't remember. I remember something with KFC. They had one really close to us. I think she worked there for a tiny, tiny bit. I'm not sure. MS. MENNINGER: Okay. BY MS. MENNINGER: Q Before the Taco Bell? A Or she could've applied there. It's just in my head. She might have just applied there, and didn't get it, and that's why I brought her to Taco Bell. Q Okay. A Because we were both the night managers. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w x oy a x © © 10 11 12 13 14 15 16 ae 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page30 of 883 Q 10 > 10 D Q aL) No. Do you know about what years this was? Not really. Do you know about how old you were? When, what? I'm just focused on the period of time in which you were living at her parent's house in the trailer. A I was probably 18 when we moved in there. Q And you said you were only there for a couple of months? A Not that I remember. Like, it might have been a little longer. I'm not sure. Q Were you engaged to Ms. Roberts? A Yes. Q When did you become engaged to her? A When we were living in Oakland Park. Q Tell me about the engagement. How did it come about? A Well, we fell in love, and -- I believe it was Valentine's Day when I proposed. Q > > Did you have a ring? Yes. Did she accept? Yes. How long were you engaged? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w a oy a x © © 10 11 12 13 14 15 16 17 18 19 20 21 22 23. 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page31 of 883 30 A Yes -- well, for a while. I mean, I know at the end, I wasn't working anywhere. Q Why weren't you working? A I don't remember the exact reason. Qo Had you quit? A I believe so. I know the pet store let me go for walking on to the other side talking to somebody. But I don't remember why I left Dunkin' Donuts. Q Do you believe that you were fired from Dunkin' Donuts? A No. That pet store was the only time anybody ever fired me. Q That will stick in your brain. A Yeah. Q At the time that you left the pet store, was Ms. Roberts still working there? A Yes. Q And how long do you recall her working there? A Not long. Q I hate to do this to you, but what does "not long" mean to you, weeks, months, days? A Over a month. That's really all I can say. Maybe over a month before she went to work at the Mar-a-Lago or Donald Trump's country club. Q Did she leave the pet store to go work at Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w s wu a x © Oo 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page32 of 883 34 BY MS. MENNINGER: Q Did you know her friend by the name of Tony Figueroa? A Somewhat. QO Tell me what you remember about Tony Figueroa. A Other than him being an idiot, not much. QO Did you have any interactions with Mr. Figueroa? A Very little. Q When do you recall seeing him, like, in what city, I mean? A Up in West Palm Beach. Q Did he come over to your apartment? A I believe so. Q Did you believe them to be having a relationship? A At the very end when I left, yes. Q Was that one of the reasons for your leaving? A One of them. Q What were the others? A Well, after I found out about that, that's when I heard about all the other stuff that was happening. Q What did you hear about all the other stuff? A Well, I mean, after she went to work for Mar-a-Lago then she was, I guess, recruited to go work for Jeff something. I don't remember his last name. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w a oy a x © © 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page33 of 883 35 Q Is that what she told you "she was recruited"? A Yeah. Well, she didn't use those words. But I don't know why else anybody would take -- like, they hired her over there as a massage therapist, but she didn't have any experience. Q At Mar-a-Lago -A At Mar-a-Lago, yes. Then all of a sudden one day, she was working for Jeff, whatever his name was. Q Let me just take a step back. You found out towards the end of your relationship with Ms. Roberts that she was then having a relationship with Mr. Figueroa. Is that right? A I don't know if it was a relationship. But, yes. Q Enough to cause you to think you didn't want to be engaged anymore? A Yes. Q Did you and Ms. Roberts have a fight at that time? A Yes. Q What do you remember about the fight? What do you recall? A I don't recall. I remember us having a fight and then leaving not too long afterwards. Qo You referred to finding out all this other stuff Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

be N w a oy a x © io 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page34 of 883 Qo When you got the apartment in Oakland Park, you got it with Virginia? A Well, yeah. She was living with us -- and Mario. MS. MENNINGER: All right. I think that's all I have. MR. EDWARDS: Okay. THE VIDEOGRAPHER: We're going off the record. This concludes disc one, volume one of the video-deposition of James Michael Austrich. We're going off the record. The time is approximately 11:20 a.m. (Break taken.) THE VIDEOGRAPHER: We're back on the record with disc two, volume one, of the videodeposition of James Michael Austrich. And the time is approximately 11:23 a.m. Thank you. CROSS-EXAMINATION BY MR. EDWARDS: Q Mr. Austrich, as you know, my name is Brad Edwards, and I represent Virginia. A Yes. Q I'm going to ask you some follow-up questions to the questions that you were asked previously. All right? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w s oy a x © © 10 11 12 13 14 15 16 dB) 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page35 of 883 how long we lived there. Q Okay. At some point in time, though, while you're living on her parent's property, it becomes 1999? A Yeah, I believe. QO Okay. And so when you started living at her parent's property, you're 18, she's 15, but at some point in time you turn 19 and she turned 16? A Yes. Q Okay. And at some other point in time, she leaves the job at the pet store? A Pet store, yeah. Q And goes to work at the Mar-a-Lago? A Yes. At Donald Trump's country club, yeah. Q Okay. Donald Trump's country club is called the Mar-a-Lago? MS. MENNINGER: Objection. THE WITNESS: Yeah, that's what I always remember it as. Yes. BY MR. EDWARDS: Q Is that right? MS. MENNINGER: Objection, leading. I do get a chance to object. Leading. BY MR. EDWARDS: Q When you used the term "Mar-a-Lago" and used the term "Donald Trump's country club," are we talking about Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

ay N w a oy a x © Oo 10 11 12 13 14 15 16 ay 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page36 of 883 100 A But if she had to get clean for her job, she would have gotten clean for the job. Q Okay. Do you remember her being hired as a bathroom attendant there, a locker room attendant? A Now that you're saying that, some kind of attendant sounds familiar. But I don't really remember. All I remember is for the massage. As a -- I don't remember exactly what she got hired for at Donald Trump's place. But I just remember the masseuse thing. But as you're saying "the attendant," the attendant sounds familiar because I doubt her father would hire her as a massage therapist without knowing anything. Q So you had known her for some period of time before she gets this job at the Mar-a-Lago, right? A Right. Q Did she have any massage therapy training whatsoever? A No. Q Ever given a massage to anyone? A Not that I remember. Q Ever given a massage to you? A Not until she was already doing the massage stuff. But, no, I don't remember any kind of massage training or even like an inkling for it. Q Okay. Then when she goes to work for Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w x oy a x © Oo 10 11 12 13 14 15 16 1 18 19 20 21 22 23 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page37 of 883 Mar-aused, A Q Mar-aanywhe A at one Q correc A Q 101 Lago, you don't remember, I think is the words you whether Yes. You No, And she worked there for weeks or months? don't remember? not at all. at the time when she gets the job at the Lago, do you remember where you were working, if re? No. of the And t me if Yes. And I mean, I think at that time, I was working places. But I don't really remember where. then, and I believe that you used this word, I'm wrong, she's recruited to work for Jeff? do you remember her telling you that it was an assistant or somebody associated with Jeff that recrui ted her MS. THE MS. THE to work with Jeff? MENNINGER: Objection, leading. WITNESS: I don't remember. MENNINGER: Misstates the testimony. WITNESS: Sorry. I don't remember. All I remember was that somebody got her from there to J eff. MR. EDWARDS: Got it. BY MR. EDWARDS: Owen & Associates Court Reporters BP. 352. O. Box 157, Ocala, Florida 624.2258 * owenassocs@aol.com

b N w s oy a x © 0 10 11 12 13 14 15 16 17 18 19 20 21 22 23 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page38 of 883 109 Q Then there's months; November, December. A So this is the year 2000, and these are the months? MS. MENNINGER: Objection to this entire line of questioning. The witness has no foundation for talking about this particular document. BY MR. EDWARDS: Q Okay. So do you know how long that -- as you sit here today, do you remember how long Virginia had been going over to Jeff's house before she started traveling on an airplane with him? MS. MENNINGER: Objection, foundation. THE WITNESS: No. BY MR. EDWARDS: Q It could be months, it could be a year? MS. MENNINGER: Objection, foundation. THE WITNESS: I don't think it -- I don't think she was there for very long without doing traveling. BY MR. EDWARDS: Q But in your mind, you can't tell me how long "very long" is? A No, I mean, I don't. Q Okay. And is there anything that would tell you the year or the month in which you remember Virginia first Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w a oy a x © co 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page39 of 883 110 going over to Jeff's house? A Not really. Q There's nothing I could really show you in this world that would remind you right now? A No. Q Okay. Before going over to work with Jeff, did Virginia have any massage experience? A No. Qo When -- I think you said with respect to "bringing other girls, that sounds familiar," what other girls do you remember her bringing? Do you remember their names? A I don't remember names. MS. MENNINGER: Objection, foundation. BY MR. EDWARDS: Q Did you ever drive any of the other girls over to Jeff's house? A I don't think so. Q Okay. How many times did you to to Jeff's house? A A few times. Like, I think I went -- I think I dropped her off and somebody always brought her back. I don't really remember picking her up too much. Q Okay. And in the beginning, she was telling you that she was performing massages? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w s oy a x © Oo 10 11 12 13 14 15 16 A 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page40 of 883 127 A Yeah, something like that. Q Do you know what time of year? A No. Qo Do you know whether the spa at Mar-a-Lago closes during the summers? MR. EDWARDS: Form. THE WITNESS: No, I have no idea. BY MS. MENNINGER: Q You don't know how she got the job with Jeff? A No. I know somebody -- somebody -- like, that's why I said "recruited" -- that's the only word I can think of -- that worked for Jeff. Q Why do you use A Because that's football or everything. of, you recruit somebody. QO Hired her? A Yeah, I guess. fast thing. Q You don't know A No. Q You don't know A No. QO You don't know A Nope. the word "recruited"? the only word -- I don't know, That's the only word I can think It was -- it was just a very who that person was? what she said to that person? what that person said to her? Owen & Associates Court Reporters P.0:, Box 157, 352.624.2258 * Ocala, Florida owenassocs@aol.com

be N w oy a x © © 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page41 of 883 128 Q Do you remember her coming home and saying "I got a job with Jeff"? A I remember she said she got a job with Jeff. Q Did she tell about that job? A I think it was -- I think at the time it was for massage therapy, like, she was going to be a masseuse. Q And she was excited about it? A Yeah. Q She wasn't sad about it? A Not that I remember. But I really don't remember much from back then. Q She wasn't crying when she came home and said "I just got a job with Jeff," right? A No. Q You're guessing that you -- she got the job with Jeff before you moved into the Bent Oak apartment, but you don't know. Correct? MR. EDWARDS: Form THE WITNESS: YeS- But I would think we would have had to have had the money by then. So that was the only time she was making real good money. BY MS. MENNINGER: Q And do you know how much that apartment cost? A I know it was expensive. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w a oy a x © o 10 11 12 13 14 15 16 17 18 19 20 21 22 23 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page42 of 883 146 CERTIFICATE STATE OF FLORIDA COUNTY OF MARION I, Karla Layfield, RMR, Stenographic Court Reporter, do hereby certify that I was authorized to and did stenographically report the foregoing deposition of James Michael Austrich; that said witness was duly sworn to testify truthfully; and that the foregoing pages, numbered 1 through 145, inclusive, constitute a true and correct record of the testimony given by said witness to the best of my ability. I FURTHER CERTIFY that I am not a relative or employee or attorney or counsel of any of the parties hereto, nor a relative or employee of such attorney or counsel, nor am I financially interested in the action. WITNESS MY HAND this ___ day of June, 2016, at Ocala, Marion County, Florida. Karla Layfield, RMR Stenographic Court Reporter Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

EXHIBIT 3 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page44 of 883 Page 1 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS VIRGINIA L. GIUFFRE, Plaintiff, -againstGHISLAINE MAXWELL, Defendant. 250 N. Australian Avenue, Suite 1400 West Palm Beach, Florida 33401 Friday, September 9, 2016 8:35 a.m. - 2:08 p.m. CONFIDENTIAL VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN Taken before Darline M. West, Registered Professional Reporter, Notary Public in and for the State of Florida At Large, pursuant to Notice of Taking Deposition filed by the Plaintiff in the above cause. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page45 of 883 Page 74 1 J. Epstein - Confidential 2 BY MR. CASSELL: 3 Q. Isn't it true that Maxwell led Virginia up 4 to your Palm Beach mansion massage room the first 3D: time you met her? 6 MR. PAGLIUCA: Object to form and 7 foundation. 8 THE WITNESS: Fifth. 9 BY MR. CASSELL: 10 Q. You saw Maxwell bringing Virginia up to 11 your room, true, sir? 12 MR. PAGLIUCA: Object to form and 13 foundation. 14 THE WITNESS: Fifth. 15 BY MR. CASSELL: 16 0. Isn't it true that it was standard AT operating procedure for Maxwell to bring underage 18 girls up to your room? 19 MR. PAGLIUCA: Object to form and 20 foundation. 21 THE WITNESS: Fifth. 22 BY MR. CASSELL: 23 Q. Isn't it true that it was standard 24 operating procedure for Maxwell to bring underage 25 girls up to your room for you to sexually abuse? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page46 of 883 Page 116 1 J. Epstein - Confidential 2 THE WITNESS: Fifth. 3 BY MR. CASSELL: 4 Q. In 2000, Virginia was approached by 5 Maxwell, true? 6 MR. PAGLIUCA: Object to form and 7 foundation. 8 THE WITNESS: Fifth. 9 BY MR. CASSELL: 10 Q. Maxwell was one of the main women whom you 1. used to procure underage girls for sexual activities, 12 true? 13 MR. PAGLIUCA: Object to form and 14 foundation. 15 THE WITNESS: Fifth. 16 BY MR. CASSELL: 1.7 Q. It was your understanding that Maxwell met 18 Virginia at the Mar-a-Lago Club in Palm Beach in 19 2000, true? 20 MR. PAGLIUCA: Object to form and 21 foundation. 22 THE WITNESS: Fifth. 23 BY MR. CASSELL: 24 Q. In 2000, you were a member of the 25 Mar-a-Lago Club, true? MAGNA® LEGAL SERVICES

10 1: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page47 of 883 Page 117 J. Epstein - Confidential MR. PAGLIUCA: Object to form. THE WITNESS: Fifth. BY MR. CASSELL: Q. In 2000, Ms. Maxwell had access to the Mar-a-Lago Club, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. The reason Maxwell had access to the Mar-a-Lago Club in 2000 was because of your connections to the club, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Maxwell was a primary co-conspirator in your sexual abuse scheme, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Maxwell was a primary co-conspirator in your sex trafficking scheme, true? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page48 of 883 Page 118 1 J. Epstein - Confidential 2 MR. PAGLIUCA: Object to form and 3 foundation. 4 THE WITNESS: Fifth. D BY MR. CASSELL: 6 Q. Maxwell herself regularly participated in 7 your sexual exploitation of minors, true? 8 MR. PAGLIUCA: Object to form and 9 found. 10 THE WITNESS: Fifth. 11 BY MR. CASSELL: 12 Q. In 2000, Maxwell herself regularly 13 participated in your sexual exploitation of minors, 14 true? 15 MR. PAGLIUCA: Object to form and 16 foundation. 17 THE WITNESS: Fifth. 18 BY MR. CASSELL: 19 Q% Maxwell herself regularly participated in 20 your sexual exploitation of Virginia, true? 21: MR. PAGLIUCA: Object to form and 22 foundation. 23 THE WITNESS: Fifth. 24 BY MR. CASSELL: 25 Q. Did Maxwell participate in your sexual MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page49 of 883 Page 376 1 REPORTER'S CERTIFICATE 2 STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 I, DARLINE MARIE WEST, RPR, certify that I was 6 authorized to and did stenographically report the 7 foregoing deposition; and that the transcript is a 8 true record thereof. 9 10 I further certify that I am not a relative, A. employee, attorney, or counsel of any of the parties, 12 nor am I a relative or employee of any of the 13 parties' attorney or counsel connected with the 14 action, nor am I financially interested in the Eo action. 16 17 Dated this 13th day of September 2016. 18 19 20 21 22 DARLINE MARIE WEST, RPR 23 24 25 MAGNA® LEGAL SERVICES

EXHIBIT 4 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page51 of 883 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE: 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. VIDEOTAPED DEPOSITION OF TONY FIGUEROA Volume 1 of 2 Pages 1 - 157 Taken at the Instance of the Defendant DATE: Friday, June 24, 2016 TIME: Commenced: 8:59 a.m. Concluded: 1:22 p.m. PLACE: Southern Reporting Company B. Paul Katz Professional Center (SunTrust Building) One Florida Park Drive South Suite 214 Palm Coast, Florida 32137 REPORTED BY: LEANNE W. FITZGERALD, FPR Florida Professional Reporter Court Reporter and Notary Public Southern Reporting Company www.Southernreporting.com - (386)257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page52 of 883 82 Q Right? A Yeah. Q And she travelled the world? A Uh-huh (affirmative). Yes. Q Did JJ say there was anything weird about her job? A No. MR. EDWARDS: Object to the form. BY MS. MENNINGER: Q Did you know whether she had any massage training? A I did not. Like I said, the past three -three or four years before then, I had no contact with her whatsoever. So I had no clue what she was certified in or had done with her life. Q Okay. I would like to take about a fiveor ten-minute break, if that's okay with you. A That's fine. THE VIDEOGRAPHER: The time is 10:13. We are off the record. The time is 10:27. We are back on the record. MS. MENNINGER: All right. I would like to mark as an exhibit now Defendant's Exhibit 4. Southern Reporting Company www.Southernreporting.com - (386) 257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page53 of 883 88 certain times and stuff. And it would just -- you know, it just did not make sense to me that it it was just a masseuse, you know. Like I said, he's a billionaire. You can afford another masseuse. Why do you need her, you know. Q Do you know whether he -(Brief interruption.) A Let me turn this down. Qo Sorry. A I'm sorry. (Briefly off the record.) Q Do you know whether he had other masseuses at the time? A I -- I really don't know. All I know is he would have Virginia, obviously, go out and look for other girls, also, to bring back, as well. QO And how do you know that? A Because she had explained to me that sometimes when she would go out on trips that her and Ms. Maxwell and stuff would go out to, like, clubs and stuff and just try and pick up girls to bring back, so... Q That's what Virginia told you? A Yes. Q All right. Did any of your information -Southern Reporting Company www.Southernreporting.com - (386) 257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page54 of 883 89 (Brief interruption.) A I thought I muted it. Q Did any of your information come from anywhere other than Virginia? A No. MR. EDWARDS: Object to the form. A Like I said, I did not talk -—- I did not really speak to any of them other than, you know, hi, how's it going and stuff like that, until I had actually met Jeffrey. And then he was the only one I ever really spoke with. I had met Ms. Maxwell a couple of times, but it was never, like, you know, actual conversations, so... BY MS. MENNINGER: Q All right. Well, let me -- when did you meet Jeffrey? A I'd probably say -- probably a few months after I had moved in with her. Q Okay. And how did you come to meet Jeffrey? A Dropping her off over at his mansion. Q And did you drop her off using her car? A Yes. Qo And so she just asked you: Can you take me over there? Southern Reporting Company www.Southernreporting.com - (386) 257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page55 of 883 90 A Yeah. Q And did she tell you where to go? A Yeah. She told where he lived and everything. And then obviously I got to take the car, because she was going somewhere else in the world and did not need it, so... Q You were dropping her off for a multi-day trip? A Yeah. She would normally go about two weeks out of every month, so... Q Two weeks straight? A Yeah. It was two weeks home and two weeks gone, basically. Q Did you always take her to his house, OKs as A Yeah. Pretty much every time I took her there, it was always to his mansion. I picked her up one time -- maybe it was a couple of times -from the jet stream place. But pretty much every single time it was at the hou- -- at the mansion. (Brief interruption.) Q Okay. So you're -- is that your phone? I'm -A No, it is. I thought I muted it. QO That's okay. Southern Reporting Company www.Southernreporting.com - (386) 257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page56 of 883 92 talking like that, so... Q Okay. Where did your first conversation with Jeffrey take place? A I'm pretty sure it was in the kitchen or the living room. Q Inside the house? A Yeah, it was inside the house. I've never seen him anywhere else other than in the mansion or getting off the jet. QO So you were allowed to go inside the house -A Yeah. Q -- with Ms. Roberts? A Yeah. But I never went upstairs. I've only been in the kitchen, the living room, and by the pool. Q How many times would you estimate that you had been over to the house? A I mean, at least once every two weeks to drop her off, you know. Q Was there a period of time between 2001 and when she left in 2002 where she was not working for Jeffrey? A Yes. Q What period of time was that? Southern Reporting Company www.Southernreporting.com - (386) 257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page57 of 883 93 A It was pretty much, like, when she was actually working as a server. Like, basically because we were trying to not have her go back there. Like, she did not want to go back there. And we were trying to just work without needing his money, you know. Q All right. And if I can re-call up that Exhibit 2, can you see from here when about she was working as a server? A March 4th, '02. Q Do you know about how long she worked there? A I do not. I'm not sure. Q Days? Weeks? Months? Anything? A I really have no clue. Q Okay. How old was Ms. Roberts in 2002, if you know? A I'd probably say, like, 18 or so, maybe. Q If her birthday is in '83 -A Oh, if it's in '83, then I'd say -because I was born in '82, so a year younger than me would be... Q 18, 19? A Yeah, somewhere around there. MR. EDWARDS: Object to the form. Southern Reporting Company www.Southernreporting.com - (386) 257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page58 of 883 96 Q I guess my question is: Did she ever tell you that she had started as a regular masseuse for him and then transitioned to something other than a masseuse? A No. She never said that it transitioned. But she ended up explaining to me what had happened before, so... QO What has —- what is that? A That her and Ms. Maxwell and Jeffrey would obviously be doing stuff, all three of them together. Like I said, that they would all go out to clubs to pick up girls and try and find them to bring back for Jeffrey. And then she told me about how, like I said, her and Ms. Maxwell and Jeffrey were all intimate together on multiple occasions. Qo When did she tell you this? A I'm not exactly sure on the dates. Q Was it while you were still together? A Yes. Q Did you -- had you met Ms. Maxwell? A Yeah, I had met her a couple of times. QO When did you meet Ms. Maxwell? A Dates, I'm unsure of. But it was pretty much, like I said, at Jeffrey's house in the kitchen. Southern Reporting Company www.Southernreporting.com - (386) 257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page59 of 883 97 Q Was it earlier in the time you were with her, or.. A It was about -- I'd say about six months or so. I don't know. I'm not exactly positive. Q All right. So at the time you met Ms. Maxwell, had Ms. Roberts already told you that she had been intimate? A No. She had told me about that, I believe, after I had max- -- after I had already met her. Q Okay. And tell me everything that you remember about what Ms. Roberts said about being intimate with Ms. Maxwell and Mr. Epstein at the same time. A I remember her talking about, like, strap-ons and stuff like that. But, I mean, like I said, all the details are not really that clear. But I remember her talking about, like, how they would always be using and stuff like that. Q She and Ms. Maxwell and Mr Epstein would used strap-ons? A Uh-huh (affirmative). Q How did you feel about that? A I just -- obviously not happy about it. Q What did you say? Southern Reporting Company www.Southernreporting.com - (386) 257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page60 of 883 103 A I did not. Q When the FBI interviewed you, did you mention this to them? A I mentioned -- anything they asked me, I did not hold anything back. Q Okay. Do you recall specifically talking about sex with the Prince? A I -- I don't recall talking to them about that, but, I mean, it's -- it could be possible. Q Other than sex with the Prince, is there anyone else that Jeffrey wanted Ms. Roberts to have sex with that she relayed to you? A Mainly, like I said, just Ms. Maxwell and all the other girls. Q Ms. Maxwell wanted -- Jeffrey wanted Virginia to have sex with Ms. Maxwell? A And him, yeah. Qo And did she tell you whether she had ever done that? A Yeah. She said that she did. Qo And when did she tell you that? A I'm not sure on the date. Q And what did she describe having happened? A I believe I already told you that. With the strap-ons and dildos and everything. Southern Reporting Company www.Southernreporting.com - (386) 257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page61 of 883 157 CERTIFICATE OF REPORTER STATE OF FLORIDA ) COUNTY OF VOLUSIA ) I, Leanne W. Fitzgerald, Court Reporter, do hereby certify that I was authorized to and did stenographically report the deposition of TONY FIGUEROA; and that the foregoing transcript is a true record of my stenographic notes. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorneys or counsel connected with the action, nor am I financially interested in the action. Dated this 5th day of July, 2016. Leanne W. Fitzgerald, FPR Florida Professional Reporter Digital Certificate Authenticated By Symantec Southern Reporting Company www.Southernreporting.com - (386) 257-3663

Case 18-2868, Document 283, 08/09/2019, 2628241, Page62 of 883 158 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE: 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. VIDEOTAPED DEPOSITION OF TONY FIGUEROA Volume 2 of 2 Pages 158 - 258 Taken at the Instance of the Defendant DATE: Friday, June 24, 2016 TIME: Commenced: 8:59 a.m. Concluded: 1:22 p.m. PLACE: Southern Reporting Company B. Paul Katz Professional Center (SunTrust Building) One Florida Park Drive South Suite 214 Palm Coast, Florida 32137 REPORTED BY: LEANNE W. FITZGERALD, FPR Florida Professional Reporter Court Reporter and Notary Public Southern Reporting Company www.Southernreporting.com - (386)257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page63 of 883 168 A Yes. Q All right. And that belief was based on Virginia telling you that? A And JJ and Michael. Q Okay. So you had heard from some other people, and then later -A Yeah. Before she had come back to the apartment, they said that she was a masseuse for this guy. And then when she came back, she told me. Q All right. Once you started dating her again -- I'm sorry. Prior to dating her. Go back to the first time you were dating her. Did she have money? A No. Q All right. Was she able to afford her own place? A No Q Was she doing massages, at all? A No Q All right. Fast forward to the second time when you get back together with her sometime in 2001. A Uh-huh (affirmative). Q Did she appear to you to have any massage training? Southern Reporting Company www.Southernreporting.com - (386) 257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page64 of 883 169 A No. QO As a seventeen-year-old at that time, was she able to afford things? MS. MENNINGER: Objection. Form. Foundation. BY MR. EDWARDS: Q Did she have money -A She had money. Qo -- while working with Jeff? And was the money in the form of cash? A Yes. Q And did she always have cash? A Yes. Q And how was the apartment paid for? MS. MENNINGER: Objection. Form. Foundation. A Cash. BY MR. EDWARDS: Q apartment? A Q would pay? A s And did you see how she was paying for the I did not watch her pay the bill, but... Okay. When you would go to dinner, who Just whoever. MS. MENNINGER: Objection. Form. outhern Reporting Company www.Southernreporting.com - (386) 257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page65 of 883 200 MS. MENNINGER: Objection. Form. Foundation. A For Jeffrey. BY MR. EDWARDS: Q All right. Let me fix this. Ghislaine -when Ghislaine Maxwell would call you during the time that you were living with Virginia, she would ask you what, specifically? MS. MENNINGER: Objection. Form. Foundation. A Just if I had found any other girls just to bring to Jeffrey. BY MR. EDWARDS: Q Okay. A Pretty much every time there was a conversation with any of them, it was either asking Virginia where she was at, or asking her to get girls, or asking me to get girls. Q All right. Let's go to that second category you just identified, which is asking Virginia to get girls. How many times were you ina room where specifically Ghislaine Maxwell would ask Virginia to bring girls? A None that I can recall. Q Okay. How many times -- when you say they Southern Reporting Company www.Southernreporting.com - (386) 257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page66 of 883 228 went with Virginia, and you dropped her off; and some occasions you went inside? A Yeah. Q And some of the occasions you went inside, you hung out by the pool? A Yes. Q Or in the kitchen with the chef? A Yeah. Q All right. And in the total of all the times that you went inside the house, you saw Ms. Maxwell -- I think you got up to six times? A Yeah, about five or six times. Q All right. Total? A Total. QO That's not five or six times where -A That was period, all together. Q -- you brought girls? A No. All together, period. Q All right. I thought you said when I was asking you questions that Ms. Maxwell never asked you to bring girls. A I don't remember saying that. Qo Okay. Well, tell me. When did Ms. Maxwell ask you to bring a girl? A Never in person. It was, like, literally, Southern Reporting Company www.Southernreporting.com - (386) 257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page67 of 883 229 like, on the phone maybe, like, once or twice. Q All right. Did Ms. Maxwell call you frequently? A No. Q All right. How many times do you think Ms. Maxwell called you, at all? A I'd just say that probably a just a few, a couple of times. Maybe once or twice. Q One or two -— A The majority of the time it was pretty much his assistant. Q How do you know Ms. Maxwell's voice? A Because she sounds British. Q So someone with a British accent called you once or twice and asked for -A Well, she told me who she was. Qo Okay. And what did she say when she called you and asked you to bring girls? A She just said, "Hi. This is Ghislaine. Jeffrey was wondering if you had anybody that could come over." Q Okay. When did that happen? A I'm not exactly sure on the time frame. Q Was it after the Roadhouse Grill or before? Southern Reporting Company www.Southernreporting.com - (386) 257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page68 of 883 248 Q So the thing that Virginia was tired of -just so that the record is clear -- well, I'll let you answer in your words. Just be clear. What was it that Virginia was trying to get away from and stop with respect to working at Jeffrey Epstein's house? MS. MENNINGER: Objection. Form, foundation -- as to Virginia's thought processes. A To stop being used and abused. BY MS. MENNINGER: Q How do you know that? MS. MENNINGER: Objection. Form. Foundation. A Due to all the things that I have come to -- that have been brought to light, and in the experiences that I've had, and the conversations that I have had with her. Like, it just all adds up to: that; so... BY MS. MENNINGER: Q When Virginia was wanting to get out, did she ever express that it was the times of work that she was trying to get away from? A No. Q Okay. What was she specifically Southern Reporting Company www.Southernreporting.com - (386) 257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page69 of 883 251 Q Was she getting paid as much as she was getting paid to work for Jeff Epstein? A Definitely not. Q She no longer had cash all around? A Nope. Q You mentioned that there was -- you had several conversations with Virginia when she was discussing them wanting -- or I think the word you used was force, but later we tried to clarify that, but them forcing her to have sex with Prince Andrew. Do you remember that? A Yeah. Q And that you expressed that you were worried for her safety if she were to decline that? A Yes. QO What about your conversation with Virginia on that particular occasion made you worried for Virginia's safety? A Just the way she was talking to me. Like, she just sounded scared. Q And what -- what -- try to dig back and remember what exactly she was saying and how she was saying it, if you could just describe that for us. A She said that she went to go in -- I remember at one time she was talking to me about how Southern Reporting Company www.Southernreporting.com - (386) 257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page70 of 883 258 CERTIFICATE OF REPORTER STATE OF FLORIDA ) COUNTY OF VOLUSIA ) I, Leanne W. Fitzgerald, Court Reporter, do hereby certify that I was authorized to and did stenographically report the deposition of TONY FIGUEROA; and that the foregoing transcript is a true record of my stenographic notes. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorneys or counsel connected with the action, nor am I financially interested in the action. Dated this 5th day of July, 2016. Leanne W. Fitzgerald, FPR Florida Professional Reporter Digital Certificate Authenticated By Symantec Southern Reporting Company www.Southernreporting.com - (386) 257-3663

EXHIBIT 5 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page72 of 883 GIUFFRE VS. MAXWELL Deposition VIRGINIA GIUFFRE 05/03/2016 Agren Blando Court Reporting & Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-0017

Case 18-2868, Document 283, 08/09/2019, 2628241, Page73 of 883 Agren Blando Court Reporting & Video, Inc. IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS CONFIDENTIAL VIDEOTAPED DEPOSITION OF VIRGINIA GIUFFRE May 3, 2016 VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. APPEARANCES: FAMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. By Brad Edwards, Esq. 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954.524.2820 brad@pathtojustice.com Appearing on behalf of the Plaintiff BOIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. (For Portion) 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301-2211 Phone: 954.356.0011 smccawley@bsfllp.com Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE 5/3/2016

Case 18-2868, Document 283, 08/09/2019, 2628241, Page74 of 883 Agren Blando Court Reporting & Video, Inc. APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura A. Menninger, Esq. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 lmenninger@hmflaw.com jpagliuca@hmflaw.com Appearing on behalf of the Defendant Also Present: Brenda Rodriguez, Paralegal Nicholas F. Borgia, CLVS Videographer VIRGINIA GIUFFRE 5/3/2016

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page75 of 883 Agren Blando Court Reporting & Video, Inc. you don't. Do you have any reason to believe that any of your previous sworn statements that you have made are not true? A No. MR. EDWARDS: I just object and ask that if we're going to ask the witness questions about any of her statements in whole or in part that the witness be allowed to see the statement, review the statement and then answer your questions. Q (BY MS. MENNINGER) You may answer the question. A Can you reask the question? I'm sorry. Q Do you have any reason to believe that any of your prior sworn statements are untrue? A I have no reason to believe that my prior statements are untrue. Q Has anyone told you to say something that was not true in connection with this case? A No, ma'am. Q All right. I'd like to start witha lawsuit that you filed under the caption Jane Doe versus Jeffrey Epstein. Do you recall that lawsuit? A I believe so. VIRGINIA GIUFFRE 5/3/2016 16

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page76 of 883 Agren Blando Court Reporting & Video, Inc. (Exhibit 1 marked.) Q (BY MS. MENNINGER) I'm going to show you an exhibit that we are marking as Defendant's Exhibit 1. MR. EDWARDS: Can I see that for a second? I'd just like to make an objection on the record for the misidentification of this document. While there was a lawsuit filed under the style of Jane Doe versus Jeffrey Epstein, Jane Doe was not Virginia Giuffre. And the lawsuit that's now being handed to this witness is Jane Doe 102 versus Jeffrey Epstein. Is that the document we're talking about? MS. MENNINGER: Counsel, if you have an objection, you should state the basis for your objection in a non-leading, non-suggestive manner. If you have any other record to make, you can do so in a pleading filed with the Court. MR. EDWARDS: Sure. My objection is you've misrepresented what you've handed the witness. I want to make sure that the witness is holding what you actually want her to be holding as opposed to the lawsuit you said that you were going to hand her. That's it. MS. MENNINGER: Counsel, I will ask the VIRGINIA GIUFFRE 5/3/2016 17

10 11 12 13 14 1S 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page77 of 883 Agren Blando Court Reporting & Video, Inc. January 19th, 2015? A At the very top of the page it says January 21st, 2015. Q The date it was filed. Is there a date just above the signature block? A Oh, yes, sorry. Yes, there is. Q And what date -- what date was that? A The 19th day of January, 2015. Q Okay. And this document is something that you believe contains the truth, correct? A To the best of my knowledge at the time, yes. Q All right. Did something change between the time then and today that makes you believe that it's not all accurate? A Well, as you can see, in line 4 on page 1, I wasn't aware of my dates. I was just doing the best to guesstimate when I actually met them. Since then I've been able to find out that through my Mar-a-Lago records that it was actually the summer of 2000, not the summer of 1999. Q Oh, I'm sorry. Are you back on page 1? A On the first page. Q Okay. A Yes. VIRGINIA GIUFFRE 5/3/2016 25

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page78 of 883 Agren Blando Court Reporting & Video, Inc. MR. EDWARDS: Objection. Asked and answered. Q (BY MS. MENNINGER) You may answer. MR. EDWARDS: Answer again. A Again, I wouldn't say it's untrue. Untrue would mean that I would have lied. And I didn't lie. This was my best knowledge at the time. And I did my very best to try to pinpoint time periods going back such a long time ago. It wasn't until I found the facts that I worked at Mar-a-Lago in 2000 that I was able to figure that out. Q (BY MS. MENNINGER) And approximately when did you learn those facts about the dates you worked at Mar-a-Lago? A I would say it was mid-2015. Q Mid-2015 is the first time you became aware of the dates -A I don't know the exact -Q If you could just let me finish. A I'm sorry. Q That's all right. Approximately mid-2015 when you learned the true dates that you had worked at Mar-a-Lago? A That's correct. Sorry. VIRGINIA GIUFFRE 5/3/2016 28

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page79 of 883 Agren Blando Court Reporting & Video, Inc. MR. EDWARDS: Object to the form. A Uhm, I don't know, to be honest. Q (BY MS. MENNINGER) And in what order did Taco Bell, Publix and Mar-a-Lago go, and the aviary, sorry? A Oh, I would have to guess. Do you want me to guess? Q Sure. A Um, I would say Publix. And then, I think that's when I helped my boyfriend out at Taco Bell and then I think the aviary. Q And where was the Taco Bell? A I was living in Fort Lauder -- I think it was Fort Lauderdale. Don't quote me on that, but somewhere in Florida, Broward County, something like that. Q And who were you living with at that time? A Michael. His name is James, but Michael. Q So you were living with Michael when you worked at the Taco Bell, right? A Yes, I was living with him. Q And you worked with Michael when you worked at the Publix, correct? A No. Q Okay. So Publix came after Taco Bell or VIRGINIA GIUFFRE 5/3/2016 53

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page80 of 883 Agren Blando Court Reporting & Video, Inc. Q Whatever address you were living at, at the time you started at Mar-a-Lago. A Hn LOxehatchee, Florida 33470. Q How is it that you came to work at Mar-a-Lago? A My dad is a maintenance manager or supervisor, I don't know what you call it. But he worked in the maintenance department, mostly on tennis courts, working on the air conditioning, helping set up for functions. And he got me a summer job there. Q Okay. And you said you were on a break? A Yes. Q What were you on a break from? A I think like -- this is going back so long now, but I was attempting to get my GED. And it, summer came, so school stops during the summertime here in America, and I got a summer job. Q All right. And where were you in school? A I don't actually know the name of the place. It's -- yeah, I know. Q A GED place? A Yeah, it was, like, I was previously in Royal Palm Beach High School, but, I mean, because of VIRGINIA GIUFFRE 5/3/2016 56

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page81 of 883 Agren Blando Court Reporting & Video, Inc. Q Okay. If I can direct your attention back to Defendant's Exhibit 12 at page 15. And under the heading Response to Interrogatory Number 9, do you see that where it says -A Yes. Q -- Ms. Joffrey (pronouncing) -- Giuffre, excuse me, responds as follows? A Yes. Q Okay. It says you worked as a locker room attendant for the spa area, correct? A Yes. Q And it says records produced in this case identify the date of employment as 2000, correct? A Yes. Q What records that were produced in this case cause you to believe that the employment began in 2000? A Uhm, is this going back to another question that I'm not allowed to answer? Q No. A I have seen the documents, and I know that my employment now was in 2000. Q What documents did you see that caused you to make that answer? A The Mar-a-Lago employment documents. VIRGINIA GIUFFRE 5/3/2016 61

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page82 of 883 Agren Blando Court Reporting & Video, Inc. masseuses had their own uniforms. Q What did the masseuses' uniform look like? A I don't remember. Q No recollection at all? A None whatsoever. Q Color? A No, sorry. I remember mine. Q Okay. How did it come to pass that you were no longer working at Mar-a-Lago in two to three weeks? A I was approached by Ghislaine Maxwell. Q Okay. And how long had you been working at Mar-a-Lago when you were approached by Ghislaine Maxwell? A Roughly two to three weeks. Q Okay. Where in the spa were you when you were approached by Ghislaine Maxwell? A Just outside the locker room, sitting where the other girl that works there usually sits. She was away from the desk. I was reading a book on massage therapy. Q Was that indoors or outdoors? A Outdoors. Q Okay. And what -- were you in the sun or in the shade? VIRGINIA GIUFFRE 5/3/2016 111

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page83 of 883 Agren Blando Court Reporting & Video, Inc. wanted to aim for something higher than being a locker room attendant one day. And. Yeah. Q What was the name of the massage therapist that you were speaking with? A Oh, I have no idea. Q Can you give me any physical description of any of them? A Um, there was one who had blonde short hair. There was -- I would say there's probably about four massage therapists that work in there. So, I mean, I don't remember all of them. Q Okay. What time of day was it? MR. EDWARDS: Object to the form. A Afternoon. Q (BY MS. MENNINGER) How late? A Anywhere between 2 to 4. Q And what time did you get off of work? A I believe I got off at 5. Q And what was the rest of your conversation with Ms. Maxwell? I'm sorry, I don't think you finished. A Thank you. Well, she noticed I was reading the massage book. And I started to have chitchat with her just about, you know, the body and the anatomy and how I was interested in it. And she VIRGINIA GIUFFRE 5/3/2016 116

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page84 of 883 Agren Blando Court Reporting & Video, Inc. told me that she knew somebody who was looking for a traveling masseuse. And I said, Well, I don't have any accreditations. This is the first book I've ever read. She goes, That's okay. I know somebody. We can train you. We can get you educated. You know, we can help you along the way if you pass the interview. If the guy likes you, then, you know, it will work out for you. You'll travel. You'll make good money. You'll be educated, and you'll finally get accredited one day. Q Okay. A She finished off by, you know, giving me her number. And I told her I'd have to ask my dad. And I called my dad. I ran over, actually, to see my dad, talked to him. He said it would be okay. I used the phone from Mar-a-Lago to call her and tell her that I was allowed to come over. And she said, Great. Meet me here at -- I don't remember the exact address, but it was El Brillo Way in Palm Beach -- after you get off. And my dad drove me. Q Did you write down her add -- the address that she gave? VIRGINIA GIUFFRE 5/3/2016 117

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page85 of 883 Agren Blando Court Reporting & Video, Inc. A Yes. Q Did you write down her phone number? A Yes. Q So did you go run and talk to your dad while she was still there? A No, I believe she left. And she told me to ask my dad and then to give her a phone call. Q Okay. Did she ask you your age when she had that conversation with you? A No, she did not. Q Did you tell her your age? A No, I did not. Q And so somewhere you wrote down a phone number to call her back at? A Um-hum. Q All right. And where did you write that down? A Probably just a piece of paper lying around the desk. Q Okay. But you don't remember? A I mean, no, I don't have that piece of paper anymore, so no. Q Okay. And did you write down an address? A Yes. Q And what number do you think you called? VIRGINIA GIUFFRE 5/3/2016 118

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page86 of 883 Agren Blando Court Reporting & Video, Inc. Q When did you get your first car? A After my trip to London to meet Prince Andrew. Q Okay. What kind of car did you get? A A Dodge Dakota. And did you purchase that yourself? Yes, I did. And how much did it cost? Pr O PF 0 I don't remember off the top of my head how much it cost. Q Who did you buy it from? A My dad helped me bargain with it. I don't remember where we bought it from. Q And was the title put in your name or your dad's name? A I think the title was put in my name. I think. I mean, my dad was with me. I've never registered a car or anything like that before. So -Q So that was your first time? A Yes. Q Memorable, right? A Yes. Q When you got there, a butler or someone answered the door, is that what you said? A No, Ghislaine answered the door. VIRGINIA GIUFFRE 5/3/2016 120

10 11 12 13 14 1S 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page87 of 883 Agren Blando Court Reporting & Video, Inc. A Yes. Q Who else was at home when you got home? A My mom, my dad and my brother. Q Which brother? A Sky. Q And anyone else who was there at the time? A I believe Michael might have been living with me at that time. So he might have been there. Q Do you recall if he was there when you got home? A I don't really remember. I remember what I did when I got home, that I basically made a beeline for the bathroom. Q Let me ask you a question. Michael was living with you at that home, at your parents' home at the time, is your best recollection today; is that right? A That's my best recollection, yes. Q When you say living with you, were you guys staying in the same room? A Yes. Q Were you engaged at that time to him? A That was a really weird relationship. He was a friend who looked after me, and he did propose to me and I did say yes. But my heart was never in VIRGINIA GIUFFRE 5/3/2016 127

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page88 of 883 Agren Blando Court Reporting & Video, Inc. it. He was somebody that helped me off the streets so I felt compelled to say yes to him. Q Okay. So when he proposed to you and you said yes, did that take place before you started working at Mar-a-Lago or after you started working at Mar-a-Lago? A Before. Q And so if he were living with your parents at that time, you were living in the same room; is that correct? A I believe so. Q And your parents understood him to be your fiance? A I don't think they agreed with it, but I think they understood it as that. I mean -Q I mean, you communicated to them that he had proposed and you had accepted? A Yeah, in not such a pretty way. I mean, they obviously weren't very happy about it. And it wasn't my true intentions to ever marry him. Q Okay. A But I did it to make him feel okay. I didn't want to be mean. Q What did your mom say about your VIRGINIA GIUFFRE 5/3/2016 128

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page89 of 883 Agren Blando Court Reporting & Video, Inc. A I believe Juan Alessi was pretty much within ear distance. Q Could you see him? A Yes. Q Okay. A Like I said, in ear distance, when I mean ear distance like hearing, in the hearing vicinity. And it was in the same time that she was asking him to drop me off at home. Q Okay. When you were driving home the first night with Juan Alessi, did you have any conversation with him? A No. I had told him my address. It was a very quiet ride. Q Did you ride in the front or the back? A The front. Q It is your contention that, Ghislaine Maxwell had sex with underage girls virtually every day when I was around her, correct? A Yes. Q All right. With whom did Ghislaine Maxwell have sex in your presence? A Well, there's a lot of girls that were involved. We weren't on a first name basis with each other. I wouldn't be able to give you lists of names VIRGINIA GIUFFRE 5/3/2016 138

10 11 12 13 14 1S 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page90 of 883 Agren Blando Court Reporting & Video, Inc. of girls. It was continuous. Q It was continuous. Name one girl that Ghislaine Maxwell had sex with in your presence. A Emmy Taylor. I mean, that's a name that I know well because Emmy was always around. I'm trying to think of her name, sorry. Sarah. Her name used to be Sarah Kellen. I think she's changed it now that she's married. | (phonetic) -- I can't pronounce her last name properly, but it's around those lines. There were a lot of other girls that I honestly can't remember their names. I'm sorry. I wish I could help out more because I really would like to provide more witnesses for this, but I can't remember a lot of girls' names. Q So those are the three names of females that you observed Ghislaine Maxwell have sex with -MR. EDWARDS: Object to the form. Mischaracterizes testimony. Q (BY MS. MENNINGER) -- is that what I understand your answer to be? MR. EDWARDS: Objection. Mischaracterizes her testimony. A Those are -- those are some three of the VIRGINIA GIUFFRE 5/3/2016 139

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page91 of 883 Agren Blando Court Reporting & Video, Inc. Q More than 20? A I would say more than 20. Q More than 50? A I don't think more than 50, but -Q Did -A I don't have an exact number. I mean, if -- I think if you look at the flight logs, you know, that helps, but then they're not fully complete. We only have flight logs to one plane and then there's a time I was flown commercially into the island. Q Um-hum. A So it's really hard for me to gauge a number. Q Okay. Do you have any photographs of yourself on the island? A I know I used to, but they would be left in that apartment. Q What other locations did you participate in sexual contact with Ghislaine Maxwell, other than the island? A Everywhere. New York, Palm Beach. Q Where in New York? A The mansion, Jeffrey's mansion. Q Okay. Anywhere else in New York? VIRGINIA GIUFFRE 5/3/2016 155

10 11 12 13 14 1S 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page92 of 883 Agren Blando Court Reporting & Video, Inc. think I met Prince Andrew in 2001. And Glenn Dubin and Stephen Kaufmann were, like I said, the first people I was sent out to after my training. So TI don't know. I'm not going to give you an exact time if I don't know it. Q I asked you the relative order. A And I'm trying to give you it. Q And where does Alan Dershowitz fit into that group of people? A Same. I can't tell you piece by piece by piece who -- I know Glenn Dubin was first. Q Okay. A And I know Stephen Kaufmann was one of the first I was sent to. Alan Dershowitz could have been between there. Between, sorry, between Glenn and Stephen. The first time I was with Alan Dershowitz was in New York, so I wasn't actually sent to him. It actually happened at one of Jeffrey's residences. (Ms. McCawley left the deposition.) A So it's very hard for me to chronologically give you each person individually. Q (BY MS. MENNINGER) Okay. Name the other politically connected and financially powerful people that Ghislaine Maxwell told you to go have sex with? A Again, I'm going to tell you "they" VIRGINIA GIUFFRE 5/3/2016 193

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page93 of 883 Agren Blando Court Reporting & Video, Inc. because that's how it went. They instructed me to go to George Mitchell, Jean Luc Brunel, Bill Richardson, another prince that I don't know his name. A guy that owns a hotel, a really large hotel chain, I can't remember which hotel it was. Marvin Minsky. There was, you know, another foreign president, I can't remember his name. He was Spanish. There's a whole bunch of them that I just -- it's hard for me to remember all of them. You know, I was told to do something by these people constantly, told to -- my whole life revolved around just pleasing these men and keeping Ghislaine and Jeffrey happy. Their whole entire lives revolved around sex. They call massages sex. They call modeling sex. They call -Q I asked you the names for people. Are you going to tell me any other names or is that all of them? A I'm trying to think. That's the answer I'm trying to give to you. It's that it's so hard to just keep naming and naming and naming. Q All right. A A lot of times I would be introduced to them. I didn't know -VIRGINIA GIUFFRE 5/3/2016 194

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page94 of 883 Agren Blando Court Reporting & Video, Inc. many times you want me to keep answering this question. Both told me to do this, okay? They both sent me to these people. How many times do you want me to answer this? Q (BY MS. MENNINGER) I think you're answering a different question so that's why I'm going to ask you again. I am not asking you anything about a time when Jeffrey and Ghislaine together told you to go do something. I'm asking you to name a single time during which Ghislaine Maxwell acting alone directed you to go have sex with another person? MR. EDWARDS: Objection. Asked and answered. Harassing. Argumentative. A I've given you the names of the people that Ghislaine instructed me to go have sexual relations with. I am not discluding (sic) the fact that Jeffrey also told me. Ghislaine told me from her mouth to do these things. Jeffrey told me from his mouth to do these things with these people. Ghislaine instructed me to do the things that I did with Jeffrey Epstein on the very first meeting that I had with him. She brought me there under the preclusion (sic) that I VIRGINIA GIUFFRE 5/3/2016 198

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page95 of 883 Agren Blando Court Reporting & Video, Inc. was going to be trained as a masseuse and that she instructed me to take off my clothes and to give oral sex to Jeffrey Epstein. Q (BY MS. MENNINGER) Excuse me. I've asked you for the names. A I've just given you a name. Jeffrey Epstein is a big name. Q All right. A She instructed me on that one. Q So you're saying -MR. EDWARDS: The witness is finishing her answer right now. She's in the process of explaining one of the people Ghislaine told her to have sex with. Q (BY MS. MENNINGER) So you're saying Ghislaine Maxwell directed you to have sex with Jeffrey Epstein? A Correct. Q Ghislaine Maxwell directed you to have sex with Glenn Dubin? A Correct. Q What words did Ghislaine Maxwell tell you to go have sex with Glenn Dubin? A It was the same all the time, all right? They want me to go provide these men with a massage. VIRGINIA GIUFFRE 5/3/2016 199

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page96 of 883 Agren Blando Court Reporting & Video, Inc. A When it happened? Q When Ghislaine Maxwell used the words, Go give a massage to Bill Richardson, where were you? MR. EDWARDS: Object to the form. Mischaracterizes her testimony. A I can't tell you where we were. I know where I was sent to. I don't know where we were when she told me to do that. Q (BY MS. MENNINGER) Where were you sent to =A New Mexico. Q -- by Ghislaine Maxwell? MR. EDWARDS: Object to the form. Mischaracterizes her testimony again. A Are you smiling at me because -Q (BY MS. MENNINGER) No, I'm asking you to answer the question. A I have answered the question. I was sent to New Mexico. Q Okay. Where were you sent from? A I already answered that. I don't know where I was sent from. Q Okay. A I was flying everywhere with these people. Q Where were you sent by Ghislaine Maxwell VIRGINIA GIUFFRE 5/3/2016 201

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page97 of 883 Agren Blando Court Reporting & Video, Inc. A No, she was not in the room. She was in another cabana. Q And other than telling you to go give the owner of this large hotel chain a massage, do you remember any other words she used to you to direct you in what you should do? A Not at the time, no. Q Where did -- where were you and where was Ms. Maxwell when she directed you to go have sex with Marvin Minsky? MR. EDWARDS: Object to the form. A I don't know. Q (BY MS. MENNINGER) Where did you go to have sex with Marvin Minsky? A I believe it was the U.S. Virgin Islands, Jeff's -- sorry, Jeffrey Epstein's island in the U.S. Virgin Islands. Q And when was that? A I don't know. Q Do you have any time of year? A No. Q Do you know how old you were? A No. Q Other than Glenn Dubin, Stephen Kaufmann, Prince Andrew, Jean Luc Brunel, Bill Richardson, VIRGINIA GIUFFRE 5/3/2016 204

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page98 of 883 Agren Blando Court Reporting & Video, Inc. another prince, the large hotel chain owner and Marvin Minsky, is there anyone else that Ghislaine Maxwell directed you to go have sex with? A I am definitely sure there is. But can I remember everybody's name? No. Q Okay. Can you remember anything else about them? A Look, I've given you what I know right now. I'm sorry. This is very hard for me and very frustrating to have to go over this. I don't -- I don't recall all of the people. There was a large amount of people that I was sent to. Q Do you have any notes of all these people that you were sent to? A No, I don't. Q Where are your notes? A I burned them. Q When did you burn them? A In a bonfire when I lived at Titusville because I was sick of going through this shit. Q Did you have lawyers who were representing you at the time you built a bonfire and burned these notes? A I've been represented for a long time, but it was not under the instruction of my lawyers to do VIRGINIA GIUFFRE 5/3/2016 205

10 11 12 13 14 1S 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page99 of 883 Agren Blando Court Reporting & Video, Inc. this. My husband and I were pretty spiritual people and we believed that these memories were worth burning. Q So you burned notes of the men with whom you had sex while you were represented by counsel in litigation, correct? MR. EDWARDS: Object to the form. A This wasn't anything that was a public document. This was my own private journal, and I didn't want it anymore. So we burned it. Q (BY MS. MENNINGER) When did you write that journal? A Just over time. I started writing it probably in, I don't know, I can't speculate, 2012, 2011. Q So you did not write this journal at the time it happened? A No. Q You started writing this journal approximately a decade after you claim you finished being sexually trafficked, correct? A Yes. Q And you started writing a journal after you had a lawyer, correct? A Correct. VIRGINIA GIUFFRE 5/3/2016 206

10 11 12 13 14 1S 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page100 of 883 Agren Blando Court Reporting & Video, Inc. THE VIDEOGRAPHER: We're back on the record at 2:55. Q (BY MS. MENNINGER) Do you have any photographs of yourself either nude or in a sexually compromising position that you claim were taken by Ghislaine Maxwell? A I do not have any of those in my evidence. But if you ask Ghislaine Maxwell, she would have plenty. Q Do you have any in your storage boxes in Sydney? A No. Q Do you know whether your attorneys have any such photographs that you claim were taken by Ghislaine Maxwell? A No. Q You don't know or they don't have them? A I don't know. And I don't think they have them. If they had them, they would have told me. You should ask your client. She's got plenty of them. Q What type of camera did Ghislaine Maxwell use? A It was a black camera. And it had a, I don't know the types and names of them, but the lens VIRGINIA GIUFFRE 5/3/2016 232

10 11 12 13 14 1s 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page101 of 883 Agren Blando Court Reporting & Video, Inc. that goes out. Q Was it digital or single reflex? A Again, I don't know types of cameras. I mean, I use my phone for using a camera. So it's a black camera and it had a lens that you could put out further or bring back. Q Did you ask her to take any photographs of you? A No. She asked to take photographs of me. Q Was it a film or a digital camera? A I never saw how she printed them out. Q What's the first time you told anybody that you had been sexually trafficked? MR. EDWARDS: Form. A Tony Figueroa, my ex-boyfriend, knew some of the stuff that was happening, though I did not go in great detail to him, being that he's my boyfriend. And then the first person I really opened up to about everything was my husband. Q (BY MS. MENNINGER) Did you tell Tony Figueroa that you were forced to have sex with Jeffrey Epstein? A Yes. Q Did you tell Tony Figueroa you were forced to have sex with Ghislaine Maxwell? VIRGINIA GIUFFRE 5/3/2016 233

10 11 12 13 14 1S 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page102 of 883 Agren Blando Court Reporting & Video, Inc. any interactions with law enforcement? A Yes. Q When? A When I tried to break away from Jeffrey and Ghislaine, I started making myself unavailable. And I got a job at Road House Grill. And Tony used to come pick me up in the afternoons, at nighttime, and he'd sit at the bar. And there's this big cup that's got tips in it. I was in the back room. And I had to -first you have to sign out and you have to take off your aprons, put your aprons away. And there's a whole bunch of cleaning up stuff you have to do. In that time period, Tony grabbed money from a cup that had money in it. That was for the bartenders for their tips. My boss called me the next day. He told me that I had stolen the money, which I hadn't. And I came back and I returned the money after I confronted Tony about it. Gave the money back to him and he said, I'm sorry, but it's just law that I have to call the police. So he called the police. And knowing that Jeffrey has got the Palm Beach Police Department in his pocket, I went to Jeffrey Epstein and I told him what had happened. VIRGINIA GIUFFRE 5/3/2016 240

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page103 of 883 Agren Blando Court Reporting & Video, Inc. And Jeffrey said, Don't worry about it. Let me take care of it for you. Q Okay. I'm sorry. When did you have interaction with law enforcement, then? A What year? Q Did you speak with a law enforcement officer? A I don't believe I spoke to them. Jeffrey handled everything. Q Okay. And you said that you had finished your shift at -- this is at the Road House Grill, correct? A Correct. Q You had finished your shift? A Yeah, it was the end of the shift. Q Okay. And you had cleaned up and were checking out, correct? A Yeah, it's a completely separate part of the -- it's like back of the house. Do you know what that means, like in waitering terms? Q (Indicating. ) A Yeah, back of the house. Q And what was -- who was this boss that you spoke to? A I can't remember his name. VIRGINIA GIUFFRE 5/3/2016 241

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page104 of 883 Agren Blando Court Reporting & Video, Inc. exclusivity? A Yes. Q What was that period? A I believe it was like a three-month period or something. Q Okay. And what other terms of the contract, do you recall? A I couldn't talk to any other news publication about the story. Q Anything else? A Not that I know of. Q Were you happy when the period was up? A Well, I mean, at that time I wanted to write about my story. So I guess, yes, I was happy when that period was up. Q And you were actively writing a book at that time, correct? A My manuscript. I've never published it. Q You were writing the manuscript at the time of your period of exclusivity with Sharon Churcher, correct? A Those three months were just craziness. I think I started after that. Q You think you started writing the book after the 90 days were up? VIRGINIA GIUFFRE 5/3/2016 249

10 11 12 13 14 1s 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page105 of 883 Agren Blando Court Reporting & Video, Inc. A Yeah. Q And then you attempted to sell that manuscript, correct? A I didn't attempt to sell it. I went to other publications, like, what do you call them? People -- I'm trying to think of the name of the word. People who publish books, not like a newspaper or anything. And I inquired about what they thought of my manuscript and if they thought it was, you know, a good story. And, yeah. Q So you sent the manuscript to these people for the purposes of trying to publish the book, correct? A Some people, yes. Q And you were trying to get money from the book publication, correct? A Well, I wasn't going to sell it to them for free. Q But you were unsuccessful in finding someone to publish it, correct? A Well, I was always on the fence with it. I wasn't too sure if I wanted to or didn't want to. I was more seeking judgment based upon these people who have done this plenty and plenty of times. Still to this day, I mean, I've had people VIRGINIA GIUFFRE 5/3/2016 250

10 11 12 13 14 1S 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page106 of 883 Agren Blando Court Reporting & Video, Inc. who have been interested in it and I still don't know if I want to do it yet. I mean, I think there's a lot more that can go into it, you know. Q You were actively sending the manuscript to people for purposes of having them reach a deal with you and publish it, correct? A No deal was ever talked about. What we talked about was the possibility of publishing it, is it publishing-worthy, would I need to get a ghostwriter. You know, this is the first time I've ever written a manuscript so I didn't know what I was doing. Q Okay. You contacted Jarred Weisfeld, correct? A Correct. Q I'm going to mark a document as Defendant's Exhibit 16. It is a composite exhibit. (Exhibit 16 marked.) MR. EDWARDS: Thank you. Q (BY MS. MENNINGER) I'm not going to ask you to read every single page of this, but if you look at the first page. A Um-hum. Q Can you tell what this is in terms of what type of document? VIRGINIA GIUFFRE 5/3/2016 251

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page107 of 883 Agren Blando Court Reporting & Video, Inc. calm the anxiety and everything down. Q Before you met Jeffrey Epstein, had you used any drugs? A Sure, yes. Q Which drugs had you used prior to meeting Jeffrey Epstein? A I smoked pot. I've taken Ecstasy. Q Cocaine? A Yeah, I would have snorted cocaine, um-hum. Q Did you ever abuse alcohol before meeting Jeffrey Epstein? A No, I was -- I wasn't even of age to be able to buy it. I mean, if there was alcohol at parties I would have drank it, but I wouldn't say I abused it. Q Okay. Were there ever occasions upon which you were observed to be drunk by other people, prior to meeting Jeffrey Epstein? A If you're drinking, the possibility of getting drunk is always there. I don't -- I can't recall exact situation where that was the case, but -Q Were you diagnosed as a drug addict prior to meeting Jeffrey Epstein? VIRGINIA GIUFFRE 5/3/2016 333

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page108 of 883 Agren Blando Court Reporting & Video, Inc. AGREN BLANDO COURT REPORTING & VIDEO, INC. 216 - 16th Street, Suite 600 Denver, Colorado 80202 4450 Arapahoe Avenue, Suite 100 Boulder, Colorado 80303 May 11, 2016 Sigrid S. McCawley, Esq. BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301-2211 Re: Videotaped Deposition of VIRGINIA GIUFFRE Giuffre v. Maxwell Case No. 15-cv-07433-RWS The aforementioned deposition is ready for reading and signing. Please attend to this matter by following BOTH of the items indicated below: Call 303-296-0017 and arrange with us to read and sign the deposition in our office. XXX Have the deponent read your copy and sign the signature page and amendment sheets, if applicable; the signature page is attached. Read the enclosed copy of the deposition and sign the signature page and amendment sheets, if applicable; the signature page is attached. XXX WITHIN 30 DAYS OF THE DATE OF THIS LETTER By due to a trial date of Please be sure the original signature page and amendment sheets, if any, are SIGNED BEFORE A NOTARY PUBLIC and returned to Agren Blando for filing with the original deposition. A copy of these changes should also be forwarded to counsel of record. Thank you. AGREN BLANDO COURT REPORTING & VIDEO, INC. cc: All Counsel VIRGINIA GIUFFRE 5/3/2016 346

Case 18-2868, Document 283, 08/09/2019, 2628241, Page109 of 883 GIUFFRE VS. MAXWELL Deposition VIRGINIA GIUFFRE VOLUME II 11/14/2016 Agren Blando Court Reporting & Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-0017

Case 18-2868, Document 283, 08/09/2019, 2628241, Page110 of 883 Agren Blando Court Reporting & Video, Inc. IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS CONFIDENTIAL VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II November 14, 2016 VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. APPEARANCES: BOIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301 Phone: 954.356.0011 smccawley@bsfllp.com Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE VOLUME II 11/14/2016 348

Case 18-2868, Document 283, 08/09/2019, 2628241, Page111 of 883 Agren Blando Court Reporting & Video, Inc. APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura Menninger, Esq. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 lmenninger@hmflaw.com jpagliuca@hmflaw.com Appearing on behalf of the Defendant Also Present: Ann Lundberg, Paralegal Maryvonne Tompkins, Videographer VIRGINIA GIUFFRE VOLUME II 11/14/2016 349

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page112 of 883 Agren Blando Court Reporting & Video, Inc. A Yes. Q And you believe the Neiman Marcus was located in which city? A Well, it's around Fort Lauderdale. I can't tell you exactly. Fort Lauderdale is so big, like Broward County? Is that the word for it? Q And what did you do at Neiman Marcus? A I worked in the changing rooms. Q And what did you do in the changing room? A I think I just like -- if I remember right, I just put clothes away that people left in there. Probably went out to get sizes, different sizes for women who wanted different sizes of the same product. Q And where did you work after Neiman Marcus? A Taco Bell. Q Did you work at Southeast Employee Management Company? A I don't recognize that. I don't know if that's a payroll company or what it is. I don't know what Southeast -- what is it called? Q Southeast Employee Management Company. A No, I don't remember that. Q Did you ever work as a temp? VIRGINIA GIUFFRE VOLUME II 11/14/2016 470

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page113 of 883 Agren Blando Court Reporting & Video, Inc. A Not that I remember. Q Going to different offices and filling in? A No. Q Did you work for Oasis Outsourcing? A I don't -- I don't know if that's a payroll company or if that's an actual place, but that doesn't ring a bell. Q Did you -- do you know how much you got paid when you were working at places like Oasis Outsourcing? A Well, considering I don't know if I worked at Oasis Outsourcing, I wouldn't even know how much I got paid. Q Did you review your Social Security records? A Yes. Q You saw Oasis Outsourcing listed there? A Right, but like I said, it doesn't even ding a bell at all. Q Do you know how much money they said you made from them? MS. MCCAWLEY: Objection. If you want to show her the documents, she can see what amount is listed and answer your questions, but if you're not going to show her the document, that's the best she VIRGINIA GIUFFRE VOLUME II 11/14/2016 471

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page114 of 883 Agren Blando Court Reporting & Video, Inc. can do. A Yeah, if you could. I'm happy to answer your questions. I want to be helpful, so... Q (BY MS. MENNINGER) Great. Well, do you remember how much money you made from Oasis Outsourcing? A Like I said, I don't even remember working for Oasis Outsourcing, or what it is, so I couldn't tell you. Q Do you remember how much money you were making per hour at Neiman Marcus? A No, not off the top of my head. Q Do you know how many months you worked there? A Not long. I'd probably say -- I mean, I don't know. I'm not going to guess. But around the three-month mark would be my -- I don't know the exact answer. Q Do you remember any of your coworkers? A No. Q Did you work at Mannino's? A Briefly, yes. Q What is Mannino's? A A cute little Italian restaurant in Wellington. VIRGINIA GIUFFRE VOLUME II 11/14/2016 472

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page115 of 883 Agren Blando Court Reporting & Video, Inc. Q And what did you do at Mannino's? A I did waitressing. Q And how much did you make? A Oh, I don't know. I don't remember. Q Did you work at TGI Fridays? A Again, very shortly. Short time period, and I was a waitress again. Q And how much did you make there? A I have no idea. Q Did you get fired? A No. Q Why did you leave? A I was -- that's around the time period that I was approached by -- I can't remember his name, but he owned a veterinary clinic or he was a vet, one of the two, and he offered me to come work for him. Q When you were working at TG -- TGI Fridays, were you also working at the Roadhouse Grill? A No. Q Those were not at the same time? A I don't know. I don't think so. Maybe consecutively like after each other. Q Do you recall working at the Roadhouse VIRGINIA GIUFFRE VOLUME II 11/14/2016 473

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page116 of 883 Agren Blando Court Reporting & Video, Inc. Grill? A Yes. Q And why did you leave there? A We all know that the thing that went down there. Tony picked me up and took some money out of a jar, and then I went to go give it back to the guy, thinking that it would be all right, and it wasn't. So I got fired, I think. Q Sure. Okay. I show you some -- are we on 9? MR. PAGLIUCA: Yes, 9. Q (BY MS. MENNINGER) I'd like to show you Defendant's Exhibit 9. (Exhibit 9 marked.) THE DEPONENT: Thank you. Q (BY MS. MENNINGER) Do you recognize your handwriting on this document? A Yes. Q Did you fill out an application for employment -A Yes. Q -- on March 26th of 2002? A Yes. Q And where were you living at that time? A I've put down my parents' address, but I VIRGINIA GIUFFRE VOLUME II 11/14/2016 474

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page117 of 883 Agren Blando Court Reporting & Video, Inc. and seasonal employee, correct? A Correct. Q And your dad was a full-time year-round employee, right? A Yes. Q He worked there all the time. A Yes. Q And your job was a seasonal employment. A Well, as far as I know -MS. MCCAWLEY: Objection. A -- I was hired for the summer, so... Q (BY MS. MENNINGER) Right. Okay. So the work hours, in the next paragraph, what -- what is that -- can you just read that bottom paragraph for us? A "The Club never shuts down from November 1st to Mother's Day; for 24 hours a day, 7 days a week, it serves the diverse needs of our members. Therefore to ensure the adequate coverage at all times, departments have arranged different schedules for their employees." Q Okay. I'm going to show you Defendant's Exhibit 20. A Close this one? Q Yeah. VIRGINIA GIUFFRE VOLUME II 11/14/2016 550

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page118 of 883 Agren Blando Court Reporting & Video, Inc. STATE OF COLORADO) ) ss. REPORTER'S CERTIFICATE COUNTY OF DENVER ) I, Pamela J. Hansen, do hereby certify that I am a Registered Professional Reporter and Notary Public within the State of Colorado; that previous to the commencement of the examination, the deponent was duly sworn to testify to the truth. I further certify that this deposition was taken in shorthand by me at the time and place herein set forth, that it was thereafter reduced to typewritten form, and that the foregoing constitutes a true and correct transcript. I further certify that I am not related to, employed by, nor of counsel for any of the parties or attorneys herein, nor otherwise interested in the result of the within action. In witness whereof, I have affixed my signature this 23rd day of November, 2016. My commission expires September 3, 2018. Pamela J. Hansen, CRR, RPR, RMR 216 - 16th Street, Suite 600 Denver, Colorado 80202 VIRGINIA GIUFFRE VOLUME II 11/14/2016 563

EXHIBIT 6 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page120 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 IN THE HIGH COURT OF JUSTICE QUEEN'S BENCH DIVISION Claim No. CR 2016 624 BETWEEN: VIRGINIA L. GIUFFRE Applicant, and ROSS GOW, Respondent. AND: UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, Case No. 15 cv 07433 RWS v. Ghislaine Maxwell, Defendant . Friday, November 18, 2016 AT: 8:27 a.m. Taken at: Essex Chambers 29, 81 Chancery Lane, London, UK, WC2A 1DD Court Reporter: Lisa Barrett, Accredited Real time Reporter DTI Court Reporting Solutions New York 1 800 325 3376 www.deposition.com

Case 18-2868, Document 283, 08/09/2019, 2628241, Page121 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 12 10 11 12 13 14 15 16 1? 18 19 20 21 22 23 24 25 A. Q. in preparation for this deposition? A. Be Ae LO es a firm on or around March 2011. Q. A. Q. A. I was introduced to her by my chairman Brian Basham but I believe the first words we had were in the Devonshire law office. Oe your firm? A. Q A. Q. A No, I have not. When you met her last night, did she assist you No. Did she tell you anything about this case? No. Do you know Ghislaine Maxwell? I do know Ms. Maxwell, yes. How did you meet her? I met her in the offices of Devonshires law So your first meeting was in person? First meeting was in person, yes. Had you spoken to her prior to that? I believe that the very first engagement was -Did Ms. Maxwell retain the services of you or Yes, she did. And was that in March of 2011? It was. Do you have a written agreement? We did have a written agreement but I can no 1 800 325 3376 DTI Court Reporting Solutions New York www.deposition.com 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08:

Case 18-2868, Document 283, 08/09/2019, 2628241, Page122 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 13 10 11 12 13 14 15 16 1? 18 19 20 21 22 23 24 25 longer locate that agreement. Q. Was that agreement ever renewed? A. It was renewed, I believe on or around the beginning of January 2015, potentially the 2nd of January via email. QO. Was the agreement revised when it was renewed? A. It wasn't revised. It was a straightforward re-establishment of the original agreement. Q. Is it your belief that that agreement was in effect on January 2nd, 2015? A. Yes. Q. Do you recall the terms of that agreement? A. Well, it was a re-establishment of an existing agreement so if we go back to the original agreement, it was to provide public relations services to Ms. Maxwell in the matter of Guiffre and her activities. MS. SCHULTZ: I'm marking as Exhibit 2, a document labeled GM 00068. (Exhibit 2 was marked for identification) MR. DYER: Why don't you start making a pile of them, Mr. Gow, because it may be that later on you'll be asked to go back to them. THE WITNESS: Yes, sir. MR. DYER: You don't have copies for me of these documents? 1 800 325 3376 DTI Court Reporting Solutions New York www.deposition.com 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08:

Case 18-2868, Document 283, 08/09/2019, 2628241, Page123 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 14 10 11 12 13 14 15 16 1? 18 19 20 21 22 23 24 25 MS. SCHULTZ: I do not have any more copies on that. MR. DYER: No, no, no, it's much more important that ... just for the purpose of following things, it's easier. BY MS. SCHULTZ: Q. Is ross@acuityreputation.com your email address? A. It is, my business email, yes. om Did you send the email depicted in this document? A. Yes, I did. Q. Did you send it on January 2nd, 2015? A. I believe I did. a; When you sent that email were you acting pursuant to Ms. Maxwell's retention of your services? A. Yes, I was. Q. Could you please tell me everything you know about Virginia Roberts Guiffre. MS. MENNINGER: Objection, foundation and form. MR. DYER: You may answer. BY MS. SCHULTZ: Q. You testified earlier that you were retained -MR. DYER: Are you withdrawing that question? BY MS. SCHULTZ: 1 800 325 3376 DTI Court Reporting Solutions New York www.deposition.com 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08:

Case 18-2868, Document 283, 08/09/2019, 2628241, Page124 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 15 1 Q. No, I'm not, I'm not. Please -- I am 2 withdrawing that question. 3 MR. DYER: Alright. 4 MS. SCHULTZ: I am withdrawing that question. 5 BY MS. SCHULTZ: 6 Q. You testified previously that you were retained 7 to handle matters relating to Virginia Roberts Guiffre; 8 is that correct? 9 A. Correct. 10 Q. Okay. So you are aware of who Ms. Roberts 11 Guiffre is? 12 A. I am. 13 Q. Okay. Please tell me everything you know about 14 Virginia Roberts Guiffre, please. 15 MS. MENNINGER: Objection, foundation, form, 16 and may call for privileged materials. a7 BY MS. SCHULTZ: 18 Q. You can answer -- to the extent that anything 19 you testify to is not protected by a privilege. 20 A. Ms. Roberts first came to my attention on or 21 around March 2011 when I was called into a meeting with 22 Philip Barden and Ms. Maxwell at Devonshires law office, 23 that she had made -- Ms. Guiffre had made extremely 24 unpleasant allegations about Ms. Maxwell's private life. 25 We were -- Acuity Reputation, my firm DTI Court Reporting Solutions New York 1 800 325 3376 www.deposition.com 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08:

Case 18-2868, Document 283, 08/09/2019, 2628241, Page125 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 16 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 was called in to protect Ms. Maxwell's reputation, and to set the record straight. That was -- and that work commenced on or around March of 2011. Q. What do you mean by "set the record straight"? A. Ms. Guiffre's allegations about Ms. Maxwell were, we believe, and to this day continue to believe, untrue, defamatory, and fantastical. And with Devonshires' lawyers, we set about putting out -crafting a statement which would put Ms. Maxwell's point of view across that Ms. Guiffre's allegations were untrue and, frankly, abhorrent. Q. What advice did you give Miss Maxwell as part of your retention? A. It is standard procedure in cases where it's understood that a party may be defaming one's client that one puts out a statement correcting those allegations and providing a clearer picture of where the truth lies. So it was very much our counsel that Ms. Maxwell put out a statement, vehemently denying the allegations. Q. When you testified that Ms. Guiffre, I'm going to refer to her by just her married name, came to your attention at that March 2011 meeting at Devonshires with Mr. Barden and Ms. Maxwell, correct, and you learned about her at that meeting; is that correct? A. Correct. DTI Court Reporting Solutions New York 1 800 325 3376 www.deposition.com 08:37:29 08:37:33 08:37:42 08:37:46 08:37:51 08:37:55 08:37:58 08:38:09 08:38:15 08:38:19 08:38:25 08:38:28 08:38:31 08:38:32 08:38:36 08:38:42 08:38:46 08:38:49 08:38:55 08:38:59 08:39:03 08:39:06 08:39:12 08:39:16 08:39:18

Case 18-2868, Document 283, 08/09/2019, 2628241, Page126 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 31 10 11 12 13 14 15 16 1? 18 19 20 21 22 23 24 25 remaining, so... I've marked as Exhibit 3 RG(UK) 00002. Do you recognize this email? A. I do. Q:; Did you receive this email? A. I did, on the -- on New Year's Day 2015. Q. Did you contact Ms. Maxwell after receiving this email? A. I did. Qo. Did you make any response to Mr. Ball in any form? A. I did. Q. Can you tell me what you -- what response you made? A. Well, the response to Mr. Ball was part of a series of responses having spoken to my client within 24 hours or so, we got back to Mr. Ball with an agreed statement which went out to a number of media. Q. When you say "agreed statement" can you tell me more about what you mean? Who agreed to the statement? A. I need to give you some context, if I may, about that statement. So, this is on New Year's Day. I was in France so the email time here of 21:46, in French time was 22:46, and I was getting up early the next 1 800 325 3376 DTI Court Reporting Solutions New York www.deposition.com 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 09: 09: 09: 09: 59:26 59:27 59:33 59:41 59:44 59:50 59:52 59:58 00:01 00:02 00:04 00:10

Case 18-2868, Document 283, 08/09/2019, 2628241, Page127 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 32 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 morning to drive my family back from the south of France to England, which is a 14-hour journey, door to door. So on the morning of the 2nd of January, bearing in mind that Ms. Maxwell, I think was in New York then, she was five hours behind, so there was quite a lot of, sort of time difference between the various countries here, I sent her an email, I believe, saying -- parsing this -- forwarding this email to her saying "How do you wish to proceed?" And then I was on the telephone -- I had two telephones in the car, I received in excess of 30 phone calls from various media outlets on the 2nd of January, all asking for information about how Ms. Maxwell was looking to respond to the latest court filings, which were filed on the 30th of December as I understand. And by close -- towards close of play on the 2nd, I received an email forwarded by Ms. Maxwell, containing a draft statement which my understanding was the majority of which had been drafted by Mr. Barden with a header along the lines of "This is the agreed statement." At close of play on the 2nd. So I -- I was -- I had gone under the Channel Tunnel and I was sitting on the other side and that email, which my understanding was that it had 1 800 325 3376 DTI Court Reporting Solutions New York www.deposition.com 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 714 17 350 254 200 204 210 713 216 244 248 250 254 357

Case 18-2868, Document 283, 08/09/2019, 2628241, Page128 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 33 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 been signed off by the client, effectively, was then sent out to a number of media, including Mr. Ball and various other UK newspapers. Q. Mr. Gow, when you say "end of play" and "close of play," are you referring to sending the email that's Exhibit 2? A. Yes, I am. MR. DYER: My understanding is that it went to people other than those listed? THE WITNESS: Yes, that is -MR. DYER: Just a sample. THE WITNESS: That is a sample. Everyone who effectively -- well, the detail on this, I was driving, so my eldest son in the back had my BlackBerry and was trying to capture -- it was a pretty chaotic day. Most people in the UK were on holiday. In fact, it was a holiday weekend, our office was closed, my PA was on holiday, so my son was basically doing an internship in the back of the car, downloading the names of the callers from various media outlets and -- so we had a list of those so when I got to the car park, at the end of the Eurotunnel thing in the UK, I had numerous names, so the email went out to a wide range of people. But the 30 or so calls I had is an aggregate number, so there might have been five calls from the BBC DTI Court Reporting Solutions New York 1 800 325 3376 www.deposition.com 09:02: 09:02: 09:02: 09:02: 09:02: 09:02: 09:02: 09:02: 09:02: 09:02: 09:02: 09:02: 09:02: 09:02: 09:02: 09:02: 09:02: 09:02: 09:02: 09:03: 09:03: 09:03: 09:03: 09:03: 09:03: 17 20

Case 18-2868, Document 283, 08/09/2019, 2628241, Page129 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 44 10 11 12 13 14 15 16 1? 18 19 20 21 22 23 24 25 10 more seconds. MS. SCHULTZ: Understood, and I apologize. MR. SPEARMAN: This is what, Exhibit 9? MR. DYER: Yes. MS. SCHULTZ: Yes. (Exhibit 9 was marked for identification.) BY MS. SCHULTZ: Q. This also appears to be an email chain with you and Ms. Maxwell; is that correct? A. It does appear to be so. O: Did you send the top email of the chain that says "Okay, G, going with this"? A. I did. Q. And did you receive from Ms. Maxwell, the bottom email of that chain? A. I believe so. Well, I believe -- yes, yeah, it was forwarded from Ms. Maxwell, yes. MR. DYER: Sorry, I don't quite understand that answer. THE WITNESS: I misspoke that. I did receive it from Ms. Maxwell. MR. DYER: Okay. BY MS. SCHULTZ: Q. The subject line does have "FW" which to me indicates it's a forward. Do you know where the rest of DTI Court Reporting Solutions New York 1 800 325 3376 www.deposition.com 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 19:50 19:52 19:54 19:56 19:56 19:56

Case 18-2868, Document 283, 08/09/2019, 2628241, Page130 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 45 10 11 12 13 14 15 16 17 18 19 20 a1 22 23 24 25 this email chain is? A. My understanding of this is: It was a holiday in the UK, but Mr. Barden was not necessarily accessible, at some point in time, so this had been sent to him originally by Ms. Maxwell, and because he was unavailable, she forwarded it to me for immediate action. I therefore respond, "Okay, Ghislaine, I'll go with this." It is my understanding that this is the agreed statement because the subject of the second one is "Urgent, this is the statement" so I take that as an instruction to send it out, as a positive command: "This is the statement." Q. Okay. A. And I say, "Thanks, Philip" because I'm aware of the fact that he had a hand, a considerable hand in the drafting. Q. Okay. Could I ask you to please refer back to Exhibit 2. Looking also at Exhibit 9, Exhibit 9 appears to have five sentences in it. Do you agree that those same five sentences are part of the communication that is borne in Exhibit 2? A. Sorry, could you say that again. I'm just following what your -0. It was a bad question. Let me try that again. DTI Court Reporting Solutions New York 1 800 325 3376 www.deposition.com 09:20:45 09:20:49 09:20:54 09:20:59 09:21:03 09:21:07 09:21:14 09:21:19 09:21:20 09:21:22 09:21:24 09:21:27 09:21:30 09:21:33 09:21:33 09:21:37 09:21:40 09:21:41 09:21:47 09:22:03 09:22:10 09:22:13 09:22:18 09:22:20 09:22:21

Case 18-2868, Document 283, 08/09/2019, 2628241, Page131 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 64 1 Q. Okay. Have you ever communicated anything 2 regarding Ms. Guiffre's criminal allegations to the press 3 or the media? 4 A. As part of a wider conversation about her 5 unsavory allegations about Ms. Maxwell, it's possible 6 that I might have done, but I can't recall the detail, 7 I'm afraid. 8 0: Do you -- do you remember discussing that with 9 The Guardian? 10 A. No, I don't. I'm not saying I didn't but I 11 can't recall. You have to bear in mind, if you'd be so 12 kind, that I've been speaking to over 30 journalists and 13. media outlets about this, and I can't recall every single 14 -- the detail of every single conversation. 15 Q. Earlier you testified with regard to Exhibit 2 16 that in the days following sending that email, you also 17 communicated with other press and media outlets. Do you 18 recall today any of the other press and media outlets you 19 communicated with, in addition to those listed at the top 20 of that email? 21 A. The Guardian, The Sun, from the top of my 22 memory, but in addition to -- in addition to emails there 23 would have been telephone calls and I'm -- there may not 24 be a transcript of those calls, these are emails inter 25 alia, others, and I can't recall every single email that 1 800 325 3376 DTI Court Reporting Solutions New York www.deposition.com 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09:

Case 18-2868, Document 283, 08/09/2019, 2628241, Page132 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 66 10 11 12 13 14 15 16 1? 18 19 20 21 22 23 24 25 from John Swain? A. I believe I did. Q. That's all the questions I have about that document . A. Thank you. Q. Regarding communications you made after sending the email in Exhibit 2, I believe, and please correct me if I'm wrong, you testified that you received 30 or more calls that were -- that you would classify as press inquiries regarding Ms. Guiffre; is that correct? A. Yes. Q. Do you recall emailing the statement to other entities beyond what is on the list on Exhibit 2? A. Yes, I think I answered that previously. Yes I mean there is a far -- I said inter alia, so there is a wider range of people that I would have emailed it to in response to incoming queries -Q. Do you -A BU. vl iS Q. Sorry. A. I can't remember every single one. Q Do you recall ever reading the statement to the press or the media over the phone? A. It's very possible that I would have done so, yes. DTI Court Reporting Solutions New York 1 800 325 3376 www.deposition.com 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 58:42 58:44 58:49 58:51 58:52 59:05 59:08 59:14 59:17 59:20 59:23 59:24 59:29 59:33 59:36 59:40 59:43 59:46 59:46 59:47 59:48 59:50 59:52 59:56 59:57

Case 18-2868, Document 283, 08/09/2019, 2628241, Page133 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 67 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. DYER: Do you mean Exhibit 2? MS. SCHULTZ: Yes. Exhibit 2. THE WITNESS: To be clear, Exhibit 2 was the base document. MS. SCHULTZ: Uh-hmm. THE WITNESS: In addition to the 2011 March statement. Those were the two working documents that were always referred to, both of which -- well, the first one was in a public domain and was on record on the Devonshires -- on -- with Devonshires name at the top on PR Newswire which is a global delivery service. So that was easily accessible by people. And the second one was the -- further to the 2nd of January 2015. BY MS. SCHULTZ: 0. To the extent you can recall or could estimate, how many other emails do you believe you sent bearing that statement that's in Exhibit 2? A. I really can't remember but certainly more than six and probably less than 30, somewhere in between. Any time there was an incoming query it was either dealt with on the telephone by referring them back to the two statements of March 2011 and January 2015 or someone would email them the statement. So no one was left unanswered, broadly, is the -- is where we were. But I can't remember every DTI Court Reporting Solutions New York 1 800 325 3376 www.deposition.com 09:59: 10:00: 10:00: 10:00: 10:00: 10:00: 10:00: 10:00: 10:00: 10:00: 10:00: 10:00: 10:00: 10:00: 10:00: 10:00: 10:00: 10:00: 10:00: 10:00: 10:00: 10:00: 10:01: 10:01: 10:01: 58 00

Case 18-2868, Document 283, 08/09/2019, 2628241, Page134 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 68 10 11 12 13 14 15 16 1? 18 19 20 21 22 23 24 25 single person we reached out to. Q. Okay. So is it your testimony that you reached out to individuals who did not first contact you? A. No. We were in response mode. Q. Okay. A. There was enough to do responding to incoming queries, I wouldn't have been making more work, to be honest. Q. Alright. MR. DYER: So journalists paid no attention to your "No further communication will be provided on the matter." A. No -- that's quite correct, sir, and there probably was a -- it's regarded as tweaking their tales BY MS. SCHULTZ: Q. Mr. Gow, I'm handing you what I've marked as Exhibit 14. The Bates number is RG(UK) 000004. I'll give you a moment to look at it. (Exhibit 14 was marked for identification.) BY MS. SCHULTZ: Q. Thank you. Toward the top of the page there is a passage that reads: "Apologies, should read Virgina Roberts all the way through." [As read] DTI Court Reporting Solutions New York 1 800 325 3376 www.deposition.com 10: 10: 10: 10: 10: 10: 10: 10: 10: 10: 10: 10: 10: 10: 10: 10: 10: 10: 10: 10: 10: 10: 10: 10: 10: 01:13 01:19 01:22 01:26 01:28 01:29 01:38 01:38 01:42 01:44 01:47 01:48 01:50

Case 18-2868, Document 283, 08/09/2019, 2628241, Page135 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 109 10 11 12 13 14 15 16 1? 18 19 20 21 22 23 24 25 servicing ultra high net worth clients, individuals, corporates, governments and NGOs, managing their media relations and protecting their reputation. O. Approximately how long have you been providing such services? A. Acuity was set up in 2010. (Exhibit 26 was marked for identification.) BY MS. SCHULTZ: O. I'm going to hand you what I've marked as Exhibit 26. A. Thank you. Q. Does this document fairly depict pages from your -- from Acuity Reputation's website? A. It does. Q. Do you see where it says "We manage reputation and forge opinion through public relations, strategic communications and high level networking"? A. I do. Q Is that a true statement? A. Say it again. Sorry. Q. Is that a true statement? A It is, yes. I wrote that statement. MR. DYER: Sorry, you read it or you wrote it? THE WITNESS: I wrote it, so I do recognize it. BY MS. SCHULTZ: 1 800 325 3376 DTI Court Reporting Solutions New York www.deposition.com ll: 11s If Ty ll: Ty its 1y ll: Ty ie Its ll: 11: 11: ity ITs ll: ll: its ity IT Ite ll:

Case 18-2868, Document 283, 08/09/2019, 2628241, Page136 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 110 1 Q. Is it correct that public relations and 2 strategic communications are things that you personally 3 do as part of your professional activities? 4 A. I personally -- I'm involved in public 5 relations and strategic communications, yes. 6 Q. Is it correct that the media is the intended 7 recipient of this strategic communications. 8 A. It's -- the -- it's a larger ground than just 9 the media. There may be lobbyists, government think 10 tanks, focus groups, government departments. 11 0; Would it be fair to say that the media is often 12 the intended recipient of strategic communications? 13 A. It is a frequent recipient. 14 O. Referent recipient? 15 A. But not the sole recipient. 16 Q. Okay. Do you see where your website claims 17 that your company has "excellent relationships with the 18 media"? 19 A. I do. 20 Is that a true statement? 21 A. That is true, yeah. 22 MR. DYER: Except Mr. Syson. 23 THE WITNESS: Except Mr. Syson, sir. 24 MS. SCHULTZ: Of course. 25 THE WITNESS: And representatives of the Daily 1 800 325 3376 DTI Court Reporting Solutions New York www.deposition.com ll: ite 11: Thy ll: ll: ity ITs ll: 11: Ty I: It 11: ll: If ih iT ll: 1: ITs iis 11: Thy ll:

Case 18-2868, Document 283, 08/09/2019, 2628241, Page137 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 111 1 Mirror. 2 BY MS. SCHULTZ: 3 Q. Is it correct that you advertise your 4 "excellent relationships with the media" because your 5 services often include giving communications to the media 6 on behalf of your clients? 7 A. Yes. 8 MS. SCHULTZ: That's all I have for right now. 9 MR. DYER: I just wanted to ask you one 10 question about Exhibit 25. This was the email from the 11 New York Daily News to you which you sent on to 12 Ms. Maxwell and Mr. Barden. 13 THE WITNESS: Yes. 14 MR. DYER: Do you recollect whether you were >) asked to make any statement in response to this matter, 16 the issue of proceedings in September of last year? ay, THE WITNESS: I don't, sir. It's always been 18 the case that Mr. Barden and I were encouraging 19 Ms. Maxwell to make a statement, but she was very 20 reluctant to do so. 21 MR. DYER: Right. I think you've got him to 22 accept that up until some time March, April, May, he may 23 have spoken to Mr. Syson. And that was the last 24 statement that there's any evidence of him making about 25 this matter. But on the evidence, as I understand it, DTI Court Reporting Solutions New York 1 800 325 3376 www.deposition.com 11: 11: ll: T1y ll: Ty its its ll: ll: ll: ity 11: 11: ll: 11: Ths IT: ll: ll: iT: 11: ITs Ih: ll:

Case 18-2868, Document 283, 08/09/2019, 2628241, Page138 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 127 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CERTIFICATE OF COURT REPORTER I, Lisa M. Barrett, an Accredited Real-time Reporter, hereby certify that the testimony of the witness Ross Neil Sutherland Gow in the foregoing transcript, numbered pages 1 through 122, taken on this 18th day of November, 2016 was recorded by me in machine shorthand and was thereafter transcribed by me; and that the foregoing transcript is a true and accurate verbatim record of the said testimony. I further certify that I am not a relative, employee, counsel or financially involved with any of the parties to the within cause, nor am I an employee or relative of any counsel for the parties, nor am I, in any way, interested in the outcome of the within cause. Name: Lisa M. Barrett, RPR, CRR, CRC, CSR DTI Court Reporting Solutions New York 1 800 325 3376 www.deposition.com

EXHIBIT 7 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page140 of 883 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS Besse tesese as si See sess ce see seca eesscss Ss x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. SoS oSeeSue Sess ss So Se Se See sae eee asessser= x June 20, 2016 9:12 a.m. CONFIDENTIAL Deposition of MJ pursuant to notice, taken by Plaintiff, at the offices of Podhurst Orseck, 25 West Flagler Street, Suite 800, Miami, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. MAGNA® LEGAL SERVICES Page 1

Case 18-2868, Document 283, 08/09/2019, 2628241, Page141 of 883 Page 54 1 Hs © CONFIDENTIAL 2 BY MR. EDWARDS: 3 0. When you got to his house, you were 4 requested to give a massage? 5 MR. PAGLIUCA: Object to foundation and 6 form. 7 THE WITNESS: I don't exactly remember. I 8 don't remember if I was asked in the kitchen. 9 I don't remember if -- I don't remember. 10 BY MR. EDWARDS: Li: Q. Massage was part of the game, though? 12 MR. PAGLIUCA: Object to form and 13 foundation. 14 THE WITNESS: I don't remember. I'm 15 sorry. 16 BY MR. EDWARDS: 17 Q. But even during this deposition today, we 18 have described at times you giving him a massage? 19 A. Yes. You're asking about my first 20 encounter, though. 21 Q. Sorry, I'm just trying to sum up the whole 22 thing. 23 A. Okay. 24 Q. Was massage part of the lure to get you 25 specifically to his house? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page142 of 883 Page 55 1 Es © CONFIDENTIAL 2 A. Yes. 3 MR. PAGLIUCA: Object to form and 4 foundation. 5 BY MR. EDWARDS: 6 Q. And at the time, you are 15, 16 or 17 7 years old? 8 MR. PAGLIUCA: Object to form and 9 foundation. 10 THE WITNESS: Yes. Lil: BY MR. EDWARDS: 12 Q. No massage experience? 13 A. No. 14 O. You were told to bring other girls to his 15 house? 16 MR. PAGLIUCA: Object to form and 17 foundation. 18 THE WITNESS: After a while, yes. 19 BY MR. EDWARDS: 20 OG. These massages were turned sexual by 21 Jeffrey, as opposed to by anyone else? 22 A. Jeffrey took my clothes off without my 23 consent the first time I met him. 24 Q. The massages were scheduled by people 25 working for Jeffrey? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page143 of 883 Page 56 1 He © CONFIDENTIAL 2 A. I don't recall. 3 MR. PAGLIUCA: Object to form and 4 foundation. 5 BY MR. EDWARDS: 6 Q. Jeffrey Epstein, during these massages 7 would use sex toys or have sex toys used? 8 MR. PAGLIUCA: Object to form and 9 foundation. 10 THE WITNESS: Well, at that point, it's no Li longer a massage. Something else is going on. 12 But, yes, he would take out adult toys and 13 different things. 14 BY MR. EDWARDS: 15 Q. While you were a teenager, Jeffrey Epstein 16 asked you to live with him? 17 A. Yes. He wanted me to be emancipated. 18 Q. Jeffrey Epstein encouraged girl-on-girl 19 sex? 20 MR. PAGLIUCA: Object to form and 21 foundation. 22 THE WITNESS: Yes. 23. BY MR. EDWARDS: 24 Q. And after you cooperated with the police, 25 you were intimidated by people working for Jeffrey MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page144 of 883 Page 57 1 Es © CONFIDENTIAL 2 Epstein? 3 MR. PAGLIUCA: Object to form and 4 foundation. 5 THE WITNESS: Yes. 6 MR. EDWARDS: All right. I don't have 7 anything further for you. I apologize that we 8 even had to go through this, all right? 5 THE WITNESS: Okay. 10 EXAMINATION Lil: BY MR. PAGLIUCA: 12 Q. Ms. JB, by name is Jeff Pagluica. I 13 live in Denver, Colorado. And, like you, I don't 14 want to be here today either, okay? I would rather 15 be in Denver. 16 I just want to -- as I understand it, and 17 I'm not trying to get into any of your treatment 18 over the last, let's say, 10 years, because I don't 19 know how long it's been, but as I understand what 20 you and your lawyer have said here today, you have 21 been involved in some number of years of therapy, in 22 which the purpose -- part of the purpose of the 23 therapy has been to forget all of these events that 24 Mr. Edwards was asking you questions about; is that 25 correct? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page145 of 883 Page 71 - CONFIDENTIAL CERTIFICATE OF OATH STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) aOR WNP I, the undersigned authority, certify that 6 HE) 2 Sonally appeared before me and was duly sworn. oh WITNESS my hand and official seal this 23rd day of June, 2016. 8 9 Kelli Ann Willis, RPR, CRR 10 Notary Public, State of Florida Commission FF928291, Expires 2-16-20 11 aoe a deb oe ae hk oh oh 12 CERTIFICATE 13 STATE OF FLORIDA 14 COUNTY OF MIAMI-DADE ) 15 I, Kelli Ann Willis, Registered Professional Reporter and Certified Realtime 16 Reporter do hereby certify that I was authorized to and did stenographically report the 17 foregoing deposition of [J that a review of the transcript was not requested; and 18 that the transcript is a true record of my stenographic notes. 19 I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any 20 of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected 21 with the action, nor am I financially interested in the action. 22 Dated this 23rd day of June, 2016. 23 24 KELLI ANN WILLIS, RPR, CRR 25 MAGNA® LEGAL SERVICES

EXHIBIT 8 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page147 of 883 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VIRGINIA L. GIUFFRE, Plaintiff, Vv. CASE NO.:15-CV-07433-RWS GHISLAINE MAXWELL, Defendants. January 25, 2017 9:05 a.m. - 12:44 p.m. 401 E. Las Olas Boulevard Fort Lauderdale, Florida eeee CONF IDENT TIA L ¥*** VIDEOTAPE DEPOSITION OF SARAH KELLEN Taken on behalf of the before Michael J. D'Amato, RMR, Notary Public in and for the State of Florida at Large, pursuant to Notice of Taking Deposition in the above cause. Job # 293966 MAGNA® LEGAL SERVICES

10 nat 12 13 14 15 16 17 18 Lo 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page148 of 883 Page 15 decline to answer. Q. Who introduced you to Ghislaine Maxwell? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand protect the innocent and therefore I must unfortunately decline to answer. Q. When you met Ghislaine Maxwell was she working for Jeffrey Epstein? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand protect the innocent and therefore I must unfortunately decline to answer. Os Did Ghislaine Maxwell work as a recruiter for young girls for Jeffrey Epstein when you met her? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand protect the innocent and therefore I must unfortunately decline to answer. Q. I'm defining young girls to mean females the ages 12 to 23. Do you understand that? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand protect the innocent and therefore I must unfortunately decline to answer. Q. Didn't Ghislaine Maxwell approach you to MAGNA® LEGAL SERVICES

10 A 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page149 of 883 Page 20 girls for sex with Jeffrey Epstein? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand protect the innocent and therefore I must unfortunately decline to answer. Q. Did you assist Ghislaine Maxwell in procuring underage girls for sex with Jeffrey Epstein? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand protect the innocent and therefore I must unfortunately decline to answer. O Isn't it true that Ghislaine Maxwell would recruit underage girls for sex and sex acts with Jeffrey Epstein? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand protect the innocent and therefore I must unfortunately decline to answer. OQ. Did Ghislaine Maxwell give you information on what underage girls she had contact information for? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand protect the innocent and therefore I must unfortunately decline to answer. Os Did Ghislaine Maxwell teach you to offer these MAGNA® LEGAL SERVICES

10 a 12 13 14 15 16 17 18 Lo 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page150 of 883 Page 199 CERTIFICATE OF COURT REPORTER I, MICHAEL J. D'AMATO, a Registered Merit Reporter and Notary Public in and for the State of Florida at Large, do HEREBY CERTIFY that I was authorized to and did stenographically report the deposition of SARAH KELLEN; that a review of the transcript was requested; and that the foregoing transcript, pages from 1 to 197, is a true and accurate record of my stenographic notes. I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected with the action, nor am I financially interested in the action. Dated this 27th day of January 2017. MICHAEL J. D'AMATO, Registered Merit Reporter MAGNA® LEGAL SERVICES

EXHIBIT 9 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page152 of 883 Page 1 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS VIDEOTAPE DEPOSITION OF: PETER KENT November 29, 2016 VIRGINIA L. GIUFFRE, Plaintiff, GHISLAINE MAXWELL, Defendant. PURSUANT TO SUBPOENA AND NOTICE, the videotape deposition of PETER KENT was taken on behalf of the Plaintiff at 150 East 10th Avenue, Denver, Colorado 80230, on November 29, 2016, at 9:00 a.m., before Sandra L. Bray, Registered Diplomate Reporter, Certified Realtime Reporter, and Notary Public within Colorado. MAGNA LEGAL SERVICES (866) 624-6221 MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page153 of 883 10 1. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 25 MS. McCAWLEY: I'm just asking about his retention, which I believe is discoverable under Rule 26. Q. (BY MS. McCAWLEY) Do you recall whether you were retained to perform work for one expert or two experts? THE DEPONENT: Am I allowed to answer this? MR. PAGLIUCA: Yes. A. I actually don't recall. Q. (BY MS. McCAWLEY) Do you know whether you were provided with one report or two reports when you initially were retained? A. I believe I was provided with both the reports at the same time. QO. Let me turn to about halfway back. So it's going to be -- there's markings on the bottom. It says PK-005. A. Yes. 0% And it indicates an amount there, an invoice. Is this one of your invoices? A. Yes. O% It indicates an amount of $17,875? A. Yes. Q. Is that the total amount you've been MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page154 of 883 Page 26 1 paid, with the exception of what we paid you for your 2 testimony here today, in this matter? 3 AY I think so. What date was this? 4 0: It looks like it's dated October 29th, 5: 2016. 6 A. Oh, yes. In that case, yes. 7 Q. Have you performed any work after that 8 date that you've been paid for? 9 Ay Only in preparation for this deposition. 10 Q Have you been paid for that work? 11 A. No. 12 Q. No. Have you invoiced that work yet? 13 A No. 14 Q. All right. And then I'm going to turn 15 you to the next page -- please don't put it away 16 yet -- which appear to be invoices. 17 A. Time sheets. 18 Q. Time sheets? You tell me. 19 A. It's a time sheet. 20 Q. Is this typically how you record your 21 time when you're doing expert work? 22 A. Yes. 23 Q. And this indicates -- the first entry is 24 on 9/28/2016. Is that when you commenced work on this 25 matter? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page155 of 883 Page 162 REPORTER'S CERTIFICATE STATE OF COLORADO ) }, “SSis CITY AND COUNTY OF DENVER) I, SANDRA L. BRAY, Registered Diplomate Reporter, Certified Realtime Reporter, and Notary Public ID 20084001729, State of Colorado, do hereby certify that previous to the commencement of the examination, the said PETER KENT was duly sworn by me to testify to the truth in relations to the matters in controversy between the parties hereto; that the said deposition was taken in machine shorthand by me at the time and place aforesaid and was thereafter reduced to typewritten form; that the foregoing is a true transcript of the questions asked, testimony given, and proceedings had. I further certify that I am not employed by, related to, nor of counsel for any of the parties herein nor otherwise interested in the outcome of this litigation. IN WITNESS WHEREOF, I have affixed my signature this 8th of December, 2016. My commission expires January 16, 2020. X__ Reading and Signing was requested. Reading and Signing was waived. Reading and Signing is not required. MAGNA® LEGAL SERVICES

EXHIBIT 10 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page157 of 883 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ee es Seas Me eS ee SOE, SUS, Sie Se SO VIRGINIA L. GIUFFRE, Plaintiff, Case No.: 15-cv-07433-RWS -against-— GHISLAINE MAXWELL, Defendant. CONFIDENTIAL Videotaped oral deposition of NADIA MARCINKO, taken pursuant to notice, was held at the law offices of BOIES SCHILLER & FLEXNER, LLP, 575 Lexington Avenue, New York, New York commencing January 17, 2017, 1:04 p.m., before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page158 of 883 Page 10 el N. Marcinko - Confidential 2 reside, a dwelling that is paid for by either 3 Jeffrey Epstein or Ghislaine Maxwell? 4 A. Same answer. 3 Os Do you know Jeffrey Epstein? 6 A. Same answer. a; Ow Do you know Ghislaine Maxwell? 8 A. Same answer. 9 Q. How old were you when you met 10 either Jeffrey Epstein or Ghislaine Maxwell? 1 A. Same answer. 12 Q. Who introduced to you Ghislaine 13 Maxwell? 14 A. Same answer. 15 Om When you met Ghislaine Maxwell, was 16 she working for Jeffrey Epstein? 17 A. Same answer. 18 Q. Did Ghislaine Maxwell work as a 19 recruiter of young girls for Jeffrey Epstein 20 when you met her? 21 A. Same answer. 22 Q. Did Ghislaine Maxwell instruct you 23 to recruit young girls for Jeffrey Epstein? 24 A. Same answer. 25. Oe Did Ghislaine Maxwell encourage MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page159 of 883 Page 12 1 N. Marcinko - Confidential 2 Ghislaine Maxwell? 3 A. Same answer. 4 Q. Have you observed Ghislaine Maxwell 3 and Jeffrey Epstein offering these young 6 girls money, education or other things of 7 value during the massage to get that young 8 girl to return to Jeffrey Epstein for sexual 9 purposes? 10 A. Same answer. 11 QO. Have you observed Ghislaine Maxwell 12 and Jeffrey Epstein convert what started as a 13 massage with these young girls into something 14 sexual? 15 A. Same answer. 16 @. Have you understood when I talk 17 about young girls, I'm talking about girls 18 between the age range of 13 and 23 years old? 19 A. Same answer. 20 Q. Have you observed that when 21 Ghislaine Maxwell and Jeffrey Epstein used 22 the term, massage, it always includes sex? 23 A. Same answer. 24 Q. Was massage a word used by 25 Ghislaine Maxwell to lure girls into sex with MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page160 of 883 aL 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 96 CERTIFICATE I HEREBY CERTIFY that the witness, NADIA MARCINKO, was duly the deposition ji testimony gi sworn by me and that Registered Professional Reporter Dated: January (The foregoing this transcript does not reproduction of the same under the direct control 17, 2017 certification of apply to any by any means, unless and/or supervision of the certifying reporter.) MAGNA® LEGAL SERVICES

EXHIBIT 11 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page162 of 883 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Se oS oie 2 2s aah a eS Sud, & se VIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against- 15-cv-07433-RWS GHISLAINE MAXWELL, Defendants. So, ee. ee ee ee, Ss ge ** CONF IDENTIAL** Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page163 of 883 Page 23 1 G Maxwell - Confidential 2 Q. I'm not talking about friends. I'm 3 talking about individuals -4 MR. PAGLIUCA: I'm going to object 3 to you interrupting the witness who was 6 answering your question. The question 7 was, have you ever seen anyone, female 8 under the age of 18 at the house and 9 that's the question she was answering. 10 If you want to strike that question and 11 ask another question, feel free, but let 12 the witness respond, please. 13 MS. McCAWLEY: I will do that. 14 Q. Have you ever observed a female 15 under the age of 18 at Jeffrey Epstein's home 16 that was not a friend, a child -- one of your 17 friend's children? 18 A. Again, I can't testify to that 19 because I have no idea what you are talking 20 about. Al Q. You have no idea what I'm talking 22 about in the sense you never observed a 23 female under the age of 18 at Jeffrey 24 Epstein's home that was not one of your 25 friend's children, is that correct? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page164 of 883 Page 24 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. How would I possibly know how 3D: someone is when they are at his house. You 6 are asking me to do that. I cannot possibly 7 testify to that. As far as I'm concerned, 8 everyone who came to his house was an adult 9 professional person. 10 Q. Are you familiar with the police 11 report that was issued in respect to the 12 investigation in this matter? 13 MR. PAGLIUCA: Object to the form 14 and foundation. 15 Q. Are you familiar with the police 16 report that was used in this matter, the 17 investigation of Jeffrey Epstein, has been 18 produced as a document in this matter? 19 A. I have seen a police report. 20 (Maxwell Exhibit 1, police report, Al. marked for identification.) 22 Q. The police report that you have in 23 front of you, can you turn to page 28 of that 24 report, the numbers are on the top right-hand 25 corner. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page165 of 883 Page 31 1 G Maxwell - Confidential 2 -- just another one of Virginia's many 3 fictitious lies and stories to make this a 4 salacious event to get interest and press. 3 It's absolute rubbish. 6 Q. Were you in charge of hiring a individuals to provide massages for Jeffrey 8 Epstein? 9 A. My job included hiring many people. 10 There were six homes. As I sit here, I hired 11 assistants, I hired architects, I hired 12 decorators, I hired cooks, I hired cleaners, 13 I hired gardeners, I hired pool people, I 14 hired pilots, I hired all sorts of people. 15 In the course and a very small part 16 of my job was from from time to time to find 17 adult professional massage therapists for 18 Jeffrey. 19 Q. When you say adult professional 20 massage therapists, where did you find these 21 massage therapists? 22 A. From time to time I would visit 23 professional spas, I would receive a massage 24 and if the massage was good I would ask that 25) man or woman if they did home visits. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page166 of 883 Page 41 1 G Maxwell - Confidential 2 Q. Did you hire her? 3 A. First of all, I don't hire girls 4 like that, so let's be clear, I already 5 testified to that, and I have no idea what 6 you are referring to. 7 O% When you say girls like that, what 8 do you mean? 9 A. I hire people who are professional 10 at the house. You are asking if I hired 1 somebody to do what, I don't know what you 12 are talking about. I hired people to work in 13 the homes. 14 Q. What was Nadia Marcinkova doing? 15 MR. PAGLIUCA: Object to the form 16 and foundation. 17 A. I have no idea what Nadia 18 Marcinkova was doing. I didn't hire her and 19 I don't know what you are referring to. 20 Q You met Nadia Marcinkova? 21 A. I testified I did. 22 Q Did she work for Jeffrey Epstein? 23 A I have no idea what she did. 24 Q. Have you flown on planes with Nadia 25 Marcinkova? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page167 of 883 Page 77 1 G Maxwell - Confidential 2. MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I don't know what that means, 3 masseuse obligation, I don't know what you 6 are referring to. Would you like to ask the 7 question properly? 8 Q. I think it was proper. I will ask 9 it again. 10 Did you ever assist in getting 1 Virginia Roberts a cell phone to use during 12 the time that she worked for Jeffrey Epstein? 13 A. I have no recollection of doing 14 anything of that nature. 15 Q. Did you ever tell Virginia that you 16 wanted her to have a cell phone so that she 17 could be on call regularly? 18 A. I have no recollection of that 19 conversation. 20 0% How often would Virginia come over 21 to the house in Palm Beach to give massages? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Ask the question again, please. 25. 0. How often did Virginia Roberts come MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page168 of 883 Page 78 1 G Maxwell - Confidential 2 over to the house in Palm Beach to give 3 massages? 4 A. It's important to understand that I 5 wasn't with Jeffrey all the time. In fact, I 6 was only in the house less than half the z time, so I cannot testify to when I wasn't in 8 the house how often she came when I wasn't 9 there. 10 What I can say is that I barely 11 would remember her, if not for all of this 12 rubbish, I probably wouldn't remember her at 13 all, except she did come from time to time 14 but I don't recollect her coming as often as 15 she portrayed herself. 16 Q. How many times a day on an average 17 day would Jeffrey Epstein get a massage? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. When I was at the house and when I Al. was there with him, he received a massage, on 22 average, about once a day. 23 Q. Just once? 24 A. Yes. 25 QO. Were there days when he received MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page169 of 883 Page 79 1 G Maxwell - Confidential 2 four or five? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 3 A. When I was present at the house, I 6 never saw something like that. f Q. Do you know if Virginia was 8 required to be on call at all times to come 9 to the house if Jeffrey wanted her there? 10 MR. PAGLIUCA: Objection to the 1. form and foundation. 12 A. I have no idea of the arrangements 13 that Virginia made with Jeffrey. 14 Ox When Virginia was in New York, 15 would Virginia sleep at Jeffrey's mansion in 16 New York? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I don't recollect her being in New 20 York and I have no idea where she slept. Al. Q. You don't ever remember seeing 22 Virginia Roberts in New York? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25) A. I would barely recollect her at MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page170 of 883 Page 135 1 G Maxwell - Confidential 2. him at any of those homes? 3 A. Again, Virginia is absolutely 4 totally lying. This is a subject of D defamation about Virginia and the lies she 6 has told and one of lies she told was that 7 President Clinton was on the island where I 8 was present. Absolutely 1000 percent that is 9 a flat out total fabrication and lie. 10 Q. You did fly on planes, Jeffrey 11 Epstein's planes with President Clinton, is 12 that correct? 13 A. I have flown, yes. 14 Q. Would it be fair to say that 15 President Clinton and Jeffrey are friends? 16 A. I wouldn't be able to characterize 17 it like that, no. 18 Or Are they acquaintances? 19 A. I wouldn't categorize it. 20 0. He just allowed him to use his 21 plane? 22 A. I couldn't categorize Jeffrey's 23 relationship. 24 Q. When you were on the plane with 25 Jeffrey and President Clinton, did you MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page171 of 883 Page 144 1 G Maxwell - Confidential 2 building that you would have seen when you 3 were on the trip in Europe? 4 MR. PAGLIUCA: Objection to the 3 form and foundation. 6 A. I can't possibly answer that. e Q. Do you recall Virginia ever taking 8 pictures? 9 A. I barely recall Virginia, period. 10 Q. Do you recall her ever taking 1k pictures? 12 A. No, I don't. 13 Q. I'm going to direct your attention, 14 still within the flight logs to -- starting 15 on the next page from where you just were 16 which is going to be 000747. And the date at 17 the top says 2001, you will see March and I'm 18 directing your attention down towards the 19 middle to the bottom where you will see the 20 numbers 27, 29 and 31. 21 A. Uh-huh. 22 Q. And we've got actually I'm going to 23 direct your attention to the one that starts 24 with TEB for Teterboro to SAF for Santa Fe 25 and the one below it Santa Fe to Palm Beach MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page172 of 883 Page 147 1 G Maxwell - Confidential 2 her but you would have to ask Jeffrey what he 3 brought her on the trip for. 4 Q. But she would travel with him when 3D: there was a work trip like this? 6 A. I can't -- I'm seeing that she is at on this flight but I have no idea what she is 8 doing, he invited her, it would not be my 9 job. 10 0. What about Nadia Bjorlin, would she 11 regularly travel with Jeffrey on flights? 12 A. I have no idea, you would have to 13 look through the flight logs. I have no 14 idea. 15 Q. Your recollection is -- what is 16 your recollection, do you recollect Nadia 17 traveling often on flights with Jeffrey? 18 A. Absolutely not. No, not at all. I 19 don't recollect her actually on the flight at 20 all. 21 Q. I think you can set that aside for 22 the moment. 23 (Maxwell Exhibit 9, message pad 24 pages, marked for identification.) 25. 0% We will mark as Exhibit 9 these MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page173 of 883 Page 148 1 G Maxwell - Confidential 2 excerpts from -- we will identify what they 3 are but from the message pads. 4 Did you want to correct anything? 3 A. I want to make an addendum. 6 Would you mind rereading the last 7 question back to me? 8 (Record read.) 9 A. I also just want to say that at 10 this point I cannot recollect flying to 1 parties. Jeffrey went for work so -- was 12 this in Santa Fe, this flight as well. 13 Q. The flight we were looking at, yes 14 but it was to Santa Fe -15 A. I don't recall going to any parties 16 in Santa Fe at any time but certainly flying AT to Santa Fe for a party seems highly 18 improbable. 19 Q. So I'm going to direct your 20 attention to the document that I set before 21 you which is Bates number SAO 01456 and it 22 has different Bates numbers because it's a 23 smaller version of the larger production. 24 These are the pages I will be asking about. 25 In the time that you were working MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page174 of 883 Page 149 1 G Maxwell - Confidential 2 with Jeffrey in Palm Beach, do you recall a 3 process for taking, anybody at the house 4 taking messages when incoming phone calls 3 came in? 6 A. You are supposed to take a message 7 and receive the message and write the message 8 down. Who was the message was for, what time 9 it was taken and who took it and what the 10 message was, obviously. 11 Q. Does what's in front of you look 12 familiar with respect to the message pads 13 that you would have used at the house? 14 A. It is familiar. 15 Q. I'm going to direct your attention 16 to the second page of it? 17 MR. PAGLIUCA: These all have SAO 18 numbers on them or Bates ranges and I 19 don't see any of your Bates ranges on 20 these. I know you have produced message 21 pads but those have your Bates range 22 numbers on them and I'm wondering if 23 these are different documents. 24 MS. McCAWLEY: It's the same, just 25 ours have the Bates underneath them. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page175 of 883 Page 174 1 G Maxwell - Confidential 2. believe. Do you believe -3 A. I can only testify -4 Q. Let me finish the question so the 3 record is clear. 6 Do you believe Jeffrey Epstein 7 sexually abused minors? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 QO. You can answer. 11 A. I can only testify to what I know. 12 I know that Virginia is a liar and I know 13 what she testified is a lie. So I can only 14 testify to what I know to be a falsehood and 15 half those falsehoods are enormous and so I 16 can only categorically deny everything she 17 has said and that is the only thing I can 18 talk about because I have no knowledge of 19 anything else. 20 Q. I'm not asking about Virginia. I'm 21 asking whether you believe that Jeffrey 22 Epstein sexually abused minors? 23 A. Again, I repeat, I can only go on 24 what I know and what I know is a falsehood 25) based on what Virginia said. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page176 of 883 Page 178 1 G Maxwell - Confidential 2 What I'm asking you is whether you 3 believe Jeffrey Epstein abused minors? 4 MR. PAGLIUCA: I object to the form 3 and you made your record, she answered 6 the question. A fair reading of her 7 answer is she doesn't have a belief 8 because she doesn't have any personal 9 knowledge. 10 MS. McCAWLEY: Now you are 1. testifying for the witness. Let her 12 answer the question. 13 MR. PAGLIUCA: It's a fair answer 14 to the question. 15 Aw Again, I testified my only personal 16 knowledge concerns Virginia and everything 17 Virginia has said is an absolute lie, which 18 is why we are here in this room. If you are 19 asking me to testify about things I have no 20 knowledge of other than the police report 21 that you showed me, I am not in a position to 22 make a statement based on that because you 23 are asking me to speculate and I cannot 24 speculate. 25) O% I'm asking you about your belief. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page177 of 883 Page 179 1 G Maxwell - Confidential 2 I'm not asking you to speculate at all. I'm 3 asking what you believe. 4 A. You are asking me to speculate and D I won't speculate. 6 Q. I'm not asking you to speculate. 7 I'm asking what you believe. 8 MR. PAGLIUCA: She answered the 9 question and we can move on. 10 MS. McCAWLEY: She hasn't answered 1. the question. 12 MR. PAGLIUCA: We are not going to 13 engage in this debate. She answered the 14 question. If you want to mark it and 15 move to compel an answer to the 16 question, have at it. Okay. Ay Q. Ms. Maxwell, is it your belief that 18 Jeffrey Epstein interacted sexually with 19 minors? 20 A. Again, you are asking me the same 21 type of question exactly but with different 22 language. Again, my only knowledge of 23 somebody who claims these things that I have 24 personal knowledge of is Virginia. Virginia 25) is an absolute liar and everything she has MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page178 of 883 Page 180 1 G Maxwell - Confidential 2 said is a lie. Therefore, based on those 3 lies I cannot speculate on what anybody else 4 did or didn't do because if Virginia is the 3 example of what that story is and everything 6 she said is false, so everything that leads “f from that is false. 8 Q. So the 30 other minor children in 9 the police report are also telling lies about 10 being sexually abused during massages with 11 Mr. Epstein? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. Counsel, can you 14 show me in these police reports who the 15 30 minors are? 16 MS. McCAWLEY: I'm asking my 17 question. 18 MR. PAGLIUCA: You are making a 19 representation about numbers, you are 20 making a representation on the record 21 about what people said or didn't say. 22 We have no knowledge about that. These 23 are all redacted records so these are 24 bad questions. They don't lead to any 25) admissible evidence. It is only being MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page179 of 883 Page 214 1 G Maxwell - Confidential 2. A. I'm carrying on. 3 Q. I'm sorry. I thought you were 4 done. 3 A. Please. Her statement also that 6 she was driven by her father to Palm Beach. q She was driven by her mother, as a matter of 8 fact. Her whole entire characterization of 9 the first meeting with Jeffrey, as I was 10 outside speaking to her mother. 1 Q. Let me stop you there, so we don't 12 get too far ahead. Let me make sure I 13 understand your testimony. 14 The first, in the first piece when 15 you were talking, I believe you said and 16 correct me if I'm wrong, that her 17 characterization of the first meeting at 18 Mar-a-Lago was an obvious lie. 19 What part of that meeting was an 20 obvious lie? 21 A. By her own testimony, all her 22 various many different descriptions of what 23 she was or wasn't or where she was or wasn't, 24 they have all changed. She was either front 25 of house or bathroom attendant. I don't know MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page180 of 883 Page 215 1 G Maxwell - Confidential 2 what she was, so just by her own words, one 3 doesn't know what's true and what isn't true. 4 Q. Are you saying what position she 3D: said she was working in, is that what you are 6 considering the obvious lie? z A. I said inconsistency within her own 8 statement from everything, so in the 9 beginning it starts off with different 10 statements. 11 Q. Then I believe you said the second 12 piece was that she was driven by her father? 13 A. I said she was driven by her 14 mother. 15 Q. That's the obvious lie? 16 A. It's an obvious lie to me. 17 Q. You said why don't you state it in 18 your own words but the characterization of 19 how she was with Jeffrey, what about that is 20 an obvious lie? 21 Aw I was standing outside talking to 22 her mother so the entire story is a 23 fabrication. 24 Q. Did she not have sex with Jeffrey 25 Epstein during that first massage? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page181 of 883 Page 220 1 G Maxwell - Confidential 2 up to the room and start a massage? 3 A. He would not. 4 Q. So the young girls in the police 3 report who say they came over and were led up 6 to the room on the first day, would they be “| wrong about that? 8 MR. PAGLIUCA: Objection to form 9 and foundation. 10 A. I can't comment what happened when 1. I was not at the house. I can only comment 12 when I was at the house. 13 QO. Was there ever a time where a woman 14 came to the house for the first time to give 15 a massage and Jeffrey had the massage that 16 day? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. Can we talk about adult 20 professional masseuses, please? Al Q. I'm asking, whether adult or 22 underage? 23 A. I'm not interested in talking about 24 underage. I can only testify to what I know, 25 professional masseuses, adult, I cannot MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page182 of 883 Page 221 1 G Maxwell - Confidential 2 testify to anything else. 3 Q. Why can't you testify to an 4 underage girl that came over and was led up 3 to the room for a massage? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. The police records you are 9 referring to? 10 Q. You are saying that didn't happen. 1. You're saying I can only testify to adults 12 that came for an interview and were led up to 13 the room. Why can't you testify to whether 14 an underage girl was brought in for an 15 interview and led up -16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 Q. Go ahead. 19 A. Can you reask the question. 20 Q. Why can't you testify as to an 21 underage girl who came over for an interview 22 and then was then led up to the room for the 23 massage? 24 A. You've mangled your entire 25 question. Can you please reask that in a way MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page183 of 883 Page 225 1 G Maxwell - Confidential 2 present at the home when a girl under the age 3 of 18 came over for the purposes of giving a 4 massage? 3D: MR. PAGLIUCA: Objection to the 6 form and foundation. a Q. You can answer. 8 A. You can be a professional masseuse 9 at 17 in Florida, so as far as I am aware, a 10 professional masseuse showed up for a 11 massage. There is nothing inappropriate or 12 incorrect about that and your 13 mischaracterization of it, I think is 14 unfortunate. 15 Q. How many teenagers did he have that 16 were professional masseuses that worked in 17 his home? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 05 How many? Al. A. First of all, I am not aware of 22 teenagers who worked in his home. 23 Q. You are aware of Virginia Roberts 24 and you've stated she was 17 and she worked 25 for him, correct? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page184 of 883 Page 226 1 G Maxwell - Confidential 2 A. No. I did not state that at all, 3 you are mischaracterizing my words and what I 4 said. 3 What I said was that we can all 6 agree and I think at this point there is not 7 one person in this room, however much you 8 would like her to be younger, to say she was 9 not 17 because that has been a very offensive 10 thing that you have all done. So she was 17. 1 At 17 you are allowed to be a professional 12 masseuse and as far as I'm concerned, she was 13 a professional masseuse. There is nothing 14 inappropriate or incorrect about her coming 15 at that time to give a massage. Her entire 16 characterization of her first time at the 17 house was to me an obvious lie, given it was 18 impossible for her entire story to take place 19 given I was speaking to her mother the entire 20 she was at the house. Al. Q. So it was impossible that day, that 22 first day she came and you were speaking to 23 the mother, for Virginia Roberts to have had 24 sex with Jeffrey Epstein during the time that 25 you were outside with her mother? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page185 of 883 Page 228 1 G Maxwell - Confidential 2 absolutely 1000 percent that she did not have 3 any type of sexual relations as described by 4 you in your court papers that took place 3 because those allegedly according to her lies 6 involved some aspect of me. e As I was standing outside with her 8 mother the entire time, her entire story is a 9 lie. Therefore, to ask me what she did or 10 didn't do during that time, I can only 1 testify to what she said about me, which was 12 1000 percent false. 13 Q. So let's not take the first time, 14 let's take the next time she comes. 15 A. No no, how can do you that, when 16 the basis of this entire horrible story that 17 you have put out is based on this first 18 appalling story that was written, repeated, 19 multiply by the press that lied about her 20 age, lied about the first time she came, lied 21 about and characterized the entire first 22 time. I have been so absolutely appalled by 23 her story and appalled by the entire 24 characterization of it and I apologize 25) sincerely for my banging at the table MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page186 of 883 Page 229 1 G Maxwell - Confidential 2 earlier, I hope you accept my apology. It's 3 borne out of years of feeling the pressure of 4 this entire lie that she has perpetrated from 3 our first time and whilst I recognize that 6 was -- I hope you forgive me sincerely cf because it was just the length of time that 8 that terrible story has been told and retold 9 and rehashed when I know it to be 100 percent 10 false. 11 Q. So not the first time she came, but 12 the second time she came or the third time or 13 any time she came, did you ever participate 14 in a massage with her in Jeffrey Epstein's 15 room? 16 A. I have never participated at any 17 time with Virginia in a massage with Jeffrey. 18 Q. Have you ever participated at any 19 time with Virginia in any kind of sexual 20 contact or sexual touching with Jeffrey and 21 Virginia? 22 A. I have not. 23 Q. So we were going through the list 24 of obvious lies and you were talking about 25 the first time which I believe we have MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page187 of 883 Page 248 1 G Maxwell - Confidential 2 of 18? 3 A. I think we can establish what adult 4 would be. D Q. You never interviewed or I know you 6 don't want to use the word hired, whatever 7 your role was, you brought in an exercise 8 instructor that was under the age of 18 to 9 work at the house? 10 MR. PAGLIUCA: Object to the form ale and foundation. 12 A. I have already testified that what 13 I was responsible for was to find people who 14 had competencies in whatever area I was 15 looking for. The competencies I was looking 16 for were professional and adult. 17 Q. So there was no exercise instructor 18 that worked at the Palm Beach house or the 19 New York house or the New Mexico house or the 20 USVI under the age of 18? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. I can only testify to when I was at 24 the house. 25 Q. Yes. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page188 of 883 Page 310 1 G Maxwell - Confidential 2. MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. That's not how I would characterize 3 that. 6 Q. How would you characterize it? | A. I have testified that I'm 8 responsible for finding professional people 9 to work in the homes, age appropriate adult 10 people, so from pool attendants, to 11 gardeners, to chefs, to housekeepers, to 12 butlers, to chauffeurs and one of the 13 functions was to be able to answer the 14 telephones and in the context of finding 15 someone to answer the telephones, I did look 16 to try to find appropriate people to answer AT the phones. 18 Q. So did you find Johanna for 19 purposes of that role? 20 A. So in the course of looking for 21 somebody to answer phones at the house, 22 Johanna was one of the people who said that 23 she was willing to answer phones. 24 Q. Did you approach her at her school 25) campus? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page189 of 883 Page 383 1 G Maxwell - Confidential 2 Q. List all of the girls you met and 3 brought to Jeffrey Epstein's home for the 4 purposes of employment that were under the S age of 18? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I've already characterized my job 9 was to find people, adults, professional 10 people to do the jobs I listed before; pool 11 person, secretary, house person, chef, pilot, 12 architect. 13 0. I'm asking about individuals under 14 the age of 18, not adult persons, people 15 under the age of 18. 16 A. I looked for people or tried to AT find people to fill professional jobs in 18 professional situations. 19 0% So Virginia Roberts was under the 20 age of 18, correct? 21 A. I think we've established that 22 Virginia was 17. 23 Q. Is she the -- sorry, go ahead. 24 Is she the only individual that you 25 met for purposes of hiring someone for MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page190 of 883 Page 390 1 G Maxwell - Confidential 2. MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. If you want to ask Jeffrey 3 questions about me, you would have to ask 6 him. 7 OQ. Have you ever been involved in any 8 illegal activity in your lifetime? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I can't think of anything I have 12 done that is illegal. 13 O% Have you ever been arrested? 14 A. I have a DUI in the U.K. a long 15 time ago. 16 Q. Is that the only arrest you have on 17 your record? 18 A. Yes. 19 or I will mark as Maxwell 22 this 20 email? 21 (Maxwell Exhibit 22, email, marked 22 for identification.) 23 Q. This is dated January 21, 2015. 24 It's from Jeffrey Epstein to you, forwarding 25 the Guardian and I would like you to look at MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page191 of 883 CERTIFICATE I HEREBY CERTIFY that the witness, GHISLAINE MAXWELL, was duly sworn by me and that the deposition is a true record of the testimony given by the witness. / [/ Lesl¥e Fagin, Registered Professional Reporter Dated: April 22, 2016 (The foregoing certification of this transcript does not apply to any reproduction of the same by any means, unless under the direct control and/or supervision of the certifying reporter.) MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page192 of 883 Confidential Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Se 2 SS eee a eye S'S 2°S -S & Se VIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against- 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. ** CONFIDENTIAL** Continued Videotaped Deposition of GHISLAINE MAXWELL, the Defendant herein, taken pursuant to subpoena, was held at the law offices of Boies, Schiller & Flexner, LLP, 575 Lexington Avenue, New York, New York, commencing July 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page193 of 883 Confidential Page 44 1 G. Maxwell - Confidential 2 thought. I really don't recall her, so it's 3 hard for me to testify what I thought about 4 her age at the time. 5 Q. Was Virginia, in the period of 6 around 2000, the youngest person that, as you 7 understood it, was giving Mr. Epstein 8 massages? 9 MR. PAGLIUCA: Object to the form 10 and foundation. 11 A. Again, I can't testify to her age, 12 but everybody else that I can recall seemed 13 to be again, like I would say, adults. 14 Q. You didn't think Virginia was an 15 adult, did you? 16 MR. PAGLIUCA: Object to the form 17 and foundation. 18 A. Like I said, I don't recall her. I 19 don't recall thinking about -- my memory is 20 of adults giving Jeffrey massages, and as I 21. don't really remember Virginia around that 22 time, I don't know what I think. 23 Ors You do remember Virginia, about 24 that time back in the 2000s, giving 25) Mr. Epstein massages? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page194 of 883 Confidential 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 As I barely remember her at all. 5 Q. Whether you barely remember her or 6 not, you do remember that back in the period p around 2000, Virginia was giving Mr. Epstein 8 massages, right? 9 MR. PAGLIUCA: Objection to form 10 and foundation. 11 A. Only in the most general terms. 12 would be somebody who would give hima 13 massage, and that's it. 14 Oe. During the period of time back in 15 the period around 2000, when you knew that 16 Virginia was somebody who would give 17 Mr. Epstein a massage, was she somebody who 18 you considered an adult? 19 MR. PAGLIUCA: Objection to form 20 and foundation. 21 A. I didn't consider her at all 22 because she is not somebody that I really 23 interacted with. 24 Q. It is your testimony that Virginia 25 was not somebody that you interacted with, MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page195 of 883 Confidential Page 55 G. Maxwell - Confidential Epstein's home in Palm Beach? MR. PAGLIUCA: Objection to form and foundation. Bea eae = uo F WwW NY KB BEER EE bh w =; ay ———————— Saaz | . = a Ss el ee eee re EE ae Ft n ae a a _—— —s! = 2 Ea MAGNA® LEGAL Services

Case 18-2868, Document 283, 08/09/2019, 2628241, Page196 of 883 Confidential Maxwell - Confidential Bao = ~Mm@o wm | Bb G. Q. x a A. a A. a es a Q. a7 a a aw a a BEE SHE EEE Eee Ny oO) MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page197 of 883 Confidential G. Maxwell - Confidential MR. PAGLIUCA: Objection to form and foundation. o Mi MM e& ww MR. PAGLIUCA: Objection to form o and foundation. i oe Oo BEEBE: f nN rag ee | ——————————— | ee ee ——— EEE Ft Eo ee SS eee | es ay Sa ea EE eA MAGNA® LEGAL Services

Case 18-2868, Document 283, 08/09/2019, 2628241, Page198 of 883 Confidential Page 58 1 G. Maxwell - Confidential 2 0 i a i 2 ee ee 7 Ee ————E——————E>E>~c~—_[{_{_ £—$ E> ee 0 —O——SSSSSS==EEEaT 11 2 ee See ee TTT a ae a ee Se ee ff 20 21 MR. PAGLIUCA: Objection to form 22 and foundation. 23 | 24 ee ——————EEE—_—___—_—————== MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page199 of 883 Confidential 1 G. Maxwell - Confidential 2 and foundation. 3 A. No. : a ee a —$$————————eeee— a 8 MR. PAGLIUCA: Objection to form 9 and foundation. 10 A. I don't know. 11 ee & = = a 2 ee eee ae 17 MR. PAGLIUCA: Objection to form 18 and foundation. Asked and answered. 19 A. No. 20 Oo; Were they ever in the Virgin 21 Islands? 22 MR. PAGLIUCA: Objection to form 23 and foundation. 24 A. No. 25 _LULTLTTtt—Ci‘CSCSCSCCts MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page200 of 883 Confidential Page 87 BRR BRE Be ce ee ee ra x NON sw MR. PAGLIUCA: Objection to form ND a and foundation. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page201 of 883 Confidential G. Maxwell - Confidential it to something in the case. MR. BOIES: I think it's tied, but if you instruct her not to answer, it goes into the -MR. PAGLIUCA: Meat grinder. w Ke Ss a BOIES: QP Can you repeat the question? Le} MR. PAGLIUCA: Same objection. ed 0 a ° MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page202 of 883 Confidential CERTIFICATE I HEREBY CERTIFY that GHISLAINE MAXWELL, was duly sworn by me and that the deposition is a true record of the testimony given by the witness. fi -p ee oe LesVie Fadfin, CU OWN DO FWD Registered Professional Reporter Dated: July 22, 2016 (The foregoing certification of this transcript does not apply to any reproduction of the same by any means, unless under the direct control and/or supervision of the certifying reporter.) MAGNA® LEGAL SERVICES

EXHIBIT 12 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page204 of 883 GIUFFRE VS. MAXWELL Deposition LYNN TRUDE MILLER 05/24/2016 Agren Blando Court Reporting & Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-0017

Case 18-2868, Document 283, 08/09/2019, 2628241, Page205 of 883 Agren Blando Court Reporting & Video, Inc. IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS CONFIDENTIAL VIDEOTAPED DEPOSITION OF LYNN TRUDE MILLER May 24, 2016 VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. APPEARANCES: S.J. QUINNEY COLLEGE OF LAW, UNIVERSITY OF UTAH By Paul G. Cassell, Esq. 383 S. University Street Salt Lake City, UT 84112 Phone: 801.585.5202 Cassellp@law.utah.edu Appearing on behalf of the Plaintiff HUTCHINSON BLACK AND COOK, LLC By John Clune, Esq. 921 Walnut Street Suite 200 Boulder, CO 80302 Phone: 303.442.6514 clune@hbcboulder.com Appearing on behalf of the Deponent LYNN TRUDE MILLER 5/24/2016

Case 18-2868, Document 283, 08/09/2019, 2628241, Page206 of 883 Agren Blando Court Reporting & Video, Inc. APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura A. Menninger, Esq. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 lmenninger@hmflaw.com jpagliuca@hmflaw.com Appearing on behalf of the Defendant Also Present: Maryvonne Tompkins, Videographer LYNN TRUDE MILLER 5/24/2016

10 11 12 13 14 1S 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page207 of 883 Agren Blando Court Reporting & Video, Inc. A Because I wasn't told any different. Q Do you know where any -- any source of that information came from? Was it Sky? A It came from Sky. Q Okay. And what do you recall him telling you about when Virginia stopped working at Mar-a-Lago? A She was in a discussion with Mrs. Maxwell to educate her and take her under her wing and be her new momma. That's what I heard. Q Okay. And who told you that? A Sky. Q Okay. And do you remember when Sky told you that? A I don't remember. Q Okay. Did you learn anything else about that, other than what you just said? A No. Q Okay. Do you know where she went to work after Mar-a-Lago? A I think she went with Mrs. Maxwell. Q But do you know where, physically? A Physically, Sky and I dropped her off one day at Mrs. Maxwell's. I did not speak with Mrs. Maxwell. I didn't have anything to say to her. LYNN TRUDE MILLER 5/24/2016 115

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page208 of 883 Agren Blando Court Reporting & Video, Inc. STATE OF COLORADO) ): ss. REPORTER'S CERTIFICATE COUNTY OF DENVER ) I, Kelly A. Mackereth, do hereby certify that I am a Registered Professional Reporter and Notary Public within the State of Colorado; that previous to the commencement of the examination, the deponent was duly sworn to testify to the truth. I further certify that this deposition was taken in shorthand by me at the time and place herein set forth, that it was thereafter reduced to typewritten form, and that the foregoing constitutes a true and correct transcript. I further certify that I am not related to, employed by, nor of counsel for any of the parties or attorneys herein, nor otherwise interested in the result of the within action. In witness whereof, I have affixed my signature this 31st day of May, 2016. My commission expires April 21, 2019. Kelly A. Mackereth, CRR, RPR, CSR 216 - 16th Street, Suite 600 Denver, Colorado 80202 LYNN TRUDE MILLER 5/24/2016 176

EXHIBIT 13 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page210 of 883 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS Besse tesese as si See sess ce see seca eesscss Ss x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. SSS 2SeeSue esd ss Se Sse Ss see sae eee acessses=s x June 21, 2016 9:17 a.m. CONFIDENTIAL Deposition of JOSEPH RECAREY, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Page 1 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page211 of 883 Page 25 JOSEPH RECAREY - CONFIDENTIAL BY MR. EDWARDS: O% All right. Was SG a licensed massage therapist? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: No. BY MR. EDWARDS: Q. And at 14 years old, are you permitted to be a licensed massage therapist? A. Not to my knowledge. Q. After speaking with SG and understanding her account of what took place at Jeffrey Epstein's home, what -- what happened next in the investigation? A. At some point the investigation was turned over to me for follow-up. I know there was trash pulled that was done prior to -- and surveillance that was done prior to the case being turned over to me; and trash pulls being an investigative technique to acquire intelligence, information and evidence. O% Okay. If we go to page 17, at the top, and, first of all, I will ask you from memory, do you remember if J identified Jeffrey Epstein in a photo lineup? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page212 of 883 Page 27 1 JOSEPH RECAREY - CONFIDENTIAL 2 "a cross-reference"? 3 A. Uh-huh. 4 O% How is a cross-reference performed? What 5 does that mean? 6 A. When -- when something is 7 cross-referenced, they -- they jot down license 8 plate numbers. They conduct their background into 9 the individuals; photographs, computer research. 10 Q. A cross-reference of Jeffrey Epstein's 11 residence revealed which affiliated names? 12 A. It revealed Nadia Marcinkova, Ghislane 13 Maxwell, Mark Epstein. Also, the cross-reference, 14 any previous reports from the residence as well. 15 Q. During your investigation, did you learn 16 of any involvement that Nadia Marcinkova had with 17 any of the activities you were investigating? 18 MR. PAGLIUCA: Object to form and 19 foundation. 20 THE WITNESS: Yes. 21 BY MR. EDWARDS: 22 O% And what involvement did you learn of 23 Nadia Marcinkova? 24 MR. PAGLIUCA: Object to form and 25 foundation. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page213 of 883 Page 28 1 JOSEPH RECAREY - CONFIDENTIAL 2 THE WITNESS: Nadia was involved sexually 3 with one of the victims at Epstein's request. 4 BY MR. EDWARDS: 5 Q. Okay. Do you remember which victim you're 6 remembering right now? 7 A. AH. 8 Q. Okay. If it indicates in the report that 9 she was also sexually involved with other victims, 10 is that possible as well? 11 A. Yes. 12 MR. PAGLIUCA: Object to form and 13 foundation. 14 BY MR. EDWARDS: 15 Q. Okay. The one that you remember in your 16 mind is AH? 7 MR. PAGLIUCA: Object to form and 18 foundation. 19 THE WITNESS: Correct. 20 BY MR. EDWARDS: 21 Os The other name that is on here as a 22 cross-reference is Ghislane Maxwell. 23 Did you speak with Ghislane Maxwell? 24 A. I did not. 25 Q. Did you ever attempt to speak with MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page214 of 883 Page 29 1 JOSEPH RECAREY - CONFIDENTIAL 2 Ghislane Maxwell? A. I wanted to speak with everyone related to 4 this home, including Ms. Maxwell. My contact was 5 through Gus, Attorney Gus Fronstin, at the time, who 6 initially had told me that he would make everyone 7 available for an interview. And subsequent 8 conversations later, no one was available for 9 interview and everybody had an attorney, and I was 10 not going to be able to speak with them. 11 Q. Okay. During your investigation, what did 12 you learn in terms of Ghislane Maxwell's 13 involvement, if any? 14 MR. PAGLIUCA: Object to form and 15 foundation. 16 THE WITNESS: Ms. Maxwell, during her 17 research, was found to be Epstein's long-time 18 friend. During the interviews, Ms. Maxwell was 19 involved in seeking girls to perform massages 20 and work at Epstein's home. 21 MR. PAGLIUCA: Object to form and 22 foundation. 23. BY MR. EDWARDS: 24 Q. Did you interview -- how many girls did 25 you interview that were sought to give or that MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page215 of 883 Page 30 1 JOSEPH RECAREY - CONFIDENTIAL 2 actually gave massages at Epstein's home? 3 MR. PAGLIUCA: Object to form and 4 foundation. 5 BY MR. EDWARDS: 6 Q. Approximately. 7 MR. PAGLIUCA: Same objection. 8 THE WITNESS: I would say approximately 9 30; 30, 33. 10 BY MR. EDWARDS: 11 Q. And of the 30, 33 or so girls, how many 12 had massage experience? 13 MR. PAGLIUCA: Object to form and 14 foundation. 15 THE WITNESS: I believe two of them may 16 have been -- two of them. 17 BY MR. EDWARDS: 18 Q. Okay. And as we go through this report, 19 you may remember the names? 20 A. Correct. Let me correct myself. I 21 believe only one had. 22 Q. And was that -- was that one of similar 23 age to the other girls? 24 MR. PAGLIUCA: Object to form and 25 foundation. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page216 of 883 Page 40 1 JOSEPH RECAREY - CONFIDENTIAL 2 foundation. 3 THE WITNESS: Yes, I did. 4 BY MR. EDWARDS: 5 Q. And were trash pulls done at the property 6 of Jeffrey Epstein? 7 A. Yes. 8 Q. What is the purpose of a trash pull, and 5 what is a trash pull? 10 A. A trash pull is when property is Li: discarded, such as trash, we coordinate with the 12 sanitation department to collect the trash, once it 13 leaves the property, and it's put into an empty well 14 of the trash truck. We acquire the bags, and we 15 sift through the contents of the trash. 16 on Did you or another detective from the unit 17 observe each step of the trash pull to make sure 18 that you had a good chain of custody of the 19) evidence? 20 MR. PAGLIUCA: Object to form and 21 foundation. 22 THE WITNESS: Yes. The members of 23 the OCTAN unit at that time did. 24 BY MR. EDWARDS: 25 Q. Okay. And what is that process? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page217 of 883 Page 41 1 JOSEPH RECAREY - CONFIDENTIAL 2 A. The process -3 MR. PAGLIUCA: Object to form and 4 foundation. 5 THE WITNESS: The process is when the -6 once you coordinate a trash pull with the 7 sanitation supervisor, you meet with the 8 sanitation worker and ensure that either the 5 can that he's going to place in the well is 10 completely empty and you physically observe him Li collect the trash and place it into the empty 12 container. And then you follow him to a 13 disclosed area, and we retrieve the bags and 14 you sift through the trash. 15 BY MR. EDWARDS: 16 Q. Okay. What were you looking for in terms 7 of evidentiary value from these trash pulls? 18 MR. PAGLIUCA: Object to form and 19 foundation. 20 THE WITNESS: We were looking for any -—21 any form of identification. You were looking 22 for -- to gather any kind of intelligence 23 and/or evidence. 24 BY MR. EDWARDS: 25 Q. Okay. If we go to page 20 of the report, MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page218 of 883 Page 42 1 JOSEPH RECAREY - CONFIDENTIAL 2 I guess I'll start with where it says on 4/4/2005, I 3 just want to ask you, was a voice mail message taken 4 into evidence from HR to SG? 5 A. Yes. 6 Q. Okay. And the purpose of that evidence is 7 to corroborate what? 8 MR. PAGLIUCA: Object to form and 9 foundation. 10 THE WITNESS: It was actually a phone call Li from HR to SG confirming an appointment to go 12 work at Epstein's residence. 13 BY MR. EDWARDS: 14 Ox The next line down is what I wanted to 15 focus on, April 5th, 2005. 16 This trash pull, what evidence is yielded 17 from this particular trash pull? 18 MR. PAGLIUCA: Object to form and 19 foundation. 20 THE WITNESS: The trash pull indicated 21 that there were several messages with written 22 items on it. There was a message from HR 23 indicating that there would be an 11:00 24 appointment. There were other individuals that 25 had called during that day. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page219 of 883 Page 43 JOSEPH RECAREY - CONFIDENTIAL BY MR. EDWARDS: Q. And when you would -- when you would see females' names and telephone numbers, would you take those telephone numbers and match it to -- toa person? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: We would do our best to identify who that person was. BY MR. EDWARDS: Q. And is that one way in which you discovered the identities of some of the other what soon came to be known as victims? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Correct. BY MR. EDWARDS: Q. Okay. There's the second paragraph from the bottom, it starts, "Detective Leigh provided trash from 4/06, 4/07/2005." Do you see that? A. Yes. Q. And what is the purpose of the indication that "the following information was retrieved: Jet MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page220 of 883 No Page 45 JOSEPH RECAREY - CONFIDENTIAL BY MR. EDWARDS: Oe And then some of the remaining messages, "Johanna, work Sunday at 4 p.m.; A, Monday after school; left message for Courtney W and NT," are these individuals that you later learned were underaged girls that had been to Jeffrey Epstein's home? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: That's correct. BY MR. EDWARDS: Q. What types of documents do you remember retrieving from the trash pulls from Jeffrey Epstein's home? A. There was numerous items. It was a lot of handwritten notes on different -- different pads of paper. Some of the pads had names on it, whether it was Epstein, whether it was Ghislane Maxwell, whether it was -- there were phone messages. When I say "phone messages," I mean, you know, the kind that come in a book. They are carbon copied, so the yellow copy always stays with the book, but the white copy is torn off. So there was always a carbon copy of the actual phone message. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page221 of 883 Page 72 1 JOSEPH RECAREY - CONFIDENTIAL 2 THE WITNESS: Correct. 3 BY MR. EDWARDS: 4 Q. And let me go back to the beginning six 5 pages of that exhibit, No. 4. 6 MR. PAGLIUCA: Why don't we just make a 7 copy of it now if we're going to ask questions 8 about it? I'm not trying to -5 MR. EDWARDS: Yes, I know. It's just the 10 first six pages. 11 (A discussion was held off the record, 12 after which the following proceedings were 13 held:) 14 THE VIDEOGRAPHER: On the record at 10:32. 15 BY MR. EDWARDS: 16 O% And what were some of the items that were 17 found in -- well, are the documents that you're 18 holding, 1 through 6, an accurate reflection of the 19 items that were found in Jeffrey Epstein's home 20 during the search warrant execution? 21 MR. PAGLIUCA: Object to form and 22 foundation. 23 THE WITNESS: Yes. 24 BY MR. EDWARDS: aS Q. And I believe that you described that some MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page222 of 883 Page 73 1 JOSEPH RECAREY - CONFIDENTIAL 2 of the -- that the house appeared to be -- I don't 3 remember the word you used -- sanitized, for lack of 4 a better word? 5 MR. PAGLIUCA: Object to form and 6 foundation. 7 BY MR. EDWARDS: 8 Ox How did you know that? 9 A. The computers had been removed from the 10 home. Li Q. How did you know the computers were 12 removed? 13 A. Based on -- based on the dangling wires 14 left behind, the monitors left, but the actual CPU 15 of it was missing. 16 When you went into the bedroom of Jeffrey 17 Epstein, everything was removed from the -- the 18 shelves, from the armoire. 19 Q. Did you find nude photographs of girls? 20 A. Yes. 21 Q. All right. 22 And what did you do with that evidence? 23 A. That was collected and placed into our 24 crime scene unit. 2S Q. And where is that evidence today? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page223 of 883 Page 74 1 JOSEPH RECAREY - CONFIDENTIAL 2 A. Any evidence that was not returned to its 3 rightful owner was turned over to the FBI. 4 0. And evidence which would be nude 5 photographs of girls would be evidence not turned 6 back over to Epstein? 7 A. Correct. 8 MR. PAGLIUCA: Object to form and 9 foundation. 10 THE WITNESS: Some of the items that were Li collected were later found to be personal items 12 of the houseman, Janush. I recall reviewing 13 his personal photographs on -- on a micro SD 14 card for, like, photos of him and his wife or 15 girlfriend at the time. 16 BY MR. EDWARDS: 17 Q. And the underaged girls that you had 18 spoken with during your investigation, had they 19 described seeing photographs of naked girls in the 20 house? 21 MR. PAGLIUCA: Object to form and 22 foundation. 23 THE WITNESS: Yes, they did. 24 BY MR. EDWARDS: 25 Os That's something that ran consistent with MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page224 of 883 Page 78 JOSEPH RECAREY - CONFIDENTIAL BY MR. EDWARDS: Q. Okay. Also reflected are the property receipts? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Correct. BY MR. EDWARDS: 0% All right. And where were those taken from, in terms of whose property is that? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: This would have been taken from the home of Jeffrey Epstein. BY MR. EDWARDS: Q. And in reviewing that evidence, were you able to substantiate or corroborate certain victims' accounts of their allegations of having been at the house? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Correct. BY MR. EDWARDS: Os Did you find names of other witnesses and MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page225 of 883 Page 79 1 JOSEPH RECAREY - CONFIDENTIAL 2 people that you knew to have been associated with 3 the house in those message pads? 4 MR. PAGLIUCA: Object to form and 5 foundation. 6 THE WITNESS: Yes. 7 BY MR. EDWARDS: 8 O. And so what was the evidentiary value to 9 you of the message pads collected from Jeffrey 10 Epstein's home in the search warrant? 11 MR. PAGLIUCA: Object to form and 12 foundation. 13 THE WITNESS: It was very important to 14 corroborate what the victims had already told 15 me as to calling in and for work. 16 BY MR. EDWARDS: 17 Q. Okay. And did you learn the identities of 18 some of the other individuals associated with 19 Jeffrey Epstein through the review of that 20 particular evidence? 21 MR. PAGLIUCA: Object to form and 22 foundation. 23 THE WITNESS: Correct. 24 BY MR. EDWARDS: 25 Q. Okay. And what did you do with that MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page226 of 883 Page 83 1 JOSEPH RECAREY - CONFIDENTIAL 2 BY MR. EDWARDS: 3 Q. In these messages, did you see messages 4 that were taken by Ghislane Maxwell or left for 5 Ghislane Maxwell? 6 MR. PAGLIUCA: Object to form and 7 foundation. 8 THE WITNESS: I do recall seeing messages 9 utilizing her pad, her stationery. 10 BY MR. EDWARDS: 11 Q. Okay. Do you remember messages 12 specifically that Ms. Maxwell, she is home, or calls 13 for Ms. Maxwell, or indicating that the person 14 taking the message is GM? Do you remember those? 15 A. Yes. 16 MR. PAGLIUCA: Object to form and 17 foundation. 18 BY MR. EDWARDS: 19 Q. And did that give you further reason to 20 want to speak to Ghislane Maxwell? 21 MR. PAGLIUCA: Object to form and 22 foundation. 23 THE WITNESS: Correct. I wanted to speak 24 with everyone in the home and everyone 25 associated with Jeffrey Epstein. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page227 of 883 NB Page 97 JOSEPH RECAREY - CONFIDENTIAL anything that's found that has any kind of identifiers, any kind of names, phone numbers, anything that could be used to identify further victims and/or to corroborate what the information we already obtained, that information would be kept. Ors Okay. A. Be followed up on. Ox You testified earlier about certain pieces of paper that had Ghislane Maxwell's name on it that were obtained. Are the documents that are listed, the first one, two, three, four pages of Exhibit 8, some of the documents that you're referring to? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: That is correct. BY MR. EDWARDS: Q. And if we go through this stack of documents, if you could just review them and tell me if these are some of the items obtained through the trash pulls at Jeffrey Epstein's home? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: That is correct. This is -MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page228 of 883 Page 98 1 JOSEPH RECAREY - CONFIDENTIAL 2 these items were collected in the trash pull. 3 BY MR. EDWARDS: 4 Q. Okay. And these are items that you felt 5 had some evidentiary value? 6 MR. PAGLIUCA: Object to form and 7 foundation. 8 THE WITNESS: Yes. 5 BY MR. EDWARDS: 10 Q. Were there other items within the trash 11 that were discarded as not having any apparent 12 evidentiary value? 13 A. Correct. There was stuff like food trash 14 we're not going to keep. You know, an apple core. 15 None of that's going to be kept. 16 Q. Okay. And when you took this stuff into 17 evidence, how was it maintained? 18 A. It was placed in a -- in a sealed 19 container, a sealed Ziploc, and placed into 20 evidence. 21 Os And then was that file later transferred 22 to the State Attorney's Office or the FBI? 23 MR. PAGLIUCA: Object to form and 24 foundation. 25 THE WITNESS: It was collected by the FBI. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page229 of 883 Page 366 3 CRRT? EE ICA TE 4 STATE OF FLORIDA ) ss 5 COUNTY OF MIAMI-DADE ) 6 I, KELLI ANN WILLIS, a Registered 7 Professional, Certified Realtime Reporter and 8 Notary Public within and for The State of 9 Florida, do hereby certify: 10 That JOSEPH RECAREY, the witness whose 11 deposition is hereinbefore set forth was duly 12 sworn by me and that such Deposition is a true 13 record of the testimony given by the witness. 14 I further certify that I am not related 15 to any of the parties to this action by blood 16 or marriage, and that I am in no way interested 17 in the outcome of this matter. 18 IN WITNESS WHEREOF, I have hereunto set 1:9 my hand this 24th day of June, 2016. 20 21 KELLI ANN WILLIS, RPR, CRR 22 23 24 25) MAGNA® LEGAL SERVICES

EXHIBIT 14 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page231 of 883 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Sh Gee ces Shee A. See. oie, Ge ee ee en ee fee VIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against-— 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. ** CONFIDENTIAL** Videotaped deposition of RINALDO RIZZO, taken pursuant to subpoena, was held at the law offices of Boies Schiller & Flexner, 333 Main Street, Armonk, New York, commencing June 10, 2016, 10:06 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page232 of 883 Page 25 fl R. Rizzo - Confidential 2 even Nadia. And what I found very repulsive, 3 out of the ordinary, was Nadia was wearing a 4 swimsuit that was very revealing and 3 basically, her bottom basically went up her 6 butt, revealing all of her buttocks. So i again, in the context not very appropriate 8 for the situation. 9 O's Could you tell the relationship of 10 age between the three girls that you have 11 described and Nadia, for instance? 12 MR. PAGLIUCA: Object to the form 13 and foundation. 14 A. Nadia seemed to be a bit older, I 15 would say. 16 Q. How does this end, or is there, 17 what do you do next? How does this meeting 18 that you've just described break up? 19 A. I asked to excuse myself and asked 20 where the bathroom was, so I'm pointed inside 21 the house, to go inside the house to the 22 bathroom. 23 I walk in there, and I walk, as I'm 24 walking to the bathroom, what caught my eye, 25) and I had to take a double lock, there were MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page233 of 883 Page 26 el R. Rizzo - Confidential 2 pictures of naked women, half-dressed girls. 3 So I went to the bathroom, again, from 4 someone, myself working in private service, I 3 always know in houses there are cameras, so 6 again, I was very reluctant to stare, because a you never know when you are on camera. 8 So I used the bathroom, and I came 9 out, and you know, curiosity got the best of 10 me, and I leaned over and started looking at 11 these pictures for a brief minute, and it was 12 just so coincidental that as I did that, Ms. 13 Maxwell enters, and she immediately says to 14 me that Jeffrey would like for me to rejoin 15 the party immediately. 16 Or. How many pictures of nude females AT did you see in Jeffrey Epstein's home? 18 MR. PAGLIUCA: Object to the form 19 and foundation. 20 Ay I can't recall the exact number. 21 Oi Can you describe the pictures that 22 you saw in terms of what the people, what the 23 people or person within the picture was 24 wearing, what the age range would be of the 25 person that's in the photograph, any poses, MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page234 of 883 Page 52 el R. Rizzo - Confidential 2 Oy Did you learn whether your 3 perception was correct? 4 MR. PAGLIUCA: Same objection. D A. It was younger. Yes; I «did: 6 Or. How old was this girl? 7 A. 15 years old. 8 Q. What happens next when Ghislaine 9 Maxwell and Jeffrey Epstein and a 15-year-old 10 girl walk into Eva Anderson's home? 1 MR. PAGLIUCA: Object to the form. 12 Foundation. 13 A. They proceed into the dining room 14 area, which is across from the living room 15 area. I go into the kitchen and I hear a 16 conversation start. Very muffled, I could 17 not hear any particulars about the 18 conversation whatsoever. 19 My wife and I are in the kitchen 20 preparing the evening meal. Eva brings the 21 young girl into the kitchen. In the kitchen, 22 there is an island with three barstools. Eva 23 instructs the young girl to sit to the 24 furthest barstool on the right. 25 ‘Oo. Describe for me what the girl MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page235 of 883 Page 53 ‘lt R. Rizzo - Confidential 2 looked like, including her demeanor and 3 anything else you remember about her when she 4 walks into the kitchen. 3 A. Very attractive, beautiful young 6 girl. Makeup, very put together, casual 7 dress. But she seemed to be upset, maybe 8 distraught, and she was shaking, and as she 9 sat down, she sat down and sat in the stool 10 exactly the way the girls that I mentioned to 1 you sat at Jeffrey's house, with no 12 expression and with their head down. But we 13 could tell that she was very nervous. 14 Q. What do you mean by distraught and 15 shaking, what do you mean by that? 16 A. Shaking, I mean literally 17 quivering. 18 Or What happens next? 19 A. We were, again, the absurdity, 20 never introduced. Like you would walk into a 21 room and say this is -- so my wife and I are 22 in the kitchen and this young girl is sitting 23 there. It was a very uncomfortable moment. 24 I look at my wife. And so I want to ease the 25 moment, and so I introduced myself and I MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page236 of 883 Page 54 el R. Rizzo - Confidential 2 introduced my wife, and she doesn't really 3 respond. 4 And I asked her, are you okay? And 3 she doesn't really respond. Nothing verbal, 6 no cues, her head is still down. I ask her 7 if she would like some water, tissue, 8 anything, and she basically doesn't respond. 9 Ors You ask her for a tissue? 10 A. If she would like a tissue or some 1. water at the time. 12 Q. Was she crying at the time? 13 A. My perception, she was on the verge 14 of crying. And I'm trying to loosen the 15 situation every way I know how, so the only 16 way I knew how, and I thought maybe this will 17 comfort her, I said oh, by the way, do you 18 work for Jeffrey. 19 And she says that, I guess kind of 20 made her feel comfortable, because maybe it 21 was that comment or my persistence, and she 22 said yes. So I said, what do you do? And 23 she says I'm Jeffrey's executive assistant, 24 personal assistant. Which, from looking at 25 her, just didn't seem to suit. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page237 of 883 Page 55 el R. Rizzo - Confidential 2 And I blurted out: You're his 3 executive personal assistant? What do you 4 do? And she says I was hired as his 3 executive personal assistant. I schedule his 6 appointments. 7 And I'm shocked, and I blurt out: 8 You seem quite young, how did you get a job? 9 How old are you? And she says to me, point 10 blank: I'm 15 years old. 11 And I said to her: You're 15 years 12 old and you have a position like that? At 13 that point she just breaks down hysterically, 14 so I feel like I just said something wrong, 15 and she will not stop crying. My wife and I 16 were at a loss for words, and I keep on 17 trying to console her, and nothing I was 18 saying, are you all right, do you needa 19 tissue, do you need water, consoles her. 20 And then in a state of shock, she 21. just lets it rip, and what she told me was 22 just unbelievable. 23 QO. What did she say? 24 MR. PAGLIUCA: Object to the form 25 and foundation. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page238 of 883 Page 56 el R. Rizzo - Confidential 2 A. She proceeds to tell my wife and I 3 that, and this is not -- this is blurting 4 out, not a conversation like I'm having a 3 casual conversation. That quickly, I was on 6 an island, I was on the island and there was a Ghislaine, there was Sarah, she said they 8 asked me for sex, I said no. 9 And she is just rambling, and I'm 10 like what, and she said -- I asked her, I 1: said what? And she says yes, I was on the 12 island, I don't know how I got from the 13 island to here. Last afternoon or in the 14 afternoon I was on the island and now I'm 15 here. And I said do you have a -- this is 16 not making any sense to me, and I said this 17 is nuts, do you have a passport, do you have 18 a phone? 19 And she says no, and she says 20 Ghislaine took my passport. And I said what, 21 and she says Sarah took her passport and her 22 phone and gave it to Ghislaine Maxwell, and 23 at that point she said that she was 24 threatened. And I said threatened, she says 25) yes, I was threatened by Ghislaine not to MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page239 of 883 Page 57 ‘lt R. Rizzo - Confidential 2 discuss this. 3 And I'm just shocked. So the 4 conversation, and she is just rambling on and D on, again, like I said, how she got here, she 6 doesn't know how she got here. Again, I ah asked her, did you contact your parents and 8 she says no. 9 At that point, she says I'm not 10 supposed to talk about this. I said, but I 1 said: How did you get here. I don't 12 understand. We were totally lost for words. 13 And she said that before she got 14 there, she was threatened again by Jeffrey 15 and Ghislaine not to talk about what I had 16 mentioned earlier, about -- again, the word 1.7 she used was sex. 18 Or And during this time that you're 19 saying she is rambling, is her demeanor 20 continues to be what you described it? 21 A. Yes. 22 Ox Was she in fear? 23 A. Yes. 24 MR. PAGLIUCA: Object to the form 25 and foundation. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page240 of 883 Page 58 el R. Rizzo - Confidential 2 Oz. You could tell? 3 A. Yes. 4 MR. PAGLIUCA: Same objection. D A. She was shaking uncontrollably. 6 Ors, What happens with this 15-year-old q girl next? 8 MR. PAGLIUCA: Object to the form 9 and foundation. 10 A. As she is trying to explain, and 1 I'm asking questions because I'm as feared as 12 she is at this point. We hear people 13 approach and she just shuts up. 14 Oy. What happens next? 15 A. Eva comes in and tells her that she 16 will be working for Eva in the city. ae]: Oe As what? 18 A As a nanny. 19 Q Did you see this girl again? 20 A. Yes. Al Q And when? 22 A On a flight maybe a month or so to 23 Sweden. 24 O% What was the purpose of the flight? 25) A. We were going to Sweden for the MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page241 of 883 Page 59 1 R. Rizzo - Confidential 2 summer. 3 Os, Who was on the flight? 4 A. The Dubin family. 5 Ov As well as this girl? 6 A. Yes. 7 Ow What happens? 8 A. One thing that I forgot to mention 9 is during our initial conversation, I asked 10 her what her name was JM she said her name se 12 Q: What happened with x? 13 A. We flew to Sweden, we stopped at an 14 airport that we didn't usually stop at and 15 she got off the plane. 16 Q. Just so that I make sure I 17 understand, who it was that she says asked 18 her for sex on the island, who was that? 19 MR. PAGLIUCA: Object to the form. 20 Foundation. 21 A. She didn't specify who asked for 22 sex. She said that they asked for sex. 23 Immediately after that she put Ghislaine and 24 Sarah into the conversation. 25) Q. Taking her passport? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page242 of 883 Page 60 el R. Rizzo - Confidential 2 A. Yes. 3 Om From -- are there any other 4 incidents or occurrences that you observed 3 personally with Jeffrey Epstein and Ghislaine 6 Maxwell? e MR. PAGLIUCA: Object to the form 8 and foundation. 9 A. Not that I can recall. 10 Or. This last event that you described, A what's the timeframe when that occurred? 12 A. Late 2004, 2005. 13 Q. When did you resign your employment 14 from the Dubin family? 15 A. I think roughly October. 16 Or Of what year? 17 A. 2005. 18 Q. Why? 19 A. My wife and I had discussed these 20 incidents, and this last one was just, we 21: couldn't deal with it. 22 Q. When you left your employment with 23 the Dubin family, did you have a job? 24 A. When we finally left, I stayed on 25 three months after my resignation, I had a MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page243 of 883 12 13 14 Eo 16 17 18 19 20 21 22 23 24 25 Page 141 CERTIFICATE I HEREBY CERTIFY that RINALDO RIZZO, was duly sworn by me and that the deposition is a true record of the testimony given by the witness. Liéslie agin, Registered Professional Reporter Dated: June 10, 2016 (The foregoing this transcript does not reproduction of the same under the direct control certification of apply to any by any means, unless and/or supervision of the certifying reporter.) MAGNA® LEGAL SERVICES

EXHIBIT 15 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page245 of 883 Confidential Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. June 3, 2016 9:07 a.m, CcCONFIODENTIATL Deposition of DAVID RODGERS, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page246 of 883 Confidential Page 18 DAVID RODGERS flyer person, then you would reduce it to an initial? MR. PAGLIUCA: Object to form and foundation. MR. REINHART: You can answer the question. You can answer the question, if you can answer the question. You are allowed to answer the question, if you understand the question. BY MR. EDWARDS: Q. I'm trying to understand your testimony. Is it, if you came to know that person -A. Uh-huh. Q. -- as a frequent flyer passenger, you "Ss name to an would begin to reduce that person initial at some point? MR. PAGLIUCA: Same objection. THE WITNESS: Well, we don't really have a frequent flyer program that we do, so to speak. A lot of times I would do it because if you would write out everybody's name there is not enough space, you know, to get everybody's name in that little square there. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page247 of 883 Confidential Page 34 DAVID RODGERS Q. -- is that right? And is that -- is Ghislaine Maxwell somebody that through the years 1995 through 2013 was somebody who flew very frequently? A. What were the years again? Q. The years of this book, 1995 -A. I wouldn't say through 2013. But, yes, 95 through 2000 sometime. Probably, I would have to go back and -- well, you can see in there. Q. We will get to it. A. There will be a point where you don't see her much. But to say it went through 2013 would not be accurate. Q. Let's do it this way: The person that you have reflected on numerous notations -Ae Yes, Q. -- through here as GM -A. ¥es. Q. -- just by the initials, are we able to safely know that that is Ghislaine Maxwell? Ae Yes, MR. PAGLIUCA: Object to form and foundation. MR. EDWARDS: Court reporter, did you get MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page248 of 883 Confidential Page 35 DAVID RODGERS the answer? THE REPORTER: Yes. The answer came before the objection. BY MR. EDWARDS: Cs So on the next flight, the next day, from Palm Beach to SAF. Is SAF Santa Fe? A. Yes. Cs, And it indicates JE and GM. Are we able to then know that those passengers on that flight were Jeffrey Epstein and Ghislaine Maxwell? A. Yes, MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: QO. And where would you land at SAF? Is that an airport? A. It is an airport. Q. Is it a private airport? A. No. It's -- airlines go in there. Oe Did Jeffrey Epstein also have a landing strip at his property in New Mexico? A. He did at one time. Gy What would that -- do you remember what MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page249 of 883 Confidential Page 36 DAVID RODGERS that code would be? A. I don't believe there was a code. Q. All right. Were there times that you landed either the Gulfstream or the Boeing -A. No. Q. No. MR. REINHART: Let him finish the question before you answer. THE WITNESS: Oh, I'm sorry. BY MR. EDWARDS: Q. Sure. We are doing fine so far. But the court reporter is taking down all of our questions and all of our answers. We are communicating well. A. Okay. Q. But when I go to read this back, we may not get that. A. Okay. Go ahead. Q. So were there times where you landed one of Jeffrey Epstein's planes on his private landing strip at the New Mexico property? Ae Yes, But not the Gulfstream and not the Boeing. Q. What plane did you land on his property? A. The Cessna 421. And probably a MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page250 of 883 Confidential Page 96 DAVID RODGERS 9:00, so it is 20 to 11:00 here. BY MR. EDWARDS: Q. So I want to go to page 41, and down to December 9th. Sorry. December 11. A. Okay. Q. Palm Beach to Teterboro. A. Yeah. Q. And who are the passengers? A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Virginia. Q. And this appears to be the first time that Virginia's name appears in the log? A. Right. Q. Is there a -- is there a reason why the first time -- I notice that the first time on some of the other passengers, you use a first and last name. Is there any reason why you didn't use her first and last name? A. I probably didn't know her last name. Q. Just didn't catch it. A. Yes. Q. Okay. It was not that somebody told you not to use the last name? MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page251 of 883 Confidential Page 97 DAVID RODGERS Q. So that flight goes from Palm Beach to Teterboro. Can you remember whether that's the first time that you flew on a plane with Virginia Roberts? MR. PAGLIUCA: Object to -THE WITNESS: I believe it is. MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: Q. Do you remember the flight? Aye No. Q. The next flight three days later goes from Teterboro to Virgin Islands with Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, and Virginia; is that right? A. Yes. Q. And below that, it says, "Reposition." What does that mean? A. We were taking the airplane with no passengers to go into maintenance, or an OPS2 inspection. Q. Okay. This is -- this is the same Gulfstream, is that right? As Yes. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page252 of 883 Confidential Page 98 DAVID RODGERS Q. How many passengers would that Gulfstream allow? A. Twelve passengers, I believe. Q. And do you know how Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, and Virginia get off of St. Thomas or leave the island? Re No. I do not. Probably a charter, I'm guessing. Q. If -- who would fly the -- well, is there any other plane that Jeffrey Epstein was able to access back then that was a private plane? MR. PAGLIUCA: Object to foundation. THE WITNESS: No. At that point in time we don't have the Boeing yet. BY MR. EDWARDS: Q. So how many airplanes did Jeffrey Epstein back then? A. Well, we -- I don't know if we had the 421 then. We may or may not have. But it wouldn't -you know, you wouldn't be flying the 421 down to St. Thomas with Jeffrey. It is too long of a flight. Q. The Cessna? A. The Cessna 421, correct. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page253 of 883 Confidential Page 99 DAVID RODGERS Q. Okay. A. But I'm not even sure we still had it at this point in time. Q. Yeah. It shows up on the next page. We will get there. A. Does it? Okay. So then, yes, the answer is, yeah, we still had the airplane. But we wouldn't have used that. Q. So is there any way of telling how Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, and Virginia were in the Virgin Islands on that, from December 14th, 2000 -MR. PAGLIUCA: Object to foundation. BY MR. EDWARDS: Q. -- based on your knowledge or your logs or anything else? A. No, I wouldn't have any way of knowing. Q. Okay. A. Because the next flight that they are on was like this Palm Beach one, January 16th. So I wouldn't have any idea. Q. Okay. To your knowledge, did Jeffrey Epstein ever fly commercially? MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page254 of 883 Confidential Page 100 DAVID RODGERS A. He probably has. Back then at this time, I'm going to say probably not. But I know that he has flown commercially. But usually that would be like going to Europe, maybe. Q. Okay. January 16th through the 25th, those flights, do you see that block that I'm talking about? Re ¥es,. Q. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and then at times Shelly Lewis, do you see that? A. Yes, right. Q. The 25th it lands in Teterboro. And the next day, on the 26th, leaves out of Teterboro with Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts. This time you wrote the whole name. A. Right. Right. Q. So when you write the full name, does that signify -- that's when you may have learned her last name? A. Correct. Q. And do you know how she -- how she got up to New Jersey or New York? MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page255 of 883 Confidential Page 101 DAVID RODGERS A. I do not. I would guess the airlines. Ss. At this point in time, did you know what her -- what her relationship was with Jeffrey Epstein or Ghislaine Maxwell? MR. PAGLIUCA: Object to form. THE WITNESS: No. BY MR. EDWARDS: ie. Did you -- was she a masseuse? MR. PAGLIUCA: Object to foundation. THE WITNESS: I -- I'm not sure what she was. BY MR. EDWARDS: Q. Did you form any -- any belief that she was a friend or a business associate or anything? MR. PAGLIUCA: Object to foundation. THE WITNESS: Well, I mean, we had a lot of people on the airplane. And Virginia was just another one of those passengers. BY MR. EDWARDS: O.» Okay. So on the 26th, flies to Palm Beach. And then -- and then I guess the 27th -A. Right. is -- leaves from Palm Beach to the Virgin Islands - MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page256 of 883 Confidential Page 102 DAVID RODGERS Pex ¥es Q. -- with Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts, right? A. Yes Q. And on the 30th, you fly it back. That's still the Gulfstream, right? Re Yes Q. From the Virgin Islands to Palm Beach with the same four passengers, correct? Ae Yes, Q. And that's Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts? A. Cerrece .. Q. And then what happens to that plane, the Gulfstream, for the next month, from February lst through March 5th? A. Well, I don't know what happened to it, but I'm -- from, looks like February 17th, I'm going to school to get a type rating on the Boeing. And I'm gone for about three weeks. Q. So this is when you' re doing a simulator on the Boeing? A. Correce . Q. And getting your certification to fly the MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page257 of 883 Confidential Page 103 DAVID RODGERS Boeing? A. Yes. Q. The Boeing, was that previously owned by The Limited or Les Wexner? A. I'm not sure of the company name, officially. But probably, yes. Q. Some association with him? A. Some association, yes. Q. Do you know who flew the Gulfstream while you were doing the simulator? A. Well, it would have been Larry Visoski, I'm not sure who the first officer was. Q. Do you know if any logs were kept of the passengers' names? A. While I was at school? Q. Right, while you were at school A. There probably were logs, but I don't know where they are. Q. Have you ever spoken with Larry about whether he kept names of passengers? A. I don't think he does. Q. Do you know where Larry Visoski flew the Gulfstream for the month that you were -As No. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page258 of 883 Confidential Page 104 DAVID RODGERS Q. Sorry. Just let me finish my question. I know I was getting it out slow. -- but for the month that you were training on the Boeing? A. No. Q. All right. So the last flight that you took in the Gulfstream before you began, before you flew the Cessna for a day, I guess, right, from Santa Fe to DFW -A. Right. Q. -- February 3rd -A. Yes. Q. And that's the Cessna with 908GM tail Ae Yes, Q. The last flight that you flew on the Gulfstream was the flight back from St. Thomas with Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts, right? A. Uh-huh. Q. And then the next time that you're on the plane is -- on the Gulfstream is when? A. It looks like March the 5th. Q. And who are the passengers on that flight? MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page259 of 883 Confidential Page 105 1 DAVID RODGERS 2 Where is it going to? 3 A. Jeffrey Epstein, Ghislaine Maxwell, Emmy 4 Tayler, Virginia Roberts. 5 Q. And then there's notation of Gary 6 Roxborough? 7 A. Yes. 8 Q. Do you know why that is? 9 A. Yeah. He was the first officer. 10 Q. Why did he become the first officer? 11 A. Because Larry was probably in training for 12 the Boeing. 13 Q. Okay. You took -- you alternated? 14 A. Right. We didn't go at the same time. 15 Q. All right. Then the Gulfstream has the 16 same aircraft make and model. That's the same 17 Gulfstream airplane, right? 18 A. Yes. 19 Q. But the aircraft identification mark 20 changes -21 A. Correct. 22 Q. -- on March 5th, 2001. 23 A. Correct. 24 Q. And it changes to N -- it changes from 25 N908JE to N9D9JE. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page260 of 883 Confidential Page 106 DAVID RODGERS A. Yes. Q. Why was that? A. Because the N908JE went to the Boeing. That was going to be on the Boeing now. Q. And the new number for N909JE was transferred to the Gulfstream? A. Correct. Q. And where does that first flight on the 5th go? A. From Palm Beach to Stephenville up in Newfoundland for a fuel stop. Q. Okay. And then how do you know it is a fuel stop? A. Because we are going to Paris, and so we have to stop there for fuel Q. Okay. I know how -- I know how you would know that. But is there any indication on any of the numbers that go off to the right that would tell me that it's a fuel stop as opposed to -Ae No. Q. No? Okay. All right. So there's no way after today's deposition I can look at any of the numbers; it's not going to tell me what it was for? A. No. No. And it's -- obviously it looks MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page261 of 883 Confidential Page 107 DAVID RODGERS different, because one day is the 5th; one day is the 6th. But we landed there like at 11:50 at night. And then when we took off, it was, you know the next day. Q. Okay. Got it. And then where do you go the next day? A. We went from Stephenville to Paris-Le Bourget. Q. And who were the passengers going to Paris? A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts Q. And then what's the next flight? A. On the 8th, from Paris to -- I believe that is in Spain. Q. Granada, Spain? A. Granada, Spain. Correct. Q. Okay. And who are the passengers on that trip? A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Virginia Roberts, Alberto and Linda Pinto, one female, and Ricardo, it looks like Orieta. Q. And then what's the next flight? As From there to Tangiers. From Granada to MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page262 of 883 Confidential Page 108 1 DAVID RODGERS 2 Tangiers. 3 Q. When you landed -- sorry to go back -4 when you landed in -- what did we say LEGR was? 5 A. Granada, Spain. 6 Q. Where did -- where did you stay? Where do 7 you stay on those trips? 8 A. We didn't stay. We left the same day, I 9 believe 10 Q. Okay. What if we go back to one flight to 11 LFPB? 12 A. Uh-huh. LFPB. 13 Q. That's Paris? 14 A. Yeah. We stayed in Paris. 15 Q. And do -16 A. We stayed there. 17 Q. Do you know -- do you stay at the same 18 location where Jeffrey Epstein, Ghislaine Maxwell, 19 Emmy Tayler, and Virginia Roberts stay? 20 A. No. 21 Q. Where do you stay while you are in Paris? 22 A. Hotel. 23 Q. Where do they say? 24 MR. PAGLIUCA: Object to foundation. 25 THE WITNESS: He has a place there, in MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page263 of 883 Confidential Page 109 DAVID RODGERS Paris. BY MR. EDWARDS: Q. Okay. Jeffrey Epstein has a home or a house in Paris? A. Right. Q. Okay. Have you been to it? A. Yes, I believe I have. Q. Have you ever stayed there? A. No. Q. And getting to and from the airport, were you ever in the car riding to or from the airport in Paris with Jeffrey Epstein? A. No. Q. So going down to the 9th, then, where is that flight? A. That is from Tangiers to London Luton Airport. Q. And is Luton Airport, is that a major airport? A. For general aviation it is. There is airline service in there, but it is not a huge one, for sure. Q. Who were the passengers? A. Jeffrey Epstein, Ghislaine Maxwell, Emmy MAGNA®© LEGAL SERVICES

10 11 12 13 14 15 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page264 of 883 Confidential Page 110 DAVID RODGERS Tayler, and Virginia Roberts. Q. And am I reading this correctly that the next flight is two days later, on the 11th? what Jeffrey Epstein, Res Yes Q. And where does the flight on the llth go? Pex From Luton to Bangor, Maine. Q. All right. While in London, do you know Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts did? A. No, I do not. Q. Do you know who they saw? A. No, I do not. Q. After the flight to Maine, where is the next flight? day. A. Maine is from Q. Okay. A. So that was a MR. EDWARDS: time to stop. The tapes. THE WITNESS: MR. EDWARDS: five-minute break. Bangor to Teterboro the same fuel stop. All right. We are at a good videographer has to change Okay. So we why don't we take a MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page265 of 883 Confidential Page 111 DAVID RODGERS THE WITNESS: Okay. THE VIDEOGRAPHER: Off the record at 120 SF (Thereupon, a recess was taken, after which the following proceedings were held:) THE VIDEOGRAPHER: This is the beginning of Disk 2. On the record at 11:12. BY MR. EDWARDS: Q. Sure. If we go back to page 41, December 7th, 2000. MR. PAGLIUCA: Give us a Bates page, please. MR. EDWARDS: Right, 41. For the remainder, when I say "page," I'm really just referring to the Bates number. BY MR. EDWARDS: Q. So page 41, December 7th, 2000. A. Okay. es Do you see that? Where was that flight going from and to? A. Luton to -- Luton -- that's going into Marham Air Force Base. Q. Do you remember why you would have flown into the Air Force base? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page266 of 883 Confidential Page 112 DAVID RODGERS A. We flew in there to drop the passengers off. And then these passengers that were on there we dropped them off. And then -- let's see. We repositioned. I don't remember. We dropped passengers off, and we had to leave, I believe. Q. Okay. That was -A. We weren't allowed to stay there. Q. That was Tom Pritzker? A. Yes. Q. And then did you also drop off Jeffrey Epstein, Ghislaine Maxwell, Kelly Spamm? A. Yes. Q. Okay. A. I believe everyone got off the airplane there Q. And where did you reposition to? A. It says, "Positioned in Norwich, England." I guess it's Norwich. Q. Sandringham, that is what it says right above that. What is that? A. Sandringham. I believe Sandringham is the estate that the queen has -Q. Okay. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page267 of 883 Confidential Page 113 1 DAVID RODGERS 2 A. -- near there. 3 Q. All right. And the flight on 4 December 9th -5 A. Uh-huh. 6 o. That's Jeffrey Epstein, Ghislaine Maxwell, 7 Emmy Tayler, Kelly Spamm? 8 A. Right. 9 Q. And then what did you write in the 10 parenthesis under that? 11 A. "Blowing snow on runway." It was a great 12 weird phenomenon that happened that night. 13 Q. And then you're leaving out of that 14. Sandringham Airport; is that right? 15 A. We are -- which one are you on? 16 Q. On the 9th. 17 A. On the 9th -18 Q. The first entry on the 9th. 19 A. The 9th, we're leaving, looks like 20 Norwich, England, I believe, EGSH, and we go to 21 Gander, Newfoundland -22 Q. Okay? 23 A. -- for a fuel stop. 24 Q. I think before we took a break that we 25 were on page 43. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page268 of 883 Confidential Page 114 DAVID RODGERS A. Uh-huh, hs And the flight that began in Palm Beach, before going to Paris and Belgium, Tangier, I think you told me, it ended up in Maine -A. Correct. Qs. -- on March 11th, 2001. A. Right. Os Or, sorry, it ended up in Teterboro. A. Teterboro, Q. Okay. And then on the 15th, you fly from -- on the Gulfstream out of Teterboro to ISP. Do you know where that is? A. Islip, New York. Q. Okay. And Virginia Roberts was on the flight that landed in Teterboro on the 11th, correct? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Yes. BY MR. EDWARDS: Gre But leaving out of Teterboro, she's not one of the passengers on the flight. A. No. Gy Any idea where she went? MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page269 of 883 Confidential Page 115 DAVID RODGERS A. No. Q. Okay. MR. PAGLIUCA: Are you referring to Bates 0041, the 11th through 14th? Is that what you're talking about? MR. EDWARDS: Forty-three. MR. PAGLIUCA: Forty-three. MR. EDWARDS: March 11th and March 15th, 2001. MR. REINHART: If it will help there, the flight numbers column, like the fifth or sixth column over, are sequentially numbered and unique numbers. So if you want to just say "flight 1468" -MR. EDWARDS: Okay. MR. REINHART: -- that might help everybody -MR. EDWARDS: Right. MR. REINHART: -- follow along. MR. EDWARDS: Okay. Thanks, Bruce. MR. REINHART: Uh-huh. BY MR. EDWARDS: Q. So the flight now that I'm talking about that leaves out of Teterboro on the 15th, flight MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page270 of 883 Confidential Page 116 DAVID RODGERS No. 1471 -A. Right. Q. -- the passengers appear to be Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, Alexia Wallert and Banu Cukuglu? A. I think so. Q. Do you remember Banu? A. I definitely remember that. It was a hard name to spell. Yeah. Sort of, I guess. I mean, if she walked in right now, I probably wouldn't recognize her. Q. Well, it has been since 2001, so -A. Yeah, I know. Q. Okay. So then the next flight is 1472. Where is that? Where is that going? A. From Islip to Lake City, Florida. Q. All right. And the passengers, again, are who? A. Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, Alexia Wallert and Banu Cukuglu, whatever her name is Q. Did you know what relationship she had, if at all, with Jeffrey Epstein? MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page271 of 883 Confidential Page 117 DAVID RODGERS A. No. No. Q. Do you remember an Ed Tuttle? A. Yes. Q. And who was he? A. I believe Ed was a, probably in construction. I think he may have been around before the Jeffrey -- well, let me think. Q. If we skip down to March 16th, I see his name. So I don't know if that's going to help you. A. I believe -- I believe Ed Tuttle was like maybe an architect, or somewhere in the construction, real estate side, I believe. Q. Okay. So flight No. 1477 -A. Uh-huh. Q. -- from LaGuardia to Palm Beach, is that Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Joe Pagano, Eva Dubin? A. Yes. Q. Celina Dubin? A. Yes. Q. Jordan Dubin? A. Right. Q. Maya Dubin and two nannies? A. Yes. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page272 of 883 Confidential Page 118 DAVID RODGERS Q. And Alexia Wallert? Is that what that is? A. I would assume so, yes, AW. Q. That is sort of what we talked about in the beginning, where Alexia Wallert appears in full name at the top -A. Right. Q. -- and it's AW, AW, AW. A. And there's no room to write her name out there -Q. Right. A. -- so she's AW. Q. Okay. And then the next flight, the 27th leaves out of Palm Beach. Who are our passengers on that flight and where's it going? 1478 is the flight. A. Yeah. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Virginia Roberts, two females, Banu, and that's it. Q. And do you know, in New York, when that plane lands in Teterboro, where do you stay when the plane is up there? Pie It is 2001. At an apartment there. Q. Did you have your own apartment? As Yes. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page273 of 883 Confidential Page 119 DAVID RODGERS Q. Or did you stay at one of Jeffrey Epstein's apartments? A. No. It was his apartment, Jeffrey's apartment. Q. Was that one of the apartments at 301 East 66th Street? A. Yes. Q. And did any of the other passengers from that flight, that 1478, did any of them stay at any of those apartments? A. Yeah. Emmy would have. Virginia probably did. Q. Did you see Virginia stay at the apartment? Ay I don't know. Q. When you were in New York and you left from the airport, did you ride in the same car with Virginia? A. Not usually. I mean, I don't know if we ever did. It's possible we did Q. Do you know whether Virginia Roberts "s townhouse or whether stayed at Jeffrey Epstein Virginia Roberts stayed at the apartments? MR. PAGLIUCA: Object to form. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page274 of 883 Confidential Page 120 DAVID RODGERS THE WITNESS: I don't know for sure. BY MR. EDWARDS ‘Os Can you recollect riding in a car with her, or can you recollect whether she got in a car with anyone else? MR. PAGLIUCA: Object to form. THE WITNESS: LE Gan t.5. MR. EDWARDS: Okay. MR. REINHART: Tm sorry. Are you asking about that specific trip or -MR. EDWARDS: Sorry. BY MR. EDWARDS: Q. I mean that specific trip. A. No. I can't. Q. How about in general at any time? A. No. I don't recall. I mean, I can recall, I would ride sometimes with Emmy, with Adam I remember them being in the car. But, again, that was unusual. Usually it would just be Larry and myself. But on occasion, you know, somebody might ride with us. Os When you would stay at the apartment in New York on East 66th Street, would it always be in MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page275 of 883 Confidential Page 121 DAVID RODGERS the same apartment? A. Yes. Q. All right. There are multiple apartments owned by Jeffrey Epstein? A. At that time, it was the same apartment. Q. Okay. Have you stayed in other apartments since that time? A. Yes. Q. All at that East 66th Street location? A. Yes. I really don't -- I don't have an apartment there now. We haven't gone there since probably 2008. Q. How about Banu? Would she have stayed at 301 East 66th Street? MR. PAGLIUCA: Object to foundation. THE WITNESS: Most likely. BY MR. EDWARDS Q. Why do you say that? A. Well, if she's on the plane with us on multiple trips, then most likely she probably stayed there. Q. Have you been to Jeffrey Epstein's townhouse as 9 East 71st Street? As Yes. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page276 of 883 Confidential Page 122 DAVID RODGERS Q. And it's a pretty big place, right? A. Pretty big. Q. And it has numerous bedrooms? A. Yes. Q. Any reason why Banu would not have been staying there? MR. PAGLIUCA: Object to foundation THE WITNESS: I don't know. BY MR. EDWARDS Q. I'm just trying to get to, is there a reason why you believe that Banu would have, I think you said, probably have stayed at the apartment versus the townhouse? A. Well, I only say that because Emmy, you know, stayed there. Q. Stayed where? A. At the -- at our apartments. Q. Okay. A. I'm pretty sure Adam, yeah, Adam stayed there at the time. So most of the people that were regulars on the flight, they would stay there in the apartments. Q. Okay. But do you remember Virginia or Banu staying in the apartments? MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page277 of 883 Confidential Page 123 DAVID RODGERS A. I do not specifically. Q. Okay. The next flight on the next day, 1479, is flying from Teterboro to Santa Fe; is that right? Ree Yes Q. And who are those passengers? A. Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, Virginia Roberts, Banu, Marvin Minsky, Henry Jarecki. Q. Do you remember Marvin and Henry? A. I remember Henry. I don't really remember Marvin. Q. Okay. And then two days later -- again, where would you have stayed if you landed in Santa Fe on March 29th, 2001? A. Probably would have stayed at the ranch. Q. At the Zorro Ranch? A. Yes, Q. All right. Did the other passengers that were on the plane, Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, Virginia Roberts, Banu -I'm not evening going to try her last name -A. Right. Q. -- Marvin Minsky and Henry Jarecki also MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page278 of 883 Confidential Page 124 DAVID RODGERS have stayed at the ranch? MR. PAGLIUCA: Object to foundation THE WITNESS: I'm going to say most likely they did. BY MR. EDWARDS Q. Was there any other location in Santa Fe where you are aware passengers would have stayed? Rea Not that I'm aware of. Q. If you were all going to the same place, is that an occasion where you would all ride in the same vehicle from the airport to the ranch? MR. PAGLIUCA: Object to foundation. THE WITNESS: I don't know. BY MR. EDWARDS Q. You would still right in separate vehicles? As Right. Because it takes us about an hour to finish up at the airport. Q. And then the 31st, so two days? A. Let me go back to that one -Q. Sure. A. -- and say, it is possible. I think Adam has ridden with us before. So I couldn't swear that one way or the other. But he has probably ridden MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page279 of 883 Confidential Page 125 DAVID RODGERS with us before to the airport; to or from the airport. Q. Two days later, flight No. 1408 out of Santa Fe to Palm Beach, who were the passengers there? A. Jeffrey Epstein, Ghislaine Maxwell, Prince Andrew, Virginia Roberts, Nadia Bjorlin, Henry Jarecki, Marvin Minsky. Q. Do you remember when you were at the ranch Nadia Bjorlin arriving? A. I would assume that she airlined in there. Q. Do you remember her at the ranch? Did she perform for you or anything? A. No. I don't remember her at the ranch. I mean, I'm sure she was there. JI just don't remember. Q. Okay. Do you remember a person named Heather Mann? She's found on flight 1438 next to Lydia. A. Heather Mann, not really. Q. Okay. The next flight, on page 45, is 1488. The flight number. April 9th, 2001 A. Right. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page280 of 883 Confidential Page 126 DAVID RODGERS Q. Where does that flight take off from and where does it go? A. Palm Beach to Atlantic City. Q. Who is on that flight? A. Jeffrey Epstein, Emmy Tayler, Virginia Roberts, Banu and Johanna. Q. Do you remember Johanna Sjoberg? A. I don't. Q. On that same day, you take a flight to Teterboro? A. Right. Q. Did you go to the casinos at all that day? A. I don't think so. Q. Would that be something that you would do with them? Or you would stay back? A. No. We would stay at the airport. Q. All right. And then two days later, on the llth, flight 1490, the plane flies out of Teterboro. For that two-day period of time, the night of the 9th and the night of the 10th, would you have stayed at the apartment? MR. PAGLIUCA: Object to foundation. MR. EDWARDS: In New York. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page281 of 883 Confidential Page 127 DAVID RODGERS THE WITNESS: I would say, yes. BY MR. EDWARDS: Q. All right. Do you know where Virginia and Banu and Johanna stayed? A. No idea. Q. You can't recollect whether they were -you can't recollect seeing them at the apartments? MR. PAGLIUCA: Object to foundation THE WITNESS: No. BY MR. EDWARDS: Q. All right. Then on the 11th, you leave from Teterboro and go to where? A. St. Thomas. Q. That is flight 1490. And on that flight, Jeffrey Epstein, Ghislaine Maxwell, Prince Andrew, Banu, Virginia Roberts and Johanna? A. ¥es,. Q. And that is -- that is a flight -- how does -- how did those passengers get from -- does Jeffrey Epstein have a place in St. Thomas? MR. PAGLIUCA: Object to form. THE WITNESS: Well, yes. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page282 of 883 Confidential Page 128 DAVID RODGERS BY MR. EDWARDS: Q. Where is that? A. In St. Thomas, he has an office. In St. Thomas. Q. Where does he stay in the Virgin Islands? A. On Little St. James. Q. And how do the passengers get from St. Thomas to Little St. James? A. Most likely, helicopter. Q. How many people does the helicopter fit? A. We didn't own a helicopter then. Probably -- probably 5. It depends, because they had different helicopters. I'm not sure which one they used that day. Q. What is the duration of the flight from St. Thomas to Little St. James? A. About six minutes. Q. What is the duration of a boat trip from Little St. James to St. Thomas? A. Probably about, let's say, 15 to 20 minutes. But you are on the east side of the island and the airport is almost to the west side of the island. Q. So you have to almost circle the island? MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page283 of 883 Confidential Page 129 DAVID RODGERS A. To get from the island by boat, to get to -- there's land there and take a car, it is probably -- it is probably close to an hour, 45 minutes for sure. Q. Are there passenger manifests that are kept for the helicopters? MR. PAGLIUCA: Object to foundation THE WITNESS: I'm not sure. I'm not sure. BY MR. EDWARDS: Q. Back in this time, in around April of 2001, did Jeffrey Epstein have a helicopter yet? A. No, he did not have a helicopter Q. At that time? As Correce. Q. And so do you remember the name of the company or corporation that they rented or transported? A. I don't. It was the only -- helicopter service there in St. Thomas is no longer there. Q. Okay. A. Air Center Helicopter. Q. Was there a particular person at Air Center Helicopter that you ever coordinated with? A. We would, like, call a dispatcher. Or you MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page284 of 883 Confidential Page 130 DAVID RODGERS know, whoever picked up the phone, we would call them. Q. All right. So 1491 is a flight from St. Thomas to Palm Beach; is that right? Ree Yes, Q. And Gwendolyn Beck is now on that flight? Re Yes, Q. Do you remember that flight at all, 1491? A. Not really. Q. Anything about it stick out in your mind? A. No. Q. All right. The next flight that -- do you remember a female name Kelly Bovina? A. I remember the name, but I don't remember her. Q. Was she an actress as well, do you remember that? A. I don't recall. Q. The next flight I want to direct your attention is 1501, May 3rd, 2001 Bic Okay. Q. What is that airport, ADS? A. Addison, Texas. San Antonio, Texas. Q. And who are the passengers on that? MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page285 of 883 Confidential Page 131 DAVID RODGERS A. Jeffrey Epstein, Virginia Roberts. Q. Do you know how Virginia Roberts got to Addison, Texas? A. No. Q. Was that flight -- was the purpose of that flight only to pick up Virginia Roberts? MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: Q. Can you tell by your logs? A. Not really. Let's see. We -- no, I don't know. Q. The flight previous on the 3rd flies in from where? Where is that? A. Little Rock. Q. Arkansas? A. Correct. Q. So the only passenger on that flight from Little Rock, Arkansas, to Addison, Texas, flight 1500, is Jeffrey Epstein, right? A. Right. Q. And then you land in Addison before going to Santa Fe? A. That is actually San Antonio, I believe. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page286 of 883 Confidential Page 132 DAVID RODGERS Yes. That is San Antonio, SAT. Q. How long is the flight from Addison to San Antonio? A. I would be guessing, probably an hour. Q. Do you know what the purpose was for landing -A. Well, you know, I can tell you. It is 9/10s. Fifty-four minutes. Q. Do you know what the purpose was to be to land in Addison, Texas, before arriving in San Antonio? A. I do not. But it appears that we spent the night in San -- oh, I see what you are saying. No, I don't know. That I went to Addison probably the same day. Q. Went to Addison and picked up Virginia Roberts? A. It looks like it. Q. And then in San Antonio, two days later, who are your passengers on that flight, 1502? A. Jeffrey Epstein, Virginia Roberts Q. Where do you fly? A. From San Antonio to Palm Beach. Q. And in May, on May 14th, 2001, flight MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page287 of 883 Confidential Page 133 DAVID RODGERS 1506, where is that flight leaving from? A. St. Thomas. Q. And going where? A. Teterboro. Q. And who are your passengers? A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Banu, Virginia Roberts and one female. Q. And, again, do you remember who the one female would have Powe No. individuals Correct As Correct. Q. Can you tell by this been with Virginia Roberts? MAGNA®© LEGAL SERVICES how any of those that were on that flight leaving from the Virgin Islands to Teterboro got to the Virgin Islands? A. No. Q. What were the other possible avenues back in those days for Jeffrey Epstein, Ghislaine Maxwell to travel to the Virgin Islands? A. They could have done a charter, possibly. Q. Okay. Was there ever a time when, it looks like that is the -- that is the Gulfstream that you fly out of the Virgin Islands to Teterboro,

Case 18-2868, Document 283, 08/09/2019, 2628241, Page288 of 883 Confidential Page 134 DAVID RODGERS Q. Was there ever a time you were flying the Gulfstream and -- well, let's go back a little bit. A. Okay. Q. On May 7th, at the top. A. Right. Q. Flight 1503, that is the Gulfstream traveling from Palm Beach to CHO? A. That is Charlottesville, I believe, Virginia. Q. And then on that same day from Charlottesville to Teterboro? A. Correct. Q. So when does the Gulfstream get from Teterboro to St. Thomas? A. Hmm, I don't know. Because it appears that I'm on vacation at that time. So I don't know. Q. How did you get to St. Thomas for the 14th to fly? A. Airline. Q. All right. So at some point in time, between May 7th and May 14th -A. Uh-huh. Q. -- somebody flies the Gulfstream to the Virgin Islands. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page289 of 883 Confidential Page 135 DAVID RODGERS A. Correct. Q. And who would that be? MR. PAGLIUCA: Object to foundation THE WITNESS: Larry Visoski and I don't know who the other person would have been. BY MR. EDWARDS: Q. When you pick up passengers in the Virgin Islands and you are taking them to Teterboro, do you speak with Larry Visoski about when he arrived in the Virgin Islands? A. Yeah. Yeah. We would coordinate that. rE mean, usually we would go down there together. We would ride in the same airline down. Q. In this particular case, you were on vacation? M Well, that is true. However, most likely he airlined home once he got to St. Thomas. And then most likely, we drove in a car to Miami and road the same airline down there. Q. That was something that you customarily did? A. Yes. Q. Okay. So then you have -- we have no way of knowing then who the passengers that flew to the MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page290 of 883 Confidential Page 136 DAVID RODGERS Virgin Islands would have been, if there were any in addition to those that left? Rea No. Q. All right. You fly into Teterboro on flight 1506 on May 14th, 2001, and fly out in the Gulfstream on the 24th, 10 days later; is that right? Ra Yes, Q. And your passengers, 10 days later flying to Palm Beach are Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Adam Perry Lang and a female. A. Right. Q. Do you know where Virginia Roberts went during that time after she landed in Teterboro on the 14th? Ae I dae not. Q. Page 47, I'm going to go to flight No. 1510. dune 3rd, 2001 Who is on that flight? A. Jeffrey Epstein, Virginia Roberts, Banu. Q. And you are flying from Palm Beach to St. Thomas again? A. St. Thomas, yes. Q. And then from St. Thomas to Teterboro two MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page291 of 883 Confidential Page 137 DAVID RODGERS days later, on June 5th? A. Jeffrey Epstein, Virginia Roberts, and Banu. Q. All right. And then where is the next flight on the 8th? A. On the 8th, from Teterboro to Montreal Q. Do you know what -- so Virginia Roberts and Banu were not on the flight on the 8th, right? As That's correct. Q. Okay. Do you remember the flight on the 8th with Naomi Campbell, Rebecca White, Ana Malova? A. Sort of. But not really. Q. Okay. Do you remember who Rebecca White is? A. No. Q. Do you remember how old Rebecca White was? A. No. Q. The next flight I want to direct your attention to is on the 15th of June, flight 1516 A. Uh-huh. Q. Passengers: Jeffrey Epstein, Ghislaine Maxwell, and then does that say Sheridan? A. ¥es. Q. Do you remember a passenger named Sheridan MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page292 of 883 Confidential Page 138 1 DAVID RODGERS 2 Gibson? 3 A. Possibly. 4 oy And then it says, Caroline. Do you know 5 who Caroline is? 6 A. I do not. 7 ‘as And then one female? 8 A. Yeah, I don't know who the female is. 9 os. Okay. On the 28th, there is a flight 10 L523 5 11 A. Uh-huh. 12 os From -- is that Portugal to St. Thomas? 13 A. No. It is the Azores. 14 Q. LPAZ? US: A. Yes. It was a fuel stop. 16 Os To St. Thomas? 17 A. Right. 18 Q. And then on that flight is Jeffrey 19 Epstein, Ghislaine Maxwell, Emmy Tayler and Ed 20 Tuttle, right? 21 Aas Yes. 22 Q. Six days later, leaving on July 4th from 23 St. Thomas, who are your passengers? 24 A. Jeffrey Epstein, Prince Andrew, Virginia 25: Roberts, one female. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page293 of 883 Confidential Page 139 DAVID RODGERS Q. And do you know how Virginia Roberts got to the Virgin Islands? A. No. Q. Is there any -- is it possible that the Cessna took her or the Boeing took her? Or any other aircraft that is owned by Jeffrey? MR. PAGLIUCA: Object to foundation. THE WITNESS: No, I would -- if I had to guess, I would guess the airlines. BY MR. EDWARDS: Q. Okay. A. Well, I know it wasn't the Boeing, because the Boeing is not in operation at that point in time. We hadn't flown it. I mean, it hadn't had any passengers on board yet. That is like in August of 2001. Q. Okay. And the Cessna, did you take that from Florida to the Virgin Islands? As It has been to the Virgin Islands, but I don't think we ever took any passengers down there. Q. Okay. All right. The next flight is 1525. A. Okay. Q. On July 8th, 2001. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page294 of 883 Confidential Page 140 DAVID RODGERS A. Okay. Q. That leaves out of Palm Beach? A. Okay. Q. Where do you go on that? A. Teterboro. Q. And who are your passengers? A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Prince Andrew, Virginia Roberts, Sheridan Gibson, maybe Sheridan Gibson-Beaute, I guess, and one female. Q. And then three days later, you leave out of Teterboro to CPS? A. Yes. Q. Where is that? A. That is St. Louis, actually it is Cahokia Illinois, across the river from St. Louis. Q. Who are your passengers? A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Virginia Roberts. We were actually en route to Santa Fe. We had a mechanical problem. We had to go into there for maintenance. Q. Do you remember having a mechanical problem or is the log just refreshing your memory? A. No, I remember because that was the only MAGNA®© LEGAL SERVICES

10 11 12 13 14 15 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page295 of 883 Confidential Page 141 DAVID RODGERS time we landed at Cahokia with passengers on board. Q. What was the problem? A. We had a -- we had a static line that had cracked and it was causing our altimeters to not agree. And then we went to the alternate system, things got really worse because it was stopped up with a mud dauber somewhere in the system. That is why I remember that flight. Q. When you landed in St. Louis did the passengers get off the plane? A. Yes. And then they airlined -- I believe they airlined. They could have taken a charter, I don't recall. But I know they didn't leave with us. Q. All right. And the passengers that got off the plane would have been Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler and Virginia Roberts? A. Yes. Q. And then on the 16th, those five days later, those same passengers leave Santa Fe? A. Right. Q. And go back to Teterboro? A. Correct. Q. When Jeffrey Epstein would go to his townhouse in New York, would you always fly into MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page296 of 883 Confidential Page 142 DAVID RODGERS Teterboro? A. Most of the time. It would depend on the airplane, too. Like the Boeing, you are not allowed to take it into Teterboro. Q. So while you had the Gulfstream, it seemed like Teterboro? A. Yeah, it is -- I mean, occasionally there would be a LaGuardia in there, but not really often. Q. So on the 16th, you fly in to Teterboro And then six days later, it looks like, flight No. 15 -- oh, wait. All right. So flight No. 1528, you fly into Teterboro, Jeffrey Epstein, Emmy Tayler, Ghislaine Maxwell and Virginia Roberts. Do you see that? A. Yes, Q. Then the next flight I have listed is 1530. Do you know where 1529 is? A. No, other than I'm gone for some reason. I wasn't on that flight. Let's see. July, approximately. I see I went on vacation. Q. Okay. And the 23rd, there is a flight from Palm Beach to St. Thomas with Jeffrey Epstein, MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page297 of 883 Confidential Page 143 DAVID RODGERS Shelly Lewis. Do you see that? A. Yes. Q. Five days later, the flight that leaves St. Thomas does not have Shelly Lewis; is that right? Pex Correct. Q. And then you fly to Palm Beach? Ra Yes, Q. And who are your passengers at that time? A. Jeffrey Epstein, Virginia Roberts, yes. Q. When you had the mechanical problem, do you remember any of the passengers being scared or frightened? A. No. Not really. I mean, they didn't really know that we had a problem. We just informed them that we couldn't continue on to Santa Fe. Q. Okay. And August 7th, 2001, flight 2? A. Uh-huh. Q. Is that the first flight that the Boeing makes with passengers? Ae Correct. Q. And that is Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Prince Andrew and two females Do you remember who the two females were on the MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page298 of 883 Confidential Page 144 DAVID RODGERS first passenger flight of the Boeing? A. I do not. Q. And then on the 7th -- at that flight flew from Los Angeles to Albuquerque, correct? A. Uh-huh. Q. On the 14th, you were flying the Cessna that has the 908GM tag. A. Correct. Right. Q. And then the next entry with passengers is on the 16th. And you are flying the Boeing again, right? A. Yes. Q. All right. Do you know who flew the Boeing for flight 3, 4 and 5? A. For 3, 4 and 5, no. Oh, yes. I know it wasn't me. I do remember that now. I went on vacation. And it was a contract guy that flew for us while I was gone. Q. Do you remember a passenger named Alexander Dixon? Re Alexander Dixon, no. Q. Flight No. 11 on the Boeing? A. Uh-huh. Q. Now, the Boeing has the tag 908JE? MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page299 of 883 Confidential Page 145 DAVID RODGERS A. Correct. Q. That is what you were explaining in the beginning, correct? A. Correct. Q. So September 3rd, the Boeing flies from St. Thomas to HPN? A. Yes, White Plains, New York. Q. And your passengers? A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Adam Perry Lane, Banu, Sarah Kellen, Alexander Dixon. Q. Do you remember Sarah Kellen? A. Yes. Q. And do you remember what -- is that your first time meeting Sarah Kellen, when she appears? A. I don't think so. I thought she was on an earlier flight. Let's see. But it could be. It could be, I'm not sure. Q. Do you know how Sarah Kellen got to St. Thomas to be leaving St. Thomas with you? Ae No. Q. Do you know what her relationship was, if any, with Jeffrey Epstein? A. She was -- Sarah was sort of taking over MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page300 of 883 Confidential Page 146 1 DAVID RODGERS 2 Emmy's position. Like an assistant to Ghislaine. 3 Q. All right. Page 53. January 15th, 2002. 4 A. Okay. 5 Q. There is a flight from Bedford, 6 Massachusetts; is that right? ad A. Yes. 8 Q. To where is that going? 9 A. White Plains. 10 Q. And it's Jeffrey Epstein and Jessica. 1: A. Yes. 12 Q. Do you remember who Jessica is? 13 A. I do not. 14 Q. From White Plains, who are the passengers 15 going to St. Thomas? 16 A. Jeffrey Epstein, Ghislaine Maxwell, Sarah 17. Kellen, Prince Andrew, Cindy Lopez, Johanna and one 18 female. 19 Q. Do you remember Cindy Lopez? 20 A. Yes. 21 Q. And what did she do? 22 A. I don't know what she did, but I do 23 remember Cindy Lopez. 24 Q. Was she somebody that you believed to be a 25 masseuse? MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page301 of 883 Confidential Page 147 DAVID RODGERS A. I'm not sure what her position was. It is possible. Q. All right. February 9th, 2002, flight 57 on the Boeing. A. Okay. Q. From Miami to White Plains. A. Yes. Q. Your passengers include Bill Clinton, four Secret Service. Did the Secret Service ask that you not identify them by name? As No. Q. Any reason that you didn't identify them Ae Didn't know their name. Q. Two males, one female. A. Right. Q. Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen and Prince Andrew. A. Correct. Q. Was that your first time meeting Bill Clinton? A. Yes. Q. At that point, did you have any MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page302 of 883 Confidential Page 148 DAVID RODGERS understanding of what was the relationship between Jeffrey Epstein and Bill Clinton or Ghislaine Maxwell and Bill Clinton? Re No, I didn't have any idea. Q. Had you seen any pictures, prior to that time, of Bill Clinton in any of Jeffrey Epstein's planes or homes? Ra Not him I'm aware of. Q. Have you ever seen a picture of Bill Clinton in Jeffrey Epstein's plane? A. In his plane? I don't think so. Q. Have you ever seen one in his homes? A. Not that I can recall. Q. Okay. BY, Oh, wait, wait. Back up. A picture of Bill Clinton in the plane? Do you mean the picture is on the wall in the airplane or a picture taken of Bill Clinton on the plane? Q. A picture of Bill Clinton on the wall of the airplane. A. I have a picture of me and actually the crew with Bill Clinton on the plane, but it is not on the wall of the airplane. Q. And when was the picture of you with Bill MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page303 of 883 Confidential Page 149 DAVID RODGERS Clinton taken? A. I think it was the first flight. Q. The flight that we just looked at? A. Yes. Q. To the best of your knowledge, is that the first time that Bill Clinton flew with Jeffrey Epstein or Ghislaine Maxwell? A. To the best of my knowledge. It was the first time that we had flown him. Q. Okay. On flight No. 72, which is page 54, March 10th. A. Okay. Q. The Boeing flies from St. Thomas to JFK; is that right? Ae Yes, Q. Is there any way of knowing when the Boeing got to St. Thomas by these logs? A. Yes, it got there on the 28th. Because it is trip No. 71 above it. Oh, wait. Oh. Wait. State the question again. Q. Yes, exactly. Do we know how or when the Boeing got to St. Thomas? It is leaving out of St. Thomas on flight 72, but flight 71 seems to me to land in Palm MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page304 of 883 Confidential Page 150 DAVID RODGERS Beach. A. Correct. Gs So I'm just missing the kind of connection there A. Yes. Me, too. Q. Okay. A. Yeah, I don't have an answer for that. Q. Okay. Would somebody else have flown the Boeing, while you were doing this simulator, the 6th and 7th and 8th? A. It is possible. Q. That is one possible conclusion, based upon what we have here? A. That is probably what happened. Q. Okay. So then March 10th -- sorry. March 10th, you fly to JFK, right? A. Yes. Q. March 4th, from JFK to Palm Beach. March the 17th, from Palm Beach back to JFK. And then March 19th, 2002, you fly from JFK to -- where is that? A. Luton, London. Q. And who are your passengers? MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page305 of 883 Confidential Page 151 DAVID RODGERS A. Bill Clinton. Doug Band. Three Secret Service, Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen. Q. And the next day -- or, sorry, two days later. Do you know where those passengers stayed in London? A. I have to think about this one second No, in fact, I don't think they did. Because we didn't spend the night there. We went there. I got to the hotel. As soon as I got to the hotel, I got word from Secret Service that President Clinton wanted to leave that night, so we left that night. So we made it to the hotel, the crew did, but we were there not that long. Two or three hours, four hours, maybe. Q. Do you remember why he wanted to leave that night? A. No. No, because when we went there, we thought we were going to be there for like probably at least a couple of nights. But it didn't turn out -- we didn't even spend one night there. Q. Okay. So does this probably mean that you got there late at night on the 19th, the early MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page306 of 883 Confidential Page 152 DAVID RODGERS morning on the 21st? A. We took off the 19th. So when we land there, it is really the 20th. And probably when we took off there, it is like after midnight or thereabouts. Q. And that is when you fly back to JFK? A. Back to JFK, yes. Q. And you went there with three Secret Service and came back with 10? A. Yes. Q. How did that happen? A. Well, there was an advance party waiting for us when we got there and then when we came back, they just flew back with us. Q. What was the events that you were traveling to London for? A. I'm not sure. I would imagine, he was probably giving a speech. Q. Okay. And you came back with Bill Clinton, Doug Band? A. Yes. Q. Who was Doug Band? A. Doug was Bill Clinton's, he's an attorney, and he was like his right-hand guy, really, as far MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page307 of 883 Confidential Page 153 DAVID RODGERS as doing anything. Q. Okay. And you also flew back with Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen and Naomi Campbell? Pie Yes Q. How did it happen that Naomi Campbell joined the plane to come home? A. I don't know. The same way she joined it before I guess in Montreal. JI don't know how she was there. And one male, too. It looks like. Q. All right. The next page is page 56, flight 96. A. Okay. Q. Sorry. Let's back up to 94 When the Boeing takes off from JFK, do you know sometime during that trip that you are going to be picking up President Clinton? Bs I think so. Let me see. We went to Paris. Yes, oh, yes. We knew that was going to be a long trip. Q. Okay. A. So we knew at that point in time. I'm almost certain that we knew. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page308 of 883 Confidential Page 154 DAVID RODGERS Q. What did you know about that trip? A. We knew that was going to be a long trip because we were going to go around the world. So when we departed, it was a about a week later, as I recall, that we picked up Clinton. We left JFK on the llth, a little less than a week. Half a week later, we picked up Clinton and from there, we went to -- Hong Kong. Q. So you fly in to -- on the 20th, flight 99, Jeffrey Epstein, Ghislaine Maxwell, and Sarah Kellen. A. Right. Q. You fly in to a Naval air base in Japan? A. Correct. Q. How were you given access to stay in the Naval air base? MR. PAGLIUCA: Object to foundation. THE WITNESS: The airplane, you mean? BY MR. EDWARDS: Q. Yes. It looks like it is there two days That is why -A. I guess because we were picking up President Clinton. Q. And do you know where Jeffrey Epstein, MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page309 of 883 Confidential Page 155 DAVID RODGERS Ghislaine Maxwell and Sarah Kellen stayed? A. I do not. Q. Was there a room for them on the Naval air base? A. No, I don't think -- nobody stayed at the Naval air base. Q. All right. And then on the 22nd, you leave the Naval air base with -- who is that on that flight? A. Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, President Bill Clinton, Mike, Doug Band, Janis and Jessica. Q. You flew into the Naval air base with Jeffrey Epstein? A. Plus six other passengers. Q. Okay. Are those secret service? A. Most likely. Q. You flew in to the Naval air base with Jeffrey Epstein, Ghislaine Maxwell and Sarah Kellen only, right? A. Right. Q. And nobody stayed on the Naval air base? A. No. Q. And you are there to pick up Bill Clinton? MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page310 of 883 Confidential Page 156 DAVID RODGERS A. Yes. Q. And you pick up Bill Clinton and six passengers plus Mike? A. Correct. Q. Doug Band, who you have already explained who that is with relation to Bill Clinton, and Janis and Jessica. Re Yes, Q. Do you know who they are? Poe Yes, Q. Who are Janis and Jessica? As Secret Service. Q. How do you remember that? A. Well, there is probably 8, 8 or 9 Secret Service people there, two of them were women. The other 7 -- and it was just easier to remember the two women's names than the 7 other guys' names Q. This entry on January 22nd, 2002, Jessica is that the same or a different Jessica from -A. On which one? Q. Sure. Sorry. May 22nd. I think I butchered the date before. A. Right. Qs May 22nd, 2002. Is that the same Jessica MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page311 of 883 Confidential Page 157 1 DAVID RODGERS 2 as January 15th, 2002, flying with Jeffrey Epstein? 3 A. January 15th. 4 MR. REINHART: Flight 48. 5 BY MR. EDWARDS: 6 Q. Right. It is flight 48. 7 A. I'm don't think -- no, I they wouldn't be 8 the same Jessica, no. 9 Q. Okay. After you pick up President Bill 10 Clinton, where did you fly? 12: A. We went to Hong Kong. 12 Q. Do you know what the purpose was? 13 A. I believe he was giving a speech. 14 Q. All right. And then from there, where did 15 you fly? 16 A. That would be Shenzhen, Japan -- or China. 17 Q. Okay. And do you remember the purpose 18 there? 19 A. Speech. 20 Q. And then where did you fly? 21 A. Singapore. 22 Q. Again, another speech? 23 A. Another speech. 24 Q. During the course of these days, where did 25 President Bill Clinton sleep? MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page312 of 883 Confidential Page 158 DAVID RODGERS A. I guess at a hotel somewhere. I'm not sure. Q. Did he stay at the same place as Jeffrey Epstein, Ghislaine Maxwell and Sarah Kellen? MR. PAGLIUCA: Foundation. THE WITNESS: I don't know. BY MR. EDWARDS: s All right. Were meals served on the plane? A. Something was served, but I don't know if you would call it a meal. Probably. I'm sure we had catering and stuff. I just don't recall. ‘O% That was just typical back then to have meals, especially for the President, right? A. Normally we do not. And we probably did have catering back then, but I don't recall Q. Okay. Where did you fly from Singapore? A. Singapore, VTBD, I don't know. You have your cheat sheet over there? @. VTBD, mine says Thailand. A. I was going to guess Thailand. Then from Thailand, I think we went to -Q. My cheat sheet says Brunei? A. Exactly. You don't want to go there. MAGNA® LEGAL SERVICES

10 1.1. 12 13 14 15 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page313 of 883 Re Q. Confidential Page 159 DAVID RODGERS You don't? No. Okay. Was the purpose a speech at each location to the best of your knowledge? Fee Q. To the best of my knowledge, it was. All right. Do you know why it was that Jeffrey Epstein and Ghislaine Maxwell and Sarah Kellen As Q. accompanied him? No. And then did you leave? MR. REINHART: Did you answer that question? BY MR. Q. THE REPORTER: He said no. MR. REINHART: I didn't hear it. EDWARDS: Did you leave President Bill Clinton and Doug Band and the Secret Service in Brunei? A. Hmm. It is possible. What is WRR? Not found. Sorry. Not good. That is the only entry in here that is not But the next one, VCBI says Sri Lanka? MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page314 of 883 Confidential Page 160 DAVID RODGERS A. Okay. Then if that says Sri Lanka, then, yes, we probably did leave Clinton in Brunei, I think. And I think we went from there down to Bali. We went to Bali without -Q. Without Bill Clinton? A. Yes. Q. What was the purpose of the trip to Bali? A. Just to get away. Q. And then to Sri Lanka? A. Sri Lanka was just a fuel stop on the way to Paris. Two fuel stops. Q. That's in Dubai? A. Yes. Q. And then you get to Paris? A. Correct. Q. And then you fly back to London? A. Yes. Yes. Q. All right. Do you remember the purpose of the trip to London? A. Yes. Q. What was that? A. We had to have our APU changed on the airplane. It quit working in Paris. And we landed there. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page315 of 883 Confidential Page 161 DAVID RODGERS Q. All right. The next page, page 57, June 21st. Flight 1570. Where is that flight leaving from? A. Palm Beach to the Bahamas. Q. And who is on the flight from Palm Beach to the Bahamas? A. Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, Cindy Lopez, Jean-Luc Brunel, Virginia Roberts. Q. All right. And that is on June 21st? Ae ¥es, Q. All right. And then there is a couple of entries that say "reposition." A. Right. Q. That is flying back to Palm Beach and then back down to the Bahamas? A. Correct. Yeah, we left them there. And we flew the airplane home. Q. And then did you leave out of the Bahamas on the 23rd A. Yes. Q. Up to Teterboro. And who are your passengers on flight Lota? MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page316 of 883 Confidential Page 162 DAVID RODGERS A. Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, Cindy Lopez, Juliana Borres, I guess, Jean-Luc Brunel, Melissa Stahl Q. A Virginia Roberts was taken to the Bahamas. Do you know where she went from there? A. I do not. Os Do you remember a Frederic Fekkai? A. What is the name again? G's Fekkai, F-E-K-K-A-I. Frederic Fekkai? A. First name? Q. Fred. A. Fred. a Hairdresser? A. The last name sounds familiar. Q. All right. He's on a flight No. 116 on the Boeing. A. Uh-huh. a June 27th? A. Okay. I see. Qs And there are -- it looks like a bunch of passengers. Do you remember Daralyn Priest? A. No. Where is she? Qs Middle column. A. Daralyn. Oh, yes, I see her. Right. I MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page317 of 883 Confidential Page 163 1 DAVID RODGERS 2 don't remember her. 3 Q. Do you remember that flight? 4 A. To Paris. Not really. It was a big 5 flight. We had a lot of people on it, which was 6 unusual, going to Paris. No, I don't. 7 Q. You don't remember it. 8 A. No. 9 Q. So you don't remember the purpose of the 10 flight? 12: A. No. 12 Q. July 2002, it is page 58. Go to flight 13: 220% 14 A. Okay. 15 Q. LF? 16 A. That is Nice. 17 Q. And where do you go? 18 A. Tangiers. 19 Q. And then from Tangiers to? 20 A. To another place in Morocco. Marrakesh. 21 2 think it is Marrakesh. I could be wrong on that 22 one. It is definitely Morocco. 23 Q. From there, is that where you pick up Bill 24 Clinton? 25 A. Let's see. GMME would be Rabat, the MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page318 of 883 Confidential Page 164 DAVID RODGERS capital of Morocco, I believe. Q. Did you know before this flight that you at some point would be picking up Bill Clinton? Ae I think we did, yes. Q. Who was on the flight with Bill Clinton? A. Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, Prince Andrew, Cindy Lopez, President Clinton, Doug Band, Mike, with Secret Service and 8 Secret Service people. So probably 9 Secret Service people. Q. So Mike is a person that is also -- that is? A. He's Secret Service, yes. That is just what I recall. He was the lead guy of the Secret Service. Q. Where do you take Bill Clinton? A. We went to the Azores for a fuel stop and then we went to JFK. Kennedy, New York. Q. Then on August 5th, in the Gulfstream, on flight 1586, you leave from Teterboro and go to Santa Fe; is that correct? A. Correct. Q. On that flight, you have Jeffrey Epstein -- sorry, Jeffrey Epstein, Sarah Kellen and MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page319 of 883 Confidential Page 165 DAVID RODGERS two females? A. Yes. Q. Do you know who those two females were? A. No. Q. How long does the plane, the Gulfstream, stay in Santa Fe? A. Let's see. 1586, Gulfstream. I don't really know, because apparently, we had 1586 and the next one I see is 1589. So it flew three places, but I wasn't on that trip. Q. 1587 and 1588 are missing, right? A. That is what I'm saying. Q. Because you are not on it? A. I'm not on the trip. Q. And 1589? A. Uh-huh. Q. Leaving out of Santa Fe, who are the passengers? A. Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, Cindy Lopez, Virginia Roberts, Dan Moran, Eduardo, Alfred, Margarita and Nick Simmons. Q. Do you know how Virginia Roberts got to Santa Fe? Ay No. MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page320 of 883 Confidential Page 166 DAVID RODGERS Q. Is there any way to get to Santa Fe from, say, Florida -- well, strike that. MR. PAGLIUCA: Bus, train, car. BY MR. EDWARDS: Q. Did you ever know Virginia Roberts to take a train? A. Not that I'm aware. O's Did you ever know her to take a bus? MR. REINHART: To go to New Mexico? THE WITNESS: Not that I'm aware. Maybe she has, but I don't know about it. BY MR. EDWARDS: Q. Okay. I have a picture of her on horseback at the ranch, so who knows Let's see. August 17th, sorry, August 18th. A. Okay. Q. From Teterboro to Palm Beach? A. Right. Q. Who are your passengers? A. Jeffrey Epstein, Virginia Roberts, one female. Q. All right. Do you remember who that female was? MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page321 of 883 Confidential Page 219 DAVID RODGERS CERTIFICATE OF OATH STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) I, the undersigned authority, certify that DAVID RODGERS personally appeared before me and was duly sworn. WITNESS my hand and official seal this 8th day of June, 2016. Kelli Ann Willis, RPR, CRR Notary Public, State of Florida Commission FF928291, Expires 2-16-20 + + bo HE + FF HF HF +H + Ht HH + CERTIFICATE STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) I, Kelli Ann Willis, Registered Professional Reporter and Certified Realtime Reporter do hereby certify that I was authorized to and did stenographically report the foregoing deposition of DAVID RODGERS; that a review of the transcript was not requested; and that the transcript is a true record of my stenographic notes. I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties’ attorney or counsel connected with the action, nor am I financially interested in the action. Dated this 8th day of June, 2016. KELLI ANN WILLIS, RPR, CRR MAGNA®© LEGAL SERVICES

EXHIBIT 16 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page323 of 883 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS nl a an a x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. oe eee SBS Saeed Sse ase Sees Sceeeaseeaeses x May 18, 2016 9:04 a.m. CONFIDENTIAL Deposition of JOHANNA SJOBERG, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page324 of 883 Page 8 dL: ol Okay. Great. 2 All right. Do you know a female by the 3 name of Ghislaine Maxwell? 4 A. Yes. 5 Q. And when did you first meet Ms. Maxwell? 6 A. 2001. March probably. End of 7 February/beginning of March. 8 Q. And how did you meet her? 9 A. She approached me while I was on campus at 10 Palm Beach Atlantic College. 1. Q. And what happened when she approached you? 12 A. She asked me if I could tell her how to 13 find someone that would come and work at her house. 14 She wanted to know if there was, like, a bulletin 15 board or something that she could post, that she was 16 looking for someone to hire. 17 Q. And what did you discuss with her? 18 A. I told her where she could go to -- you 19 know, to put up a listing. And then she asked me if 20 I knew anyone that would be interested in working 21 for her. 22 Q. Did she describe what that work was going 23 to be? 24 A. She explained that she lived in Palm Beach 25 and didn't want butlers because they're too stuffy. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page325 of 883 Page ‘l And so she just liked to hire girls to work at the 2 house, answer phones, get drinks, do the job a 3 butler would do. 4 Q. And did she tell you what she would pay 3 for that kind of a job? 6 A. At that moment, no, but later in the day, 7 yes. 8 Q. And what did she say? 9 A. Twenty dollars an hour. 10 Q. Was there anybody else with Ms. Maxwell 11 when you met her? 12 A. There was another woman with her. I don't 13 recall her or what she looks like or how old she 14 was. 15 Q. And what happened next? 16 A. And then she asked me if I would be 17 interested in working for her. And she told me that 18 she was -- I could trust her and that I could jump 19 in her car and go check out the house at that moment 20 if I wanted. 21 And so I said, Sure, let's do it, and went 22 to her home with her. 23 Q. And where was that home? 24 A. In Palm Beach. 25 0. And did she describe that home as being MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page326 of 883 Page 12 1 magazines. 2 She and I went -- she wanted to take me 3 shopping to Worth Avenue, but it was a Sunday and 4 Nieman Marcus was closed, so we went back to, like, 3 a little book store. And I remember she bought, I 6 think, five pairs of reading glasses because she cf thought Jeffrey would like them. He had them all 8 over the house. On every table there was reading 9 glasses. 10 And that's about it. It was a pretty 11 simple day. 12 Q. Were you paid that day for that work? 13 A. Yes. 14 Q. And how much were you paid? Do you 15 remember? 16 A. I don't remember how many hours I was 1.7 there -- I was there. She paid me cash. 18 Q. So Maxwell paid you? 19 A. Yes. 20 Q% And then was she the one who trained you 21 with what -- with respect to what you were supposed 22 to do during the day, directed you to, like you 23 said, go to -24 A. I believe she was the one that was kind of 25) showing me around. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page327 of 883 Page 13 il Os And how long did you work in that position 2 answering phones and doing -3 A. Just that one day. 4 0. Just that one day. 3 And did your duties change? 6 A. Well, the next time she called me, she 7 asked me if I wanted to come over and make $100 an 8 hour rubbing feet. 9 Q. And what did you think of that offer? 10 A. I thought it was fantastic. 11 Q. And did you come over to the house for 12 that purpose? 13 A. Yes. 14 Q. And when you came over to the house, was 15 Maxwell present? 16 A. I don't recall. 17 Q. And what happened that second time you 18 came to the house? 19 A. At that point, I met Emmy Taylor, and she 20 took me up to Jeffrey's bathroom and he was present. 21 And her and I both massaged Jeffrey. She was 22 showing me how to massage. 23 And then she -- he took -- he got off the 24 table, she got on the table. She took off her 25 clothes, got on the table, and then he was showing MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page328 of 883 Page 14 ‘l me moves that he liked. And then I took my clothes 2 off. They asked me to get on the table so I could 3 feel it. Then they both massaged me. 4 0. So it was more than a foot massage at that 6 A. Yeah, it was mostly, like, legs and back. I Q. Was everybody in the room without clothes 8 on? 9 A. When they were on the massage table, yes. 10 Q. Did they -- when they got off the massage 11 table to perform the massage, did they dress or 12 aid. == 13 A. Yes. 14 Q. They dressed. 15 And do you recall who paid you for that 16 first day that you did the massages? 17 A. I don't recall. 18 Q. Do you recall whether Maxwell was at the 19 house during that first day when you were doing the 20 massage with Emmy and Jeffrey? 21 MS. MENNINGER: Objection, asked and 22 answered. 23 BY MS. McCAWLEY: 24 Q. You can answer. 25 A. I don't recall. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page329 of 883 Page 15 T: 0% Who did Emmy work for? 2 A. Ghislaine. 3 Q. Did Maxwell ever refer to Emmy by any 4 particular term? 3 A. She called her her slave. 6 Q. You said your job duties changed. Did you 7 start to travel as part of your job with Jeffrey and 8 Ghislaine? 9 A. Yes. The next time they called me, they 10 asked me to go to New York. 1 Q. And did you -- do you recall when that was 12 approximately? 13 A. That was Easter of 2001. 14 Q. And do you recall who was on the plane 15 with you for that trip? 16 MS. MENNINGER: Objection, leading, form. 17 MS. McCAWLEY: Actually, I'm going to stop 18 really quickly and I'm going to ask for the 19 next exhibit, please. 20 MS. MENNINGER: This is 3? 21 MS. McCAWLEY: Yes. I'm going to mark 22 this as Exhibit 3 for purposes of the 23 deposition. 24 25: MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page330 of 883 Page 27 ‘l leading. 2 THE WITNESS: Jeffrey Epstein; Ghislaine 3 Maxwell; AP and PK are the two women I do not 4 recall; Virginia Roberts; and myself. D BY MS. McCAWLEY: 6 Or Do you recall how you flew back from the 7 location in the US Virgin Islands? 8 A. They put me on a commercial flight. I 9 wanted to be home in time for Easter. 10 QO. When you say "they," do you recall who 11 made those arrangements for you? 12 A. It could have been Ghislaine. 13 Q. Did you -- do you recall performing 14 massages while you were in the US Virgin Islands? 15 A. Yes. 16 0. Who was involved in -- was there more than 17 one? 18 A. Yes. I massaged Ghislaine at one point. 19 And I massaged Jeffrey, Virginia and I, both, on the 20 beach. 21 Q. Were you dressed during the massage that 22 was on the beach? 23 A. Yes. Bikinis probably, most likely. 24 Q. Do you recall what Virginia was wearing? 25) A. I believe she was wearing a bathing suit, MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page331 of 883 Page 32 el to object and then you can still answer. No 2 one is going to stop you from answering. I 3 just need to get the objection on the record, 4 in the same way she needs to be able to talk 3 before you. My apologies. I'm not trying to 6 cut you off, but I am supposed to get it in 7 before you answer. 8 BY MS. McCAWLEY: 9 Q. Did Jeffrey ever tell you why he received 10 so many massages from so many different girls? 11 MS. MENNINGER: Objection, hearsay. 12 BY MS. McCAWLEY: 13 QO. You can answer. 14 A. He explained to me that, in his opinion, 15 he needed to have three orgasms a day. It was 16 biological, like eating. 17 Q. And what was your reaction to that 18 statement? 19 A. I thought it was a little crazy. 20 0. And what did -- do you recall what -- when 21 you observed the other females giving massages, do 22 you recall what they would dress like? Did they 23 wear scrubs or did they typically wear normal 24 clothes? 25 A. Normal clothes. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page332 of 883 Page 33 il MS. MENNINGER: Objection, leading. 2. BY MS. McCAWLEY: 3 Q. Do you believe that from your 4 observations, Maxwell and Epstein were boyfriend and SD: girlfriend? 6 A. Initially, yes. 7 0% Did Maxwell ever share with you whether it 8 bothered her that Jeffrey had so many girls around? 9 MS. MENNINGER: Objection, leading, 10 hearsay. 11 THE WITNESS: No. Actually, the opposite. 12 BY MS. McCAWLEY: 13 QO. What did she say? 14 A. She let me know that she was -- she would 15 not be able to please him as much as he needed and 16 that is why there were other girls around. 17 Q. Did there ever come a time -- did you ever 18 take a photography class in school? 19 A. Yes. 20 0% And did there ever come a time when 21 Maxwell offered to buy you a camera? 22 A. Yes. 23 MS. MENNINGER: Objection, leading. 24 BY MS. McCAWLEY: 25 Q. Did Maxwell ever offer to buy you a MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page333 of 883 Page 34 el camera? 2. MS. MENNINGER: Objection, leading. 3 THE WITNESS: Yes. 4 BY MS. McCAWLEY: 3 Q. Was there anything you were supposed to do 6 in order to get the camera? a MS. MENNINGER: Objection, leading. 8 THE WITNESS: I did not know that there 9 were expectations of me to get the camera until 10 after. She had purchased the camera for me, 1. and I was over there giving Jeffrey a massage. 12 I did not know that she was in possession of 13 the camera until later. 14 She told me -- called me after I had left 15 and said, I have the camera for you, but you 16 cannot receive it yet because you came here and 17 didn't finish your job and I had to finish it 18 for you. 19 BY MS. McCAWLEY: 20 Q. And did you -- what did you understand her 21 to mean? 22 A. She was implying that I did not get 23 Jeffrey off, and so she had to do it. 24 Q. And when you say "get Jeffrey off," do you 25) mean bring him to orgasm? MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page334 of 883 Page 35 el A. Yes. 2 Q. Did Ghislaine ever describe to you what 3 types of girls Jeffrey liked? 4 A. Model types. 5 Q. Did Ghislaine ever talk to you about how 6 you should act around Jeffrey? 7 A. She just had a conversation with me that I 8 should always act grateful. 9 Q. Did Jeffrey ever tell you that he took a 10 girl's virginity? 1. A. He did not tell me. He told a friend of 12 mine. 13 Qs And what do you recall about that? 14 MS. MENNINGER: Objection, hearsay, 15 foundation. 16 THE WITNESS: He wanted to have a friend 17 of mine come out who was cardio-kickboxer 18 instructor. She was a physical trainer. 19 And so I brought her over to the house, 20 and he told my friend Rachel that -- he said, 21 You see that girl over there laying by the 22 pool? She was 19. And he said, I just took 23 her virginity. And my friend Rachel was 24 mortified. 25: MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page335 of 883 Page 36 ‘l BY MS. McCAWLEY: 2 Q. Based on what you knew, did Maxwell know 3 that the type of massages Jeffrey was getting 4 typically involved sexual acts? D: MS. MENNINGER: Objection, foundation, 6 leading. 7 THE WITNESS: Yes. 8 BY MS. McCAWLEY: 9 Q. What was Maxwell's main job with respect 10 to Jeffrey? ae MS. MENNINGER: Objection, foundation. 12 THE WITNESS: Well, beyond companionship, 13 her job, as it related to me, was to find other 14 girls that would perform massages for him and 15 herself. 16 BY MS. McCAWLEY: 17 Q. Did Maxwell ever refer to the girls ina 18 particular way? 19 A. At one point when we were in the islands, 20 we were all watching a movie and she called us her 21. children. 22 Q. Did anybody respond to that? 23 A I don't recall. 24 Q. Did she ever refer to herself as a mother? 25 A Yes, like a mother hen. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page336 of 883 Page 64 il Q. Do you remember anything notable about the 2 phone calls? 3 A. I just remember I always had to say, He's 4 unavailable, can I take a message? 3 Q. And where did you take a message? 6 A. On a little notepad next to the phone. z Q. Do you recall any small children calling 8 the house that day? 9 A. No. 10 Q. Were you speaking to anyone about their 11 school experience or anything like that? 12 A. No. 13 Q. Did you take any messages for famous 14 people? 15 A. They could have been famous and I would 16 have been clueless. 1.7 Q. Did you take messages at any other point 18 during the time that you worked with Jeffrey? 19 A. No. 20 Q. And you said you remember at the end of 21 that day being paid by Ghislaine? 22 A. Yes. 23 Q. And you were paid for doing the errands 24 and answering phones and whatever else you did? 25 A. Yes. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page337 of 883 Page 82 el Q. When you came upstairs, where was Virginia 2 sitting? 3 A. I don't remember. 4 Q. Do you remember what she was wearing? 3 A. No. 6 Q. She was already there when you got back 7 from sightseeing? 8 A. Yes. 9 Q. Tell me what happened with the caricature. 10 A. Ghislaine asked me to come to a closet. 11 She just said, Come with me. We went to a closet 12 and grabbed the puppet, the puppet of Prince Andrew. 13 And I knew it was Prince Andrew because I had 14 recognized him as a person. I didn't know who he 15 was. 16 And so when I saw the tag that said Prince 17 Andrew, then it clicked. I'm like, that's who it 18 is. 19 And we went down -- back down to the 20 living room, and she brought it in. It was just 21 funny because -- he thought it was funny because it 22 was him. 23 Q. Tell me how it came to be that there was a 24 picture taken. 25) MS. McCAWLEY: Objection. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page338 of 883 Page 83 el THE WITNESS: I just remember someone 2 suggesting a photo, and they told us to go get 3 on the couch. And so Andrew and Virginia sat 4 on the couch, and they put the puppet, the 3 puppet on her lap. 6 And so then I sat on Andrew's lap, and I 7 believe on my own volition, and they took the 8 puppet's hands and put it on Virginia's breast, 9 and so Andrew put his on mine. 10 BY MS. MENNINGER: 1 Q. And this was done in a joking manner? 12 MS. McCAWLEY: Objection. 13 THE WITNESS: Yes. 14 BY MS. MENNINGER: 15 Q. Do you recall a photo being taken of that 16 event? 17 A. Yes. 18 Q. You've never seen the photo? 19 A. No. 20 0% You don't know whose camera it was? 21 A. No. 22 Q. Virginia was sitting on the couch next to 23 Andrew, not in a big leather armchair? 24 A. Maybe. I'm just trying to remember how I 25 remember it. MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page339 of 883 Page 142 1 exposed her bra, and she grabbed it and pulled it 2 down. 3 Q. Anything else? 4 A. That was the conversation that he had told D her that he had taken this girl's virginity, the 6 girl by the pool. e Q. Okay. Did Maxwell ever say to you that it 8 takes the pressure off of her to have other girls 9 around? 10 A. She implied that, yes. 11 Q. In what way? 12 A. Sexually. 13 Q. And earlier Laura asked you, I believe, if 14 Maxwell ever asked you to perform any sexual acts, 15 and I believe your testimony was no, but then you 16 also previously stated that during the camera 17 incident that Maxwell had talked to you about not 18 finishing the job. 19 Did you understand "not finishing the job" 20 meaning bringing Jeffrey to orgasm? 21 MS. MENNINGER: Objection, leading, form. 22 BY MS. McCAWLEY: 23 Q. I'm sorry, Johanna, let me correct that 24 question. 25) What did you understand Maxwell to mean MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page340 of 883 Page 143 i when she said you hadn't finished the job, with 2 respect to the camera? 3 MS. MENNINGER: Objection, leading, form. 4 THE WITNESS: She implied that I had not 3 brought him to orgasm. 6 BY MS. McCAWLEY: 7 QO. So is it fair to say that Maxwell expected 8 you to perform sexual acts when you were massaging 9 Jeffrey? 10 MS. MENNINGER: Objection, leading, form, 1. foundation. 12 THE WITNESS: I can answer? 13 Yes, I took that conversation to mean that 14 is what was expected of me. 15 BY MS. McCAWLEY: 16 Q. And then you mentioned, I believe, when AT you were testifying earlier that Jeffrey told you a 18 story about sex on the plane. What was that about? 19 MS. MENNINGER: Objection, hearsay. 20 THE WITNESS: He told me one time Emmy was 21 sleeping on the plane, and they were getting 22 ready to land. And he went and woke her up, 23 and she thought that meant he wanted a blow 24 job, so she started to unzip his pants, and he 25 said, No, no, no, you just have to be awake for MAGNA® LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page341 of 883 Page 150 1 A. No. 2. Q. Was it in the context of anything? 3 A. About the camera that she had bought for 4 me. D: Q. What did she say in relationship to the 6 camera that she bought for you and taking 7 photographs of you? 8 A. Just that Jeffrey would like to have some 9 photos of me, and she asked me to take photos of 10 myself. 11 Q. What did you say? 12 A. I don't remember saying no, but I never 13 ended up following through. I think I tried once. 14 O% This was the pre-selfie era, correct? 15 A. Exactly. 16 QO. I want to go back to this: You testified 17 to two things just now with Sigrid that you said 18 were implied to you. 19 A. Okay. 20 05 The first one was it would take pressure 21 off of Maxwell to have more girls around? 22 A. Right. 23 Q. What exactly did Maxwell say to you that 24 led you to believe that was her implication? 25 A. She said she doesn't have the time or MAGNA®© LEGAL SERVICES

Case 18-2868, Document 283, 08/09/2019, 2628241, Page342 of 883 Page 160 1 2 CERTIFICATE 3 STATE OF FLORIDA ss 4 COUNTY OF MIAMI-DADE ) 5 I, KELLI ANN WILLIS, a Registered 6 Professional, Certified Realtime Reporter and 7 Notary Public within and for The State of 8 Florida, do hereby certify: 9 That JOHANNA SJOBERG, the witness whose 10 deposition is hereinbefore set forth was duly 11 sworn by me and that such Deposition is a true 12 record of the testimony given by the witness. 13 I further certify that I am not related 14 to any of the parties to this action by blood 15 or marriage, and that I am in no way interested 16 in the outcome of this matter. 17 IN WITNESS WHEREOF, I have hereunto set 18 my hand this 18th day of May, 2016. 19 20 KELLI ANN WILLIS, RPR, CRR 21 22 23 24 25: MAGNA® LEGAL SERVICES

EXHIBIT 17 (Filed Under Seal)

b N w oy a x © Oo 10 11 12 13 14 15 16 ly 18 19 20 21 22 23 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page344 of 883 UNITED STATES DISTRICT COURT for the Southern District of New York Civil Action No. 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, vs. GHISLAINE MAXWELL, Defendant. VIDEO-DEPOSITION OF: TAKEN BY: REPORTED BY: DATE AND TIME: PLACE: APPEARANCES: ALSO PRESENT: Sky Roberts Defendant Karla Layfield, RMR Stenographic Court Reporter Notary Public State of Florida at Large May 20, 2016; 8:33 a.m. Millhorn Law Firm 11294 North US Highway 301 Oxford, Florida Laura A. Menninger, Esquire HADDON, MORGAN & FOREMAN, PC 150 East 10th Avenue Denver, Colorado 80203 Attorney for Defendant Brad Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, FISTOS & LEHRMAN, PL 425 Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Attorney for Plaintiff Kenneth Sarcony, Videographer Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w oy a ~ © © 10 11 12 13 14 15 16 17 18 19 20 21 22 23. 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page345 of 883 72 Q Do you remember there being a job posting that you felt like was appropriate for Virginia or did you just go out and talk to the woman who ran the spa area on your own? A I just talked to Angela. Q Okay. Do you recall whether this was intended to be a full-time job? A I don't remember if it was full time or just summer jobs or, you know, during season. It was probably for a season because Mar-a-Lago is seasonal. I mean, I was there year round but a lot of people are seasonal, you know, because it's like snowbirds, you know, summertime comes and nobody wants to be down in south Florida. Q What would you call the season, the seasonal aspect of Mar-a-Lago? What's the season? A Probably from September or October to, you know, maybe May, I guess. Q Is that the coolest time? A Times of the year, yes. Q And it's more guests that come during that period of time? A Yes. Q And is there more staff brought on during that period of time? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w a wu a ~ © © 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page346 of 883 74 we'll call her Angela. A We've got to call her something, but, you know, I didn't really know what her job title was, but I was glad that they would give her a job. Q Right. A You know, and that, you know, I was hoping she would be happy; that way she could, you know, go back and forth to work with me. She didn't have to drive or nothing. Q Did you drive to and from work with her? A Yes. Pretty sure I did, yeah. Q Do you remember her hours being relatively the same as yours? A I'm pretty sure they were. Yes. Q Do you recall her being in school at the same time? A No, I don't recall. I don't remember if she was in school or not. Q Is it possible it was over, say, winter break or = A I don't remember. I'm sorry. This is so long ago. I mean, some things stick in my mind but some things I just don't remember. Q Do you remember whether Virginia wore a uniform? A Yes, I think she did. Yeah. I think everybody Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w s oy a x © o 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page347 of 883 80 Q So you don't know if it was a couple days or a couple weeks or a couple months or a couple years? Anything in that -A Well, it wasn't a couple years. It might have been two weeks to two months. I don't know. It wasn't a whole long time, you know. QO Where were you when Virginia told you she might be going to try to get this other job? A Probably at work. She might have told me, like, at lunch or whatever. I don't remember. That was so many years ago. I just remember she said Ms. Maxwell was going to, you know, get her a job with Jeffrey Epstein and learn massage therapy. And I thought, well, that's great, you know, because learning new jobs is all about life, you know. You've got to learn each -- you know, I've learned a lot of different things over my lifetime so it's good to learn every new job you can because that can help you later in life and that's what I think I told her. Q Okay. So the best you can recall today is you had a conversation with her sometime at lunch perhaps at Mar-a-Lago where she told you she was going to try to get another job? A Yes. And I thought that was a good thing. Q Do you know now that you recall that, what Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w a wu a x © o 10 11 12 13 14 15 16 17 18 19 20 21 22 23. 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page348 of 883 84 A No. Q Did she ever call you from that home? A Not that I know of. QO Was this when she was still living at home with you on Rackley Road? A Yes. Yes. Q Not Rackley Drive. A Rackley Road. Q Do you know whether Michael was living with you at Rackley Road at the time or not? A I don't think so. I don't remember. I didn't care for Michael. Of course, what parent cares for your daughter's boyfriend. Q Why didn't you care for Michael? A I didn't think anybody was good enough for my daughter but that's just me. Q I suspect you're right about all fathers. Do you remember her telling you anything about what her job with Mr. Epstein was going to be or was? A She said it was going to be massage therapy. Q Okay. Did she tell you she was getting some training? A Yes. Q Did she tell you about the training? A No. She just said she was being trained in Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w oy a x © © 10 11 12 13 14 15 16 17 18 19 20 21 22 23. 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page349 of 883 85 massage therapy. Q All right. When she came home at night from working with Mr. Epstein, did she look distressed to you in any way? A Not that I remember. Q Okay. Did she report any complaints about her job with Mr. Epstein? A Not to me. Q Okay. Did she report them to anyone else who then reported them to you? A No. Q Your wife, for example? A I have no idea. Like I said, if she did tell my wife, I never heard about it. Q Okay. Have you ever met Ms. Maxwell? A Not that I remember ever meeting her. QO Do you know what she looks like? A No. Q Did you ever meet anyone else who worked with Mr. Epstein? A No. Q Do you remember anyone else who worked for Mr. Epstein bringing your daughter home, for example? A No. Qo Did your daughter ever move into the home where Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w oy a x © Oo 10 11 12 13 14 15 16 17 18 19 20 21 22 23. 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page350 of 883 134 Q Okay. But your hours, if I understood you right, were approximately 7:00 a.m. to 3:00 p.m.? A Yes. Qo And Tuesday through Saturday? A Yes. Q Those hours would be the same time as somebody her age would have been in high school? A Yes. Q Okay. So does that -- does that give an indication to you that the short period of time she was working was during the summer when there was not school? A It seems to be that way. Q Okay. A I mean, to me, yeah. Q It could have been a summer job? A Yes, it could have been. Qo Okay. You would not have, as a father, had her working somewhere instead of going to school? A No, I wouldn't. Q And the day that Virginia came and spoke to you about meeting someone named Ms. Maxwell who was offering her another job, do you remember the conversation that you had with Virginia on that day? A No, not really. I just remember Virginia saying that, you know, she met Ms. Maxwell at the spa and that Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w s wu a x © © 10 11 12 13 14 15 16 17 18 19 20 21 22 23. 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page351 of 883 138 Q And there it describes her job at Mar-a-Lago as lasting from August 2000 to September of 2001. Do you see that? A Yes. QO Does that refresh your memory about how long she was working there? MR. EDWARDS: Form. THE WITNESS: She didn't work that long. MS. MENNINGER: Okay. THE WITNESS: Like I say, it was more, like, a couple of weeks. It wasn't -BY MS. MENNINGER: Q Well, earlier you testified it, might have been a couple of months? A Well, you know, for me, two weeks, two months, I mean, I don't even remember how long I worked at Mar-a-Lago. I told you I worked there six years and according to them, it was, like, three years. Seemed like Six. Q Well, earlier you testified that Mar-a-Lago was more of a seasonal place, correct? A Yes, well, it is seasonal. But I mean, they could be open up the spa area during the summer too because I'm sure a lot of people in Palm Beach come to get massages and things like that. I mean, you know, the only Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w oy a x © © 10 11 12 13 14 15 16 17 18 19 20 21 22 23. 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page352 of 883 139: part they close off is where the chefs and all that, where they didn't do any more big events and stuff. Q Okay. A But I think the kitchen was still open. I mean, they had a dining room. Q So if she didn't work there that long August 2000 -- even though August is in the summer -- it would not be unusual in your mind? A No. Q Okay. So she could have started working in August of 2000, correct? A She could have, yeah. Q And while you don't think she worked all the way until September of 2001 -A No. Q -- that would be consistent with your recollection of it being more seasonal in the fall, September -MR. EDWARDS: Object to the form. THE WITNESS: Yes. BY MS. MENNINGER: QO So if she worked in the fall, September, October, something like that, that seems likes that accords with your memory, correct? MR. EDWARDS: Object to the form. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

b N w a wu a x © Oo 10 11 12 13 14 15 16 17 18 19 20 21 22 23 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page353 of 883 143 CERT IF ICA TE STATE OF FLORIDA COUNTY OF MARION I, Karla Layfield, RMR, Stenographic Court Reporter, do hereby certify that I was authorized to and did stenographically report the foregoing deposition of Sky Roberts; that said witness was duly sworn to testify truthfully; and that the foregoing pages, numbered 1 through 142, inclusive, constitute a true and correct record of the testimony given by said witness to the best of my ability. I FURTHER CERTIFY that I am not a relative or employee or attorney or counsel of any of the parties hereto, nor a relative or employee of such attorney or counsel, nor am I financially interested in the action. WITNESS MY HAND this day of May, 2016, at Ocala, Marion County, Florida. Karla Layfield, RMR Stenographic Court Reporter Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

EXHIBIT 18 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page355 of 883 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No.08-CV-80119-CIY-MARRA/JOHNSON On behalf of the Defendant: ROBERT J. CRITTON, ESQUIRE BURMAN, CRITTON & LUTTIER 315 North Flagler Drive, Suite 400 Plaintft, West Palm Beach; #isiida S848? os: Phone: 561,842,2820 rerit@belclaw.com mpike@belelaw.com JANE DOE NO. 2, JEFFREY EPSTEIN, Defendant. U8-BUS8U, Y8-SUS81, 08-8094, - 08-8081 1, 08-80893, 09-80469, W9-BUDYL, UY-8U6D6, UY-SU8UZ, 9-8 1092 VIDEOTAPED DEPOSITION OF JUAN ALESSI VOLUME I Tuesday, September 8, 2009 10:12 am. = 3:45 p.m. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33401 Reported By: Sandra W. Townsend, FPR. Notary Public, State of Florida PROSE COURT REPORTING AGENCY West Palm Beach Office APPEARANCES: (On behalf of the Plaintiffs: RICHARD WILLITS, ESQUIRE RICHARD H. WILLITS, P.A. 2290 10th Avenue North, § Lake Worth, Fingidi: 3361 Phone: 961,82. /600 reelrhw@hounail.com EXHIBITS NUMBER DESCRIPTION STUART MERMELSTEIN, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. Exhibit number 1 Photographs 45 18205 Biscayne Boulevard, Suite 2218 Miami, Morida 33160 Phone: 305.931.2200 som@sexabuseattomey.com ahorowitz@sexabuseattomey.com WILLIAM J. BERGER, ESQUIRE ROTHSTEIN ROSENFELDT ADLER 401 East Las Olas Boulevard, Suite 1650 Fort [anderdale, Florida. 34301 Phone: 954.522.3466 hedwards@rra-law.com KATHERINE W. EZE PODHURST ORSECK, P. 25 West Flagler Street, Suite 800 Miami, Florida 33130 Phone: 305.358.2800 rjosefSberg@ipodhurst.com Kezell@podhurst.com ADAG 2 T:ANGINO, ESQUIRE IPOLD KUVIN: 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 33410 Phone: 561.515.1400 skuvingzleopoldkuvin.com (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Exhibit number 2 Exhibit number 3 Exhibit number 5 Transcript 130 Incident Report 137 Incorporation Papers 149 Incorporation ages = 150 1 (Pages 1 to 4) (561) 832-7506 Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) 76ef564a-4aic-4dee-87ac-479898cc GIUFFREQ00091

Case 18-2868, Document 283, 08/09/2019, 2628241, Page356 of 883 Page 45 MS. EZELL: I'm going to ask -- I don't know whether you've still been serially designating Exhibits or whether we're doing them separately for deposition. MR. CRITTON: | think we cannot trust that people will do them scrially. I'd do them with each one. MS. EZELL: Then would you mark this, please, as Exhibit | 10 this deposition. AndSegievdyeeg-to state on the revord that I will keep that origi féoiieastiattach it to the deposition. (Exhibit number 1 was marked for identification purposes and retained by Counsel for the Plaintiffs.) THE WITNESS: Yes, that's -BY MS. EZELL: Q. Can you identify that -- the young woman in those pictures? A. Yes. Q. Who is it? A. That's V. -- V. Now that you says R., that is V.R. definite, a hundred percent. MR. CRITTON: Let me just note my objection, as I did in A. Rod's deposition or Mr. Rodriguez's Page 47 THE WITNESS: Could have been. But, you know] Tam not --I don't think I ama very good judge of ages. If you ask me how old you are, I really couldn't tell you. MR. CRIT LON: Kathy thinks she's 25 MS. EZELL: In my dy THE WITNESS: Now, again, I must tell you, T was never told to check any i.d.s on any of the people who work at the house. BY MS. EZELL. Q_ Tunderstand that And, so, I think I'm just trying to establish that you didn't consider it part of your job description to worry about or consider the ages -A. No. Q. - of the young women that came there? A. Absolutely not. Absolutely not. Q. And, so, you never really focused on #8238" particularly thought about it if they seemed young? MR. CRITTON: Form. THE WITNESS: I don't -- I didn't see that many young girls, you know, young, underage girls at the house. I never saw except the two girls that I mentioned that I think it was underage wasN. for sure because she was still in high sekowt. Page 46 deposition, that I know you're going to confiscate Exhibit number |. I think it’s inappropriate. I think I should be allowed to have a copy of Exhibits that are being used in deposition. But I'll file a motion with the Court so we don't get into a pulling match over your Exhibits. MR. BERGER: I would ask that the court reporter initial that MS. EZELL:; Sure, Oh, you did? MR. WILLITS: She marked it. MR. BERGER: Did she put her initials or did she just put a number or a letter? MR. CRITTON: She's nodding that she did everything that she usually does, which means, initials, date and number. MR. MERMELSTEIN: You can iaik, MR. WILLITS: But when you talk, use your initials. BY MS, EZELL, Q. How old did you think V_R. was at the time she begssceming to Mr. Epstein's home? A. She could have been 17, 18, 19. Q. Could she have also been 15? MR. CRITTON: Form. Page 48 And she -- she had dinner with her mother, a couple times with her mother. And she become an actress. She's an actress and she has done movies. And he help her in her career. That's the only girl that I knew she was young, because she was going to high school and I pick her up from high school sometimes. But she was not a massage therapist. She will go for dinner. And they will go for the movies and she sang sometimes because she was a singer. So she sung at the house. Beautiful girl. Very talented. That's the only girl that I know that it was -- I would says, underage. BY MS. EZELL: Q. Okay. Did -- who told you that V.R. was a massage therapist? iA. Nobody. Q. Did you assume that she was a massage é therapist because you were told she was coming to give h massage? A No. Tassumed she was a massage therapy because I was -- I drove Ms. Maxwell to Mar-a-lago, Donald Trump's residence. And I wait in the car while Ms. Maxwell gota -- I think it was a facial or massage. I don't know. But that day I remember this girl, V., Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) PROSE COURT REPORTING AGENCY, 12 (Pages 45 to 48) INC. (961) 832-7506 76ef564a-4aic-4dee-87ac-479898cc GIUFFREQ00 102

Case 18-2868, Document 283, 08/09/2019, 2628241, Page357 of 883 Page 49 walking down from the main lobby towards the spa of Mar-a-lago. And I was driving Ms. Maxwell up, up the ramp. It's a little ramp there. And Ms. Maxwell says, stop. And she went and talked to -- she went inside. And that afternoon around 5:00 I saw V. came. She came to the house already, so she was there already. That was the first day knew. And then she would com regularly. Q. Did you ever meet any of V-'s family? A No I think she was -- one time I think her father drove her there. And I met -- I don't know if it was the boyfriend or husband or -- but he had to wait, make him wait outside while she was at the house. Q. Do you know the name or recognize the name lony Santiago” A. I think it was him. Q. That was her -A. I ktiow'hie*had an old beat-up car, Camaro or Mustang. I know it was very old car that I make him wait on the street one time. I make him come out of the driveway becatise we have to move some cars around. Q. Did there ever come a time when Tony Santiago was welcome in the kitchen? A. I think he came once in the kitchen, but Page 51 gqould says, between three months maybe before I left. And I think J left at the end of the year, so it could have been -- I remember it was a very hard day because | had to wait in the sun outside in a convertible and | was dying, waiting for an hour for Ms. Maxwell. I think it was in the summer of 2002. Q. And if I remember correctly, you left in November or December of 2002? A. Yes. « Q. Su that might lave been perhaps July bF Adgust of 20099 A. Uh-huh. Q. And, so, as I understand it, you only saw V.R. come to that house during the last three months of your time at Mr. Epstein's? A. Yes. Q. Do you have any -- any sense or can you approximate how many times she came? A. I cannot give you a number, but I would says, two, three times a week. Q. You mentioned that sometimes you would have to call these massage therapists in the middle of the night. Did you ever have to call V. for Mr. Epstein in the middle of the night? MR. CRITTON: Form. Page 50 Ms. Maxwell told me to get him out. Q. Did she tell you why? A. No. She didn't -- I guess she didn't want to become, you know, everybody -- because some of these people came with their husbands and they wait outside And I guess she didn't want this to become a norm for everybody to bring their companin lethey have -~ they will do a massage for her. Q. During the time you were there, did you ever know of Tony Santiago bringing any other girls to Mr. Epstein? A. No. I knew that sometimes I saw V. bring other girls with her, not Tony Santiago. Q. Do you remember the names of any of those girls ~ A. No, I don't. Q. -- that V. brought? A. That was at the end of my stay there. No. That was a very -~ at the very end of tke iast month of my stay. Q. Did you give - I don't believe I asked you, but if I did, forgive me. Did you give us an approximate year in which you were taking Ms. Maxwell t Mar-a-lago and saw V.R. for the first time? ‘A. That was at the -- at the end of my stay THE WITNESS: No. No. BY MS. EZELL: Q. Did there come a time while you were there that V.R. stayed in the house? MR. CRITTON: Form. THE WITNESS: I don't think so. IT cannot remember, No. BY MS. EZELL: Q. How many bedrooms were there upstairs? A. One, two, three -- one, two, three, four -four -- so that would be five, five bedrooms. Q. Five. And, so, would one have been Mr. Epstein's bedroom? A. Yes. His quarters was big, huge quarters. Q. Sort of a suite? A. Yeah. And he has - this is the room. His bathroom was here and her bathroom was ere. The-1ai room was here. And we have -- it was two scts of doors before -- two sets of double doors before you can go into the suite. There was one on top of the stairway and one in the middle of the hallway And then you walk into the ~ into the suite. Q. Okay. And you -- you just put a red eight by 11 folder in front of you? A. Yeah. 13 (Pages 49 to 52) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) 76ef564a-4aic-4dee-87ac-479898cc GIUFFRE000103

Case 18-2868, Document 283, 08/09/2019, 2628241, Page358 of 883 Page 57 A. Yes. Before she was married, yeah. They split up and she went her own way. Q. Did she marry a Glen Dubin (phonetics)? A. That's correct. And Mr. Dubin used to come to the house, ion, Q. Do you know, was Sarah Kellen ever one of the massage therapists before she became an assistant? A. I don't know if she-was-a, massage therapist. I don't remember #2#%yp a massage table for her. I think she was an assistant. And she would call -- at the end of my stay, I was -- tried to pull aside fram.my |, obligations and Sarah was doing all the phone cails and all the arrangement and all the looking out for these girls for the -- for massage therapists. They were constantly. Q. When did that role get transferred trom you to Ms. Maxwell, the role of looking afier girls and calling the girls? A. I didn't look after -- out for girls. Ms. Maxwell was the one that recruit -- | remember ong occasion or two occasions she would says to me, John, give me a list of all the spas in Palm Beach County And I will drive her from one to the other one to PGA and Boca. And she will go in, drop credit cards -- not credit cards, but Business cards, and she come out. And Rage 59 Q. And they called him uncle, you said? A. They called him uncle. Q. Did you ever lear what Tony Santiago did for a living? A. No. Q. Have you had any occasion to see him since the time you left Mr. Epstein's employ? A. No. Q. And you don't -- do you have any idea where he is? A Thave no idea T remember an incident, one lime the -- I went to pick her up at Royal Palm Beach and she was erying and I went and knock at the door and she was crying. And she says, well, -- I think it was Tony or -- because she used to live with these other guys, too. I here were two guys and her or two couples. I don't know the arrangements there. But I remember that she told me the -- Tony or her boyfriend had got mad and ripped the furniture, he cut the furniture in pieces and he even broke the sereens. Because I was -when I went into to knock the door, the screen was all ripped up like it was cut And she told me that he got mad at -- I don't know what happened. I never saw him in the Q._ Did she tell you he had hit her or beaten her Page 58 then we go to -- she will recruit the girls. Was never -- never done by me or Mr. Epstein or anybody else, that ] know. I don't know about Sarah because Sarah was. there at the last, last -- probably last weeks of my stay there. So I cannot say anything about Sarah. Q. Was there any point in time -- well, let me ask you this way: Did -- you said sometimes you woul *“tall the girls to come -A. Uh-huh. Q. -- to give them massage. And sometimes Ms. Maxwell would? A. Yeah. Q. Did there come a time when she took that over entirely from you -. No. . =~ or that continued . That's continued. ). -- until you left? . Yeah. Do you remember, is Jeffrey Epstets gaeifather to one of the Dubin children? A. I don't know ifhe godfather. I don't remember that. But he was very fond to these children, the children. Page 60] at all? MR. CRITTON: Is the she, V., V.R.? MS. EZELL: Yes. Thank you. BY MS. EZELL: Q Did you ever see during the time you were there photographs of V. in the house, the Epstein house} V.R. in the Epstein house? A. I don't think so. I don't think so. Q Did you ever see photographs of V.R. in Ms. Maxwell's albums? A. No. Q. At the time you were employed by Mr. Epstein, were there any hidden cameras? A. No. Q. You do know that he installed some after you left, correct? MR. CRITTON: Correct. THE WITNESS: I don't know. BY MS. EZELL: Q. Wasn't there a camera involved in the incident that -- the ineident in which you took money from Mr. Epstein? A. Yeah. Yes. But I don't know if he install it or not. That's what he told me. Q. Okay. 15 (Pages 57 to 60) PROSE COURT REPORTING AGENCY, INC. (961) 832-7506 Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) 76ef564a-4aic-4dee-87ac-479898cc GIUFFREQ00105

Case 18-2868, Document 283, 08/09/2019, 2628241, Page359 of 883 Page 77 Q. What kind of costume? CERTIFIGAS#: A. I don't know. It was a black, shiny costume. STATE OF FLORIDA I never saw it on her. COUNTY OF PALM BEACH Q. Was it leather? A. No. | think it was like a vinyl. But we were I, the undersigned authority, certify that very fussy about touching any of that stuff. We just... JUAN ALESSI persoiadlgegegeeeteet ie fore me and was dul MS. EZELL: No other questions. Thank you, swom on the Sth day of September, 2009. sir, THE WITNESS: You're welcome. Dated this 19th day of September, 2009. MR. LANGINO. I shouldo't have more than a half hone's worth af questions, if everyhody ix okay to power through. MR. BERGER: I probably hayg.a,half hour fo an hour. i MR. LANGINO: Okay. Sandra W. Townsend, Court Reporter MR. BERGER: Unless youssg@egehat | cover. Notary Publie - State of Florida MR. MERMELSTEIN: I could say the same thing, iy Cohn sion Expires. 6/26/12 so probably less than that. o sion No.: DD 793913 MR. LANGINO: So I guess my question is MR. BERGER: I think we ought to take a break. MR. LANGINO: That was my question. MR. BERGER: We're going to take a break Do you havewiy psowlem with that? THESSREEREEE H%. Whatever you guys want to Page 78 CERTIFICATE (Lunch recess.) 2 STATE OF FLORIDA (Continued to Volume II.) COUNTY OF PALM BEACH 1, Sandra W. Townsend, Court Reporter and Notary Public in and for the State of Florida at Large do hereby certify that the aforementioned witness was by me first duly sworn to testify the whole truth; that was authorized to and did report said deposition in stenotype: and that the foregaing pages numbered 1 tn 78, inclusive, are a true and correct transcription of my shorthand notes af said deposition I further certify that said deposition was taken at the time and place hereinabove set forth and that the taking of said deposition was commenced and completed as hessinabove sot out | further vertilysthi'lean mot attorney or counsel of any of the parties, nor am I a relative or employee of any attorney or counsel of party connected with the action, nor am | financially interested in the action. ‘The foregoing certification of this transeript does not apply to any reproduction of the same by any means unless under the dirset control and/or direction of the certifying reporter. Dated this 19th day of September, 2009, Sardsappdirceack Saunha W. Townsend, Cust Repusies. 20 (Pages 77 to 80) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) T6efS64a-4aic-Adee-87ac-479898cc GIUFFRE000! 10

Case 18-2868, Document 283, 08/09/2019, 2628241, Page360 of 883 Page 212 1 Q. -- would be the young one? 2 A. Yeah. 2 Q. You stated that Ms. Maxwell was very hard on 4 you and you got blamed for everything, and that you -5 you liked the job and you liked Mr. Epstein, but you 6 didn't like working for Mrs. Maxwell? wi A. That's correct. 8 Q. Can you tell me why,,.@ther than that she 9 blamed you for everything? 10 A. She came from a very wealthy family and she Ld was -- just my opinion; I give my personal opinion -—iz that she was rotten spoiled and she tried to drive Lhe 13 house like a palace and not a home. I was -- I discussed it with her, many, many Lb times we have discussions. And sometimes I even refuse 16 to do her orders, knowing that I was going to he b ad 17 up by Mr. Epstein or do the right thing, my thinking of 18 running the house should be. But we neycr had a good 29 relationship at all from the beginning, I don't think 20 so. But I was -- have to be her driver amd she will go 21 and shop all over the malls and I will have to go behind 22 her, pay for it and bring the bags to the car. 23 Next day or the same day she will do shopping 24 and buy and say, John, go to this store and get it. It 25 was a lot of work. It was a lot that she created and (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de GIUFFRE000242

Case 18-2868, Document 283, 08/09/2019, 2628241, Page361 of 883 Page 213 1 most of this jobs that she created. 2 Q. And one of those things you also had to do 3 with her was to take her to different spas? 4 A. Yes. a Q. And there she would recruit young women to 6 come and do massages? w A. Because she was English. And she didn't know 8 the aréa too much as well as I knew. So she -- she Q says, John, make a list »khe massage -- the spas 10 in the area from Jupiter to Boca Raton. And we went to i all the main spasm @me<then, we went to the schools for 12 massage therapists, and all the massage parlors, and a3 massage, the small massage. 14 So I make a list from the telephone book and 15 we would go from one to the another one. I would wait 16 in the cat fnd She goes in. dit And sometime she took a couple minutes and 18 walk out with cards, business cards. And that -- she 1 did the recruiting. 20 And from then, she pick up the girls and that ZL, was the end of it. I never did any recruiting and I 22 never really saw him doing it. 23 0. You really never saw? 24 A. Never saw Mr. Epstein recruiting anybody. | 25 MS. EZELL: All right. I have no other (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) GIUFFRE000243 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de

EXHIBIT 19 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page363 of 883 Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO:502008CA028051XXXXMB AB Plaintiff, -vs-— JEFFREY EPSTEIN AND SARAH KELLEN, Defendants. DEPOSITION OF JANUSZ BANASIAK Tuesday, February 16, 2010 10:09 - 2:30 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Job No.: 1317 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-bSd3c7182d1¢e GIUFFRE004424

Case 18-2868, Document 283, 08/09/2019, 2628241, Page364 of 883 Page 8 1 Q. What family was that? 2 A. It's, it was an older house in New York. I 3 worked there for seven years, no, five years before I 4 get the job in the Seagram company. So, I guess I had 5 some experience to continue. 6 Oy Do you remember the name of the family a that you worked with for seven years in New York? 8 A. Frank, Frank. 9 ie His name is something Frank, F-r-a-n-k? 10 A. Yes. 11 Os. Do you remember the first name? 12 A Fredrick. 13 Q. And were your duties as house manager for 14 Fredrick Frank similar to your duties as house 15 manager for Jeffrey Epstein? 16 A. Yes, yes. 17 ‘Ore And when you started in 2005 when you 18 heard that there was a job position with Jeffrey 19 Epstein, did you interview for that position? 20 A. Yes. 21 ‘Os Who did you interview with? 22 A. First I got interviewed with Ghislaine 22 Maxwell. 24 Q. And that's G-h-i-s-l-a-i-n-e, Maxwell? 25) A. Right, right. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-bSd3c7182d1e GIUFFRE004431

Case 18-2868, Document 283, 08/09/2019, 2628241, Page365 of 883 Page 9 1 Q. Where did that interview take place? 2 A. In New York. 3 Q. And it was for the position as house 4 manager in the Palm Beach house, correct? 5 A. Right. 6 Q. That's at 358 Albrillo way? 7 A. Correct. 8 Oy Why were you interviewed in New York, if 9 you know? 10 A. Because at that time I was living in New York 11 with my friends and so -12 Q. Where did the interview take place in New A York? 14 A In her house on 65th Street. 15 GO. Whose house, do you know? 16 A Ghislaine Maxwell. 17 Q. So, Ghislaine Maxwell interviewed you back 18 in 2005 at her house in New York for a position at 19 Jeffrey Epstein's house in Palm Beach? 20 A. Right. 21 Os And what did the interview consist of? 22 What did she ask you? 23 A. She asked me basic questions, you know, what's 24 my previous employer, how long I work for them and 25) basically she was checking my resume. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-bSd3c7182d1e GIUFFRE004432

Case 18-2868, Document 283, 08/09/2019, 2628241, Page366 of 883 Page 14 1 Q. Okay. So, I assume then that your wife 2 that you are separated from I guess at the time, she 3 didn't come down to Palm Beach? 4 A. No, no. 5 Oe And this is somebody who still lives 6 somewhere other than Florida? 7 A. Correct. 8 Q. So, you came down in February 2005 and 9 began working. What did you, what did you first 10 start doing for Jeffrey Epstein? 11 A. First I doing? I don't remember nothing 12 special. 13 Q. Okay. Well, were you working -- I will 14 rephrase it. Were you working only for Jeffrey 15 Epstein or were you working also for Ghislaine 16 Maxwell, the other person who interviewed you, or 17 anybody else in the house? 18 A. I guess only for him because she was visiting 19 a few times house, but I am employed by him. 20 Q. Okay. What was your understanding at that 21 time as to the relationship between Ghislaine 22 Maxwell and Jeffrey Epstein? 23 A. They were like partners in business. 24 ‘Ors Okay. What business was that, if you 25 know? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-bSd3c7182d1e GIUFFRE004437

Case 18-2868, Document 283, 08/09/2019, 2628241, Page367 of 883 Page 15 1, A. I don't know what kind of business but she was 2 the one who organized I would say employment with this 3 organization. So, whatever I need, if I have some kind 4 of problem, I contact her. She was the one who decided 5 what I have to answer my problems with, what I was 6 supposed to do. Zi Q. How many times did you have problems where 8 you had to go through her? 9 A. Well, not big problems. Just a question of 10 what certain, how to do certain things. For example, 11 what kind of flowers I have to buy, what kind of things 12 he likes, what time I supposed to serve him coffee in 13 the mornings, sort of organizing things. 14 Q. Those are things that you wouldn't ask 15 Jeffrey Epstein directly? 16 A. No, no. He doesn't like those things to ask 17 him directly. He would like to prefer either through 18 his assistant or like I say, Ghislaine Maxwell. 19 Q. Is that still the same today? 20 A. Yes, still the same. Unless, something happen 21 that I need to, nobody is around and I need to urgently 22 contact him, I go to him directly. 23 Q. So, for the most part if you have a 24 question or at least -- let's go back to 2005, you 25 had a question about what needed to be done in the (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-bSd3c7182d1e GIUFFRE004438

Case 18-2868, Document 283, 08/09/2019, 2628241, Page368 of 883 Page 54 1 A. (Witness shakes head.) 2 Q. And I'm sorry. 3 A. No. 4 Q. I understood you when you shook your head. 5 A. I realize what you told me but I am sorry. 6 Q. I told you it was easy to forget. a Do you remember who it was that personally 8 removed the computers and equipment from the 9 property? Was it Mr. Epstein, was it a lawyer, was 10 it, do you remember? 11 A. It was Adriana. 12 Q. All right. And I am of the understanding 13 that there were several computers that were removed 14 from the house, correct? 15 MR. GOLDBERGER: Form. 16 THE WITNESS: Yes, three of them. 17 BY MR. EDWARDS: 18 Q. Three? And to your knowledge Adriana 19 removed all of them? 20 A. She show up one day with gentleman. I don't 21 remember his name. And she told me that they are moving 22 out those computers. 23 Q. And where were the computers? Which rooms 24 were the computers in that were removed by Adriana 25) and this gentleman you're describing? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-bSd3c7182d1e GIUFFRE004477

Case 18-2868, Document 283, 08/09/2019, 2628241, Page369 of 883 Page 191 1 CERTIFICATE OF OATH 2 THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 6 I, the undersigned authority, certify that 7 JANUSZ BANASIAK personally appeared before me 8 and was duly sworn on the 16th day of February, 9 2010. 10 11 Dated this 28th day of February, 2010. 12 13 14 15 16 Cynthia Hopkins, RPR, FPR 17 Notary Public - State of Florida My Commission Expires: February 25, 2011 18 My Commission No.: DD 643788 19 20 21 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-bSd3c7182d1¢e GIUFFRE004614

Case 18-2868, Document 283, 08/09/2019, 2628241, Page370 of 883 Page 192 al CERTIFICATE 2 THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 I, Cynthia Hopkins, Registered Professional Reporter, Florida Professional Reporter and Notary 6 Public in and for the State of Florida at large, do hereby certify that I was authorized to and did iT report said deposition in stenotype; and that the foregoing pages are a true and correct transcription 8 of my shorthand notes of said deposition. 9 I further certify that said deposition was taken at the time and place hereinabove set forth 10 and that the taking of said deposition was commenced and completed as hereinabove set out. aE I further certify that I am not attorney or 12 counsel of any of the parties, nor am I a relative or employee of any attorney or counsel of party aes connected with the action, nor am I financially interested in the action. 14 The foregoing certification of this transcript 15 does not apply to any reproduction of the same by any means unless under the direct control and/or 16 direction of the certifying reporter. 17 Dated this 28th day of February, 2010. 18 19 20 21 thia Hopkins, RPR, 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-bSd3c7182d1e GIUFFRE004615

EXHIBIT 20 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page372 of 883 Condensed Transcript IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION Plaintiff, CASE No. 502008CA028051XXXXMB AB JEFFREY EPSTEIN, Defendant. DEPOSITION OF LOUELLA RABUYO VOLUME I October, 20, 2009 10:10 a.m. 515 N. Flagler Drive Suite 200-P West Palm Beach, Florida 33401 Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard IRE Palm Beach Gardenc, FL_33410 www.esquiresolutions.com anneal et Gallo Company GIUFFRE004386

Case 18-2868, Document 283, 08/09/2019, 2628241, Page373 of 883 Louella Rabuyo - Volume I October 20, 2009 1 {IN THE CIRCUIT COURT OF THE FIETEENTH JUDICIAL CIRCUIT TM AND POR PALM BEACG COUNTY, PLORTOA CIVIL DIVvrsi0N CASE No, 502008CA028051 Plaintife, OERFREY EDSTEIN, Defendant DEPOSITION OF LOUELLA RABUYO VOLIME Tuceday, October, 20, 2008 Tovio = 3:30 pam 515 N. Flagler Drive, Suite 200-P West Palm Beach, Florida 33401 Reported By: ‘Defesa Whalen, KER, PPR Notary Public, State of Florida Hest Palm Beach Office Job #118991 10 an 42 23 as 16 a 18 as 20 21 22 23 24 25 3 APPEARANCES: (On behalf of the Defendant: ROBERT D. CRITTON, JR., ESQUIRE BURMAN CRITTON LUTTIER & COLEMAN, LLP 203 Banyan Boulevard, Suite 400 West Palm Beach, Florida 33401 Phone: 561.842.2820 (On behalf of Plaintiff LM: BRADLEY J. EDWARDS, ESQUIRE CARA L. HOLMES, ESQUIRE ROTHSTEIN ROSENFELOT ADLER 401 €. Las Oless Boulevard, Suite 1850 Fort Lauderdale, Florida 33394 Phone: 954.522.3456 (On behalf of the Witness: BRUCE E. REINHART, ESQUIRE LAW OFFICE OF BRUCE E. REINHART 250 S. Australian Avenue, Suite 1400 West Palm Beach, Florida 3401 Phone: 561.202.6360 ‘On behalf of Defendants/Jane Does 2 - &: ‘STUART S. MERMELSTEIN, ESQUIRE MERMELSTEIN & HOROWITZ, P.A, 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 Phone: 305.931.2200 (On behalf of Plaintif in related Case No. 0880811 JACK HILL, ESQUIRE (Partially via speakerphone) SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY 2199 Palm Beach Lakes Boulevard ‘West Palm Beach, Florida 33409 Phone: 561.686.6300 10 rt 2 3 14 as a6 a7 18 as 20 a 22 23 24 25 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No.08-CV-801 19-CIV- MARRAKJOHNSON JANE DOE NO. 2, Plaintif, ae JEFFREY EPSTEIN, Defendant. a Related cases: (08-80232, 08-80380, 98-80381, 08-80994, (08-80993, 08-8081 1, 08-80893, 09-80469, (09-80591, 09-80686, 09-80802, 09-81092 DEPOSITION OF LOUELLA RABUYO ‘VOLUME | Tuesday, October 20, 2009 10:10 "3:20 p.m. 515N. Flagler Drive, Suite 200-P ‘West Palm Beach, Florida 33401 Reported By: ‘Teresa Whalen, RPR, FPR Notary Public, State of Florida ‘West Palm Beach Office Job #118991 Phone: 800.330.6952 561.659.4155 ESQUIRE inder Gala Company 10 a a2 3 uw 33 a6 uv 1 20 aa 22 23 24 WITNESS: DIRECT CROSS REDIRECT RECROSS LOUELLA RABUYO BYMA.EDWARDS: 5 190 BYMA.MERMELSTEIN: 195, 208 BY MA. HILL: 156 BY MR. CRITTON: 173 EXHIBITS NUMBER DESCRIPTION PAGE DEFENDANT'S EX. 1 COPIES, COMPOSITE PHOTOGRAPHS 103 DEFENDANT'S EX.2 COMPOSITE PHONE MESSAGE BOOK 147 DEFENDANT'S EX. 3 COPY OF PHOTOGRAPH 162 Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Reach Gardens, FL 33410 www.esquiresolutions.com GIUFFRE004388

Case 18-2868, Document 283, 08/09/2019, 2628241, Page374 of 883 Louella Rabuyo - Volume I 81 A When | came back to report, that's how | leamed. Q__ Elaborate on that for me. What do you mean, when you came back to report that's how | learned? A_ | reported in the afternoon, and then that's how I learned that the police came. Q Allright. And when were you ~ you're now saying you came back to report and you learned that the police had already come to the house, right? A. Yeo, air. Q_ Prior to that occasion, when was the previous time that you were at the house? A. The day before, Q Okay. And the day before you left your shift at roughly five o'clock? A Icannot remember. | usually leave 5:00 or 5:30. Q But sometime late in the afternoon? A Yes. Q And as of that time, the day before the search warrant was issued, you had seen no police officers in or around the house? A No. @ And then the next day you reported to the job at what time? October 20, 2009 83 Q So are we talking about the day the police went to Jeffrey Epstein’s house you did not go in the morning, but you went after lunch and the police had already left? ‘A Oh. No. When | went there nobody was there, no policemen were around. Who was at the house then? Janusz, and Douglas, the architect. Schoettle? Yoo. ‘And did you have a discussion with them? No. How did you know the police had been to the house? A Janusz told me. Q When? A When | arrive. Q That's what | was asking you when I said did you have a discussion with them, meaning Janusz and Douglas. A. Okay. Being because them -- with Janusz only. Q What did he say? A He said the police came and, what's this, took away some stuff. Q_Did he say what they took? 82 A. The next day? Q The next day A. | report in the afternoon. Q Was there a reason why you reported in the afternoon? A Ms, Maxwell called me. Q_ When did she call you? A. During that day, she said Louella, you can report in the afternoon. Q She called you early in the morning? A Notearly. Q__ Normally you would report to the house between eight and nine o'clock, right? A Yes, sir. Q Soin order for you not to arrive at the house, she had to have called you before eight or nine o'clock, right? A Yes, Q_ Okay. So approximately what time does Ms. Maxwell call you to tell you you can report to the house later on that day? A I cannot remember really the time. Q_ Okay. What time did you actually report to the house? A__Affer lunch, about ~ maybe after lunch. eyraneune a2. 12 13, a4 as 16 7 18 19 20 21 22 23 24 25 Ba He said pictures. Did he tell you which pictures? No, sir. Aside from pictures, what else did the police take, as Janusz told you? A_ He did not elaborate. Q Allright. Prior to the police going to the house and taking pictures, do you remember seeing pictures around Mr. Epstein's house? A Yes. Q Do you remember seeing pictures of naked or nude females around Mr. Epstein’s house? ‘A Not around, in his closet Q__InMr, Epstein's closet you would see describe what you would see related to females in pictures. ‘A Some have topless. Q Is this abig closet? A. No. Not really big, i's just this big, not so big, Q Okay. Were these pictures that could be seen by ~ strike that. Do you know of any other pictures of females that were confiscated by the police that did not come from Mr. Epstein's closet? o>oO> ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com GIUFFRE004408

Case 18-2868, Document 283, 08/09/2019, 2628241, Page375 of 883 Louella Rabuyo - Volume I October 20, 2009 a a2 a3 a4 as 16 7 1a 13 20 22 22 23 24 25 129 STATE OF FLORIDA COUNTY OF PALM BEACH |, the undersigned authority, certify that LOUELLA RABUYO personally appeared betore me on the 20th of October, 2009, and was duly sworn. Dated this doth day of October, 2009. ‘Teresa Whalen, RPR, FPR Notary Public - State of Florida My Commission Expires: 4/25/11 My Commission No.: DD 644533 Job #118991 a 32 a3 14 as 16 17 18 19 20 21 22 23 24 25 130 CERTIFICATE STATE OF FLORIDA COUNTY OF PALM BEACH I, Teresa Whalen, Registered Professional Reporter and Notary Public in and for the State of Florida at Large, do hereby certify that the aforementioned witness was by me first duly sworn to testify the whole truth; that | was authorized to and did report said deposition in stenotype; and that the foregoing pages are a true and correct transcription of my shorthand notes of said deposition. | further cerity that said deposition was taken at the time and place hereinabove set forth and that the taking of said deposition was commenced and completed as hereinabove set out. further certify that | am not attomey or counsel of any of the parties, nor am | relative or employee of any attorney or counsel of party connected with the action, nor am I financially interested in the action, The foregoing certification ofthis transcript does not apply to any reproduction of the same by any means unless under the direct control and/or direction of the certifying reporter. Dated this Soth day of October, 2009. Teresa Whalen, APR, FPR Job #118991 ESQUIRE ap Alexander Gallo Company Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com GIUFFRE004420

EXHIBIT 21 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page377 of 883 Page 1 L UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 2 3 JANE DOE NO. 2, Case No: 08-CV-80119 4 Plaintiff, 5 Vs 6 JEFFREY EPSTEIN, 7 Defendant. / 8 JANE DOE NO. 3, Case NO: 08-CV-80232 9g Plaintiff, 10 Vs a. JEFFREY EPSTEIN, 12 Defendant. / a es JANE DOE NO. 4, Case No: 08-CV-80380 14 Plaintiff, 15 Vs. 16 JEFFREY EPSTEIN, af Defendant. 18 oe 19 JANE DOE NO. 5, Case No: 08-CV-80381 O Plaintiff 21 Vs 22 JEFFREY EPSTEIN, 23 Defendant. f 24 25 Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000247 GIUFFRE000935

Case 18-2868, Document 283, 08/09/2019, 2628241, Page378 of 883 Page 2 Page 4 1 JANE DOE NO. 6, Case No: 08-CV-80994 1 VIDEOTAPED 2 2 DEPOSITION 3 3 of : 4 ALFREDO RODRIGUEZ 5 6 taken on behalf of the Plaintiffs pursuant 6 7 toa Re-Hotice of Taking Deposition (Duces Tecum) JANE DOE NO. 7, Case No, 08-CV-80993 3 7 3 sod Pains, 10 APPEARANCES: 8 1 ae MERMELSTEIN & HOROWITZ, P.A i 2 BY: STUART MERMELSTEIN, ESQ. io 18205 Biscayne Boulevard i n Suite 2218 Pe Miami, Florida 33160 2 GHA, se No: 08-C1-80811 “ Aatemey fer ane Doe 2 3, 4,5, 13 Planet 6 i 14 Vs t 16 ROTHSTEIN ROSENFELOT ADLER Sn BY: BRAD J. EDWARDS, ESQ., and 3 7 CARA HOLMES, ESQ. = Las Olas Cty Centre JANE DOE, Case No: 08-CV-80893 18 Suite 1650 8 401 East (25 Olas Boulevard Plain, 19 Fort Lauderdale, Florida 33301 19 ‘nttorney for Jane Doe end E.Wi vs 20 and LM, 20 2 JEFFREY EPSTEIN, popHursr oRseck an 2 BY: KATHERINE W, EZELL Defendant 25 West Flagler Street ees / 2 Suite 800 B Miami, Florida 33130 %4 24 ‘nttorney for Jane Doe 101 and 102. 5 25 Page 3 Page § 1 JANE DOE NO. IL, Case No: 08-CV-80469 1 2 Plaintiff, APPEARANCES: ee 3 eoro.oann 4 JEFFREY EPSTEIN, BOAT LANGING, E30 5 Defendant. 4 2925 PGA Boulevard SSS Suite 200 6 5 Paim Beach Gardens, Florida 33410 JANE DOE NO. 101, Case No: 03-CV-80591 toiney for 8.8 6 7 prin, ? RICHARD WILLTTS, FSO 8 2290 10th Avenue Norti Ue 8 Suite 404 i Lake Wort Ford 3346 JEFFREY EPSTEIN, ie a 10 BURMAN, CRETTON, LUTTIER & Defendant. a COLEMAN, LLP u BY; ROBERT CRITTON, ESQ 12. JANE DOE NO. 102, Case No: 09-CV-80656 LZ 215 North Flagier rive 13° Plaintiff, Suite 400 us‘ 3 ‘Wes: Paim Beach, Florida 33401 1s JEFFREY EPSTEIN, _ Attorney for Jeffrey Epstein. 16 __ Defendant ic = 16 7 ALSO PRESENT 18 v7 19 JOE LANGSAM, VIDEOGRAPHER 20 1031 1ves Lary Koad 18 Suite 228 o 2 North Miami, Florida 5 a July 29, 2009 2» 22 11:00 am. te 5:30 p.m. a 23 23 24 24 25 25 2 (Pages 2 to 5) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000248 GIUFFRE000936

Case 18-2868, Document 283, 08/09/2019, 2628241, Page379 of 883 Page 6 Page 8 7 INDEX OF EXAMINATION i Doe right here on the copy you gave me. I'm i 2 missing which Jane Doe this is. 3 WINES DIREGT: “EROS 3 They're all different case numbers. Do ALFREDO RODRIGUEZ 4 you want me to go through each case number? 4 5 MR. CRITTON: I'm going to note my ‘5 (By Mr. Mermelstein) 12 6 objection. Obviously if this deposition 5 z gets played -- not obviously, I'm going to 6 (By Mr, Edwards) 137 8 object to the litany of each one so I don't (By Mr. Langino) 260 9 know how we can separate it out. Maybe if ? 10 and when at the time of trial and depending : 1 on how the Court delermines what comes in 12 and what doesn't with regard to the ead BIE 13 consolidated aspects of this. I have no 12 1 Message pad 72 14 great idea other than just saying Jane Doe 13 2 Documents 115 15 versus Epstein, et al, or something like 14 16 that, or Jane Doe, et al. i: 7 MS. EZELL: Couldn't we just say and 7 18 those cases which have been consolidated 18 19 with it for Discovery purposes? 19 20 MR. EDWARDS: Although there is cases 20 a1 here that have cross noticed this from state at 22 court that haven't been consolidated so that a 23 may not work. You may have to read them 24 24 all, if it works out your way that will just 25 25 get edited out, at least he will have read Page 7 Page 9 1 Deposition taken before MICHELLE PAYNE, Court 1 that caption, every caption. Right? Is 2 Reporter and Notary Public in and for the State of 2 there a better suggestion? 3. Florida at Large, in the above cause. 3 MR. CRITTON: No. There may be a better 4 wee 4 suggestion if he starts this is such and 5 THE VIDEOGRAPHER: This is the case of 5 such day, it's the deposition of Mr. 6 Jane Doe No. 2, plaintiff, versus Jeffrey 6 Rodriguez in the case such and such, and we 7 Fpstein, defendant. Jane Doe No. 3, 7 can almost fill it in depending on which 8 plaintiff, versus Jeffrey Epstein, 8 tape it goes, how it fills in, at least 9 defendant. Jane Doe No. 4, plaintiff, 9 we'll have the context of the first and 10 versus Jeffrey Epstein, defendant. And Jane 10 depending on whether the Judge reads it in 3 Doe No. 5, plaintiff, versus Jeffrey di from a consolidated or they all come 12 Epstein, defendant. Jane Doe No. 6, 12 related, I have no great idea. 13 plaintiff, versus Jeffrey Epstein, 13 MR. EDWARDS: I was thinking if he read 14 defendant. Jane Doe No. 7, plaintiff, 14 every one of them and it was the seventh in 1s versus Jeffrey Epstein, defendant. CMA, 15 line then you just would edit it so you 16 plaintiff, versus Jeffrey Epstein, 16 would only read that one. 18 Jeffrey Epstein, et al, defendant. Jane 18 THE VIDEOGRAPHER: On page number three 19 Doe -- is there a shorter thing that we can 19 there is something missing on the top here. 20 do here? It's also missing this one right 20 Do you want me to read each case number 21 here. ai separately? 22 MR. MERMELSTEIN: Do we havea problem | 22 MR, MERMELSTEIN: I don't think it's 23 with saying Jane Doe 2 and the Epstein and 23 necessary. 24 related cases? 24 MR, EDWARDS: I don't think it's 25 THE VIDEOGRAPHER: I'm missing this Jane | 25 necessary either. 3 (Pages 6 to 9) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000249 GIUFFRE000937

Case 18-2868, Document 283, 08/09/2019, 2628241, Page380 of 883 Page 26 Page 28 1 with a copy. 1 A. Yes. Sometimes very short notice but, 2 Q. Were you the only one who was allowed to 2 yes, I was. 3. answer the phone? 3 Q. So that varied? 4 A. Yes. 4 A. Yes. 5 Q._ I'm sorry, what would you do -- a Q. Who would give you that notice? 6 A. I would leave it on the counter next to 6 A. Mrs. Maxwell or Sarah or Larry, the 7 the kitchen so when I find that piece all crumbled 7 pilot. 8 [knew that Mr. Epstein saw the message, so we 8 Q. And then you would drive to pick them up 9 communicated like that. 9 at the airport? 10 Q. Now, you mentioned Mr. Epstein would give | 10 A. Yes. 11 you instructions during the course of the day. ll Q. And who traveled with hin? 12 A. Through his assistant. 12 A. The three pilots and some guests. 13 Q. And his assistant was whom? 13 Q. What do you mean by guests? 4 A. Sarah Kellen. 14 A. He will have some friends from Harvard, 15 Q. But you didn't view her as your 15 he will have -- well, very important people that, 16 supervisor? 16 you know, friends, acquaintances from New York or 17 ‘A. She take orders from Mrs. Maxwell but she | 17 Europe because I was just told the number of 18 will tell me, Alfredo, we need to buy this, we 18 people was coming on the plane. 19 need to do this, and so and so was coming. [ 19 Q. Were there people who were employed by 20 couldn't talk directly to Mr. Epstein. 20 him who came regularly? 21 Q. Okay. So any communications from Mr. ae A. Yes. 22 Epstein always came through Ms. Kellen? 22 Q. And who would they be? 23 A. Or from the office in New York. Lesley, a3 A. Like I said, they were the pilots, Larry 24 his secretary, or somebody else, the comptroller, 24 Bisosky, George, and I don't remember the flight 25 the architect, any lawyer. 25. engineer, and he will have two girlfriends. Page 27 Page 29 1 Q. Lawyer, what kind of instructions would 1 Q. The pilot would have two girlfriends? 2 you get from lawyers? 2 A. Mr. Epstein. This is all people coming 3 A. We used to have a lot of time, for 3 in the plane together. 4 instance, the dock construction, you need to have 4 Q. Right. What do you mean by girlfriends? 5 a lot of permits in Palm Beach so they were there 5 A. Friends, you know, that he was always 6 for that reason. 6 having friends that he will befriend in New York, 7 Q. Okay. Now, so you would interact with 7 Idon't know, or some other places. 8 the staff from New York and that would include I 8 But I was just told -- my concern was how 9 think you said Lesley? 9 many people I have to feed, how many cars do I 10 A. Lesley, Bella. 10 need to transport these people from the airport to AL Q. What was Lesley's position? 11 the house, and to arrange accommodations in the 12 A. Lesley is the secretary, secretary to Mr. 12 house. 13. Epstein. 13 Q. What about Sarah Kellen, did she travel 14 Q._ Okay, Is that Lesley Groff? 14 with him? 15 A. I believe it was, I don't remember the 15 A. Yes. 16 last name. 16 Q. So she was on the plane? . Bella, Wi ? t AYES: 18 A. Bella was the assistant comptroller. 18 MR. CRITTON: Form. 19 Q. Anyone else that you dealt with in New 19 BY MR. MERMELSTEIN: 20 York? 20 Q. And Ms. Maxwell? 21 A. Doug Shadow was the architect and he used | 21 MR. CRITTON: Form. 22 to come to the house in a regular basis because we | 22 THE WITNESS: No, she will have different 23 used to have a lot of projects going on. 23 plane. 24 Q. Okay. Would you get advance notice when [24 BY MR. MERMELSTEIN: 25 Mr. Epstein was going to arrive in Palm Beach? 25 Q. Okay. 8 (Pages 26 to 29) Kress Court Reporting, Inc. 305-866-7688 71145 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000254 GIUFFRE000942

Case 18-2868, Document 283, 08/09/2019, 2628241, Page381 of 883 Page 70 Page 72 1 in cash as opposed to check? 1 A. Not him. Iwill drive anybody else but 2 MR. CRITTON: Form. 2. he would rather eat at home. 3 THE WITNESS: I was told to pay them 3 Q. So you would drive house guests to 4 cash, sir. 4 restaurants? 5 BY MR. MERMELSTEIN: 5 A. Yes. 6 Q. Simply you were told and didn't ask why? 6 Q. And when you did that you would -- didn't 7 A. No, 7 you stay with the car or did you eat with them? 8 Q. Do you recall telling the detective who 8 A. No, I will stay with the car. 9 interviewed you for the police that you thought of 9 Q. So who did you tip? 10 yourself as a human ATM machine? 10 A. If you want to park in front of the it MR. CRITTON: Form. 11 restaurant you got to tip the valet otherwise 12 THE WITNESS: Yes. 12 you're taking one of the spots. 13. BY MR. MERMELSTEIN: is Sometimes I used to take -- I'm sorry. 14 Q. You recall saying that? 14 Aviation, you know, you need to go to aviation and 1s MR. CRITTON: Form. 15 help those guys move yaur cars around, you need -16 THE WITNESS: Because I always had cash 16 they carry luggage, so I used to tip those too. 17 in my pocket. 17 Q. That would be when you picked up or 18 BY MR. MERMELSTEIN: 18 dropped off Mr. Epstein. Correct? 19 Q. And why was there always cash in your 19 A. Yes. 20 pocket? 20 MR. MERMELSTEIN: We'll mark this as an 21 A. That was part of my job to have, you 21 exhibil, composite exhibit. 22 know, for emergencies or paying somebody cash. 22 (Composite Exhibit 1 was marked for 23 Q. Okay. What kind of emergencies? 23 Identification.) 24 A. It's hard to say. I was supposed to put 24 MR. CRITTON: Just out of curiosity, on 25 cash on each Mercedes Benz on each ashtray. The |25 depositions are we going to use instead of Page 71 Page 73 1 idea behind this is you get stranded nobody accept | 1 doing plaintiff and defendant designations 2. credit card or check you have cash. 2 do you just want to run them one, two, 3 Q. How much did you leave in the ashtray? 3 three, four? 4 A. 300. 4 MR. MERMELSTEIN: That's fine with me as 5 Q. And did you ever have to replenish that 5 long as we remember where we left off. 6 money? 6 MR. CRITTON: Well, are we going to do it 7 A. Yes. 7 consecutive with all of the depositions? 8 Q. Because the Mercedes was stranded? 8 I'm okay with that if someone can keep track 9 A. No, because when Mr. Epstein will leave I 9 of that. 10 have to collect that money because I will send the 10 MR, EDWARDS: I've had that go wrong 11 cars to the car wash so to avoid that money being dl before, especially when we have some parties 12. stolen we used to keep track, you know, when to 12 who aren't here, such as Mr. Garcia, he's 13 retrieve that money and then when he's coming put | 13 going to join depositions, we have to start 14 it back there again. 14 at 27 or whatever. 15 Q. So you use cash for that purpose and you 15 MR. CRITTON: For each deposition one 16 also use cash to pay the masseuses. Correct? 16 through whatever without necessarily giving yy A. Yes. T i ; 18 Q. Did you use cash for any other purpose? 18 BY MR. MERMELSTEIN: 19 A. Car wash for the guy who used to came to 19 Q. Mr. Rodriguez, I've marked as Exhibit 1 a 20 the house and wash all the cars. Tipping 20 composite document which includes four per page of 21 sometimes for getting a good spot in the 21 what appear to be message slips. 22 restaurant you have to have cash, something like 22 First of all let me ask you, let me 23 that. 23. direct your attention to the first page of this 24 Q. Okay. Would you drive Mr. Epstein to a 24 exhibit. And the upper left message has initials 25 restaurant? 25 at the bottom. Is that correct? 19 (Pages 70 to 73) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000265 GIUFFRE000953

Case 18-2868, Document 283, 08/09/2019, 2628241, Page382 of 883 Page 74 Page 76 a A. Yes. 1 and he told you he owned a modeling agency? 2 Q. Are those your initials? 2 A. Yes, sir. 3 A. Yes. 3 Q. Anything else he told you? 4 Q. And was it the household policy to 4 A. He spoke, you know, five, six languages, 5 _ initial messages when they were taken? 5 always speaking Spanish, Italian. 6 A. Yes. 6 Q._ Did the girls who were -- you know, who 7 Q. Okay. You were instructed to do that? 7 travelled with Mr. Epstein, were they from his 8 A. Yes. 8 agency? 9 Q. Who instructed you to do that? 9 MR. CRITTON: Form, 10 A. Ms, Maxwell. There was a manual, sir, in 10 THE WITNESS: I don't know, sir. 11 the house, we had to follow the instructions of 11 BY MR. MERMELSTEIN: 12 the manual. 12 Q. You didn't discuss that? a Q. There was -- okay. 13 A. No. 14 A. Estate manager, household manager for al| | 14 Q._ Let's look at the message next to it. 15. the houses, so I will abide to that, you know, so 1s MR. CRITTON: Still nn page one? 16 I take message with my initial, the time, who 16 MR. MERMELSTEIN: Still on page one. 17 called. 17 BY MR. MERMELSTEIN: 18 Q. So there were all sorts of policies and 18 Q. It appears the one under it is to the 19 procedures in this manual? 19 same person. Is that correct? Who is that? 20 A. Yes. 20 A. Alicia. 21 Q. Who wrote it? 21 Q. Who is Alicia? 22 A. It was the estate manager for all the 22 A. Idon't know, sir. Please tell Jeffrey 23 properties and so I was -- 23. that I called so I just wrote the name. 24 Q. Who was the estate manager for all the 24 Q. Now, some of these messages if you look 25 properties? 25 through appears to be a different handwriting and Page 75 Page 77 1 A. Inever met him, sir, he was fired before 1 there is no signature on the bottom. 2 Icame along. 2 A, That's not mine, I don't know who's that 3 Q. But you don't remember his name? 3 is, sir. 4 A. No, sir. 4 Q. Ithought you said earlier you were the 5 Q. And you remember one of the things that 5 one who was responsible for taking messages. 6 said in this manual was that every message has to 6 A. Exactly, yes, I was, sir. 7 be signed? 7 Q. But there were other people who took 8 A. Yes. 8 messages as well? 9 Q. I'm not necessarily going to go through 9 A. Maybe this is after or before my time, 10 every single message. Let me go back to the one 10. sir. 11 on the upper left on the first page. It's from il Q. Okay. Because there is no date on it. 12 Jean-Luc. Is that correct? 12 A. Lused to put my dates and I know I used 13 A. Yes, sir. 13 to do that all the time, but you know. 14 Q. Who is Jean-Luc? 14 Q. These style of message pads. It wasa 15 A, He had modeling agency. 15 pad. Correct? 16 Q. How do you know that? 16 A. Yes. 17 A. He gave me his card, sir. 17 Q.Ant this is the otc fashion message pa —_-—— 18 Q. Was he a frequent guest at the house? 18 that it's like duplicate? 19 A. Yes, sir. 19 A. Exactly, the original stays with the 20 Q. Did he stay over? 20 spiral. 2i A. Sometimes he will stay, sometimes I will 21 Q. Okay. So there was a spiral notebook? 22. drive him to Miami. 22 A. Exactly. 23 Q. Do you recall his last name? 23 Q. And you would write the message on the 24 A. No, sir. 24 top copy and then you would take that out and put 25 Q. And so you had a conversation with him 25 it on the counter in the kitchen? L 20 (Pages 74 to 77) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000266 GIUFFRE000954

Case 18-2868, Document 283, 08/09/2019, 2628241, Page383 of 883 Page 150 Page 152 1 Q. You had a laptop? 1 Q. The girls who came to the house for 2 A. No, it was desktop. 2. massages, did you ever call a cab to bring any of 3 Q. Okay. So you had your own desktop in the 3. the girls home? 4 staff house? 4 A. Probably on a few occasions. 5 A. Yeah. Exactly. 5 Q. So is it your understanding that they 6 Q. And you don't know what was -- what was 6 would have arrived by cab as well? 7 the files in that computer versus on the other 7. MR. CRITTON: Form, 8 computers? 8 THE WITNESS: Yes. 9 A. No, sir. 9 BY MR, MERMELSTEIN: 10 Q. Did you ever see any pornography on any 10 Q. And how would that come about, were you 11 of the computers? 11. given instructions to call a cab by anyone? 12 A. No, sir. 12 A. No, I would call the cab, the taxi. 13 Q. Are you sure about that? 13 Q. How did you know a cab needed to be 14 A. Pornography as in sexual acts, no. 14 called? 15 Q. Pornography as in naked people, men or 1s A. Because Sarah would tell me can you get 16 women. 16 mea taxi. 17 A. Yeah, there were some. 17 Q. So when the girl was finished what she 18 Q. Okay. And describe to me what that was. 18 was doing Sarah would come to you and say -19 A. They were like models. 19 A. She would call me. 20 Q. And where were those in the computer? 1 20 MR. CRITTON: Form. 21 mean, how did you access that? 21 BY MR. MERMELSTEIN: 22 A. They were in the files and some of it 22 Q. She would call you? 23 in -- you mean which file they were, what wes your | 23 A. Yes. 24 question? 24 Q. Okay. You would be in the guest house at 2s Q. Where were they in the computer? There 25 the time? Page 151 Page 153 1 were downloaded files on computer? 1 A. Yes. 2 A. They were downloaded, yes. 2 Q. Do you recall having to do that often? 3 MR. CRITTON: Form. 3 A. No, not very often, sir. 4 BY MR. MERMELSTEIN: 4 Q. Did Mr. Epstein keep photograph equipment 5 Q. Okay. There were photographs of naked 5 in the house? 6 women? 6 A. Idon't remember seeing it. 7 A. Models. 7 Q. Do you recall seeing any video equipment? 8 Q. And why do you say models? 8 A. No, sir. 9 A. Because it was like a catalog so you have 9 Q. Do you recall any video or photograph 10 models, you know. 10 equipment in the master bedroom? 11 Q. And what was your understanding as a d1 A. No, sir. 12 source of these photos? 12 Q. The models that you saw on the computer, 13 A, [don't know, sir. It was just a 13. did you recognize any of them as having been at 14 curiosity on myself and it was -- it was none of 14 the house? 15 my business but, you know, I just happen to see 15 A. No. 16 them there. 16 Q. The girls who stayed at the house, did ay @. Did these girls appear very young to you [17 it it ? 18 MR. CRITTON: Form. 18 A. Yes. 19 THE WITNESS: No, sir. They were young 19 Q. Many of them? 20 but not underage. 20 MR. CRITTON: Form. 21 BY MR. MERMELSTEIN: 21 THE WITNESS: Some of them. 22 Q. Is there anything in particular that 22 BY MR. MERMELSTEIN: 23 makes you draw that conclusion? 23 Q. Would any of them not speak any English? 24 A. Because they are developed, you know. 24 A. No. 25 It's hard to say, sir, you know. 25 Q. They all spoke English? secs 39 (Pages 150 to 153) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000285 GIUFFRE000974

Case 18-2868, Document 283, 08/09/2019, 2628241, Page384 of 883 Page 166 Page 168 1 written down anywhere? 1 for now we'll call it a massage -- as well as 2: A. No. 2. anybody who brought that person over to the house, 3 Q._ It's my understanding that C. and T. 3 they would both get paid cash. Are you familiar 4 either came to his house alone to visit with Mr. 4 with thal? 5 Epstein or brought other girls in their age group 5 MR. CRITTON: Form. 6 to Mr. Epstein. 6 THE WITNESS: No, 7 Were you familiar with that type of 7 BY MR. EDWARDS: 8 recruitment process of girls bringing other girls? 8 Q. If C. brought another girl over to the 9 MR. CRITTON: Form. 9 house and C. stayed downstairs but this other girl 10 THE WITNESS: Yes. 10 went upstairs with Mr. Epstein, which one would 11 BY MR. EDWARDS: 11 you pay? 12 Q. Can you tell me more about what you know | 12 A. Idon't know because I was told who to 13 about girls bringing other girls that are 13 pay. 14 relatively the same age to come to Jeffrey 14 Q. And Sarah Kellen always told you? 15 Epstein's house and to use your words, havea good |15 A. Sarah tai me pay so and so. 16 time? 16 Q. So if we were going to ask anybody else 17 MR. CRITTON: Form. 17 about the exact method in terms of who would get 18 THE WITNESS: It's hard to know who they 18 paid and for what, who would the people be? I 19 knew. But I think that was -- they feel 19 mean, other than Mr. Epstein who else could we ask 20 better themselves when they're in a group 20 these questions? 21 than going by themselves, but I don't know 21 A. Sarah. 22 somebody recruiting. 22 Q. Sarah Kellen? 23 BY MR. EDWARDS: 23 A. Yes. 24 Q. Okay. And you've talked about, at least 24 Q. She would know this? 25 referred to yourself I believe to the police and 25 A. Yes. Page 167 Page 169 1 as well today as a human ATM machine. Right? 1 Q. What about Ghislaine Maxwell? 2 MR. CRITTON: Form. 2 MR. CRITTON: Form. s THE WITNESS: Something like that. I was 3 THE WITNESS: You're talking about the 4 supposed to carry cash at all times. 4 boss. I don't know. 5 BY MR. EDWARDS: 5 BY MR. EDWARDS: 6 Q. One of the primary reasons why you 6 Q. To your knowledge was Ghislaine Maxwell 7 carried cash was to pay the girls in this age 7 aware of these girls that are in the age group of 8 group of C. and T. for whatever happened at the 8 C.andT. coming to Jeffrey Epstein's house to 9 house. Right? 9 have a good time? 10 MR. CRITTON: Form. 10 MR. CRITTON: Form. 11 THE WITNESS: Yes. 11 THE WITNESS: I have to say something. 12 BY MR. EDWARDS: 12 Mrs, Maxwell called me and told me not to 13 Q. Thal’s a fair statement. Right? 13 ever discuss or contact her again in a 14 MR. CRITTON: Form. 14 threaten way. 15 THE WITNESS: Yes. 15 BY MR. EDWARDS: 16 BY MR. EDWARDS: 16 Q. When was this? z And wi 7 18 example, would bring somebody else to the house, |18 the friends for a job and she told me this, but, 19 did you pay C. as well as whomever she brought to |19 you know, I feel intimidated and so I want to keep 20 the house, pay them both? 20 her out. 21 A. No, I pay only one person. 21 Q. What exactly did she say? First of all, 22 Q. Okay. My understanding, and tell me if 22 was this a telephone call? 23. this is wrong or you can corroborate this, is that 23 A. Yes, she was in New York. 24 Mr. Epstein would pay the girl that was actually 24 Q. She called you on your cell phone? 25 performing whatever was happening in the room -- | 25 A. Yes. 43 (Pages 166 to 169) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000289 GIUFFRE000978

Case 18-2868, Document 283, 08/09/2019, 2628241, Page385 of 883 Page 238 Page 240 1 Cab Company? ah A. Nadia was the number one girlfriend for 2 A. West Palm Beach Taxi. No, it's not 2 Mr. Epstein. Very sweet girl, and she was always 3 Yellow. Could be Yellow, but I don't know. 3. -- she would come over to the house but different 4 Q. Would Mr, Epstein have the names or the 4 girls with her ail the time. 5 list? 5 Q. Okay. But Nadia, that's somebody who 6 A. Probably. 6 lives in New York? 7 MR. CRITTON: Form 7 A. Nadia, I believe, yes, her address is in 8 BY MR. EDWARDS: 8 New York, 9 Q. Anybody else? 9 Q. So how often would she stay at 358 El 10 A. Sarah. 10 Brillo? 11 Q. Sarah would have? 11 A. Very often. 12 A. Yes. 12 Q. Usually every time when Mr. Epstein was 13 Q. In addition to Mr. Epstein obviously 13 there? 14 knowing who's coming to end from the house, would | 14 A. Yes. 15 Sarah also be familiar with the names of the girls 15 Q. And she would for the mast time fly an 16 and who they were? 16 the plane with Mr. Epstein? 7 A. Yes. 17 A. Yes. 18 Q. In addition to Sarah and Mr. Epstein 18 Q. And it would be her and Mr. Epstein and 19 would Ghislaine Maxwell be familiar with the names | 19 oftentimes some other girls? 20 of some of these girls? 20 A. Exactly. al MR. CRLI TON: Form. 2t Q. Where sume points I think earlier when 22 THE WITNESS: Yes, 22 Mr. Mermelstein was asking you questions where 23 BY MR. EDWARDS: 23. there was some confusion was we're talking about 24 Q. Are these names kept in a database in a 24 two different sets of girls, the girls that would 25 computer system? 25 come over and be labelled masseuses from the Palm Page 239 Page 241 1 A. Could be. 1 Beach area, and the girls that would fly on the 2 MR. CRITTON: I'm sorry, did you say 2 plane with Mr. Epstein and Ms. Marcenacova. 3 could be? 3 So, what I'm asking you is what, if any, 4 THE WITNESS: Yeah. 4 involvement did Nadia Marcenacova have with the 5 MR. CRITTON: Move to strike as 5 girls that would arrive and be labeled as 6 speculation. 6 masseuses behind closed doors with Mr. Epstein? 7 BY MR. EDWARDS: 7 MR. CRITTON: Form. 8 Q. When you say could be, why do you say 8 THE WITNESS: He was the second -- the 9 that? 9 first role was Sarah and she was always -10 A. Because there were too many and they were | 10 Nadia is a very shy person so she will be in 11. very organized and there is nothing you write on a 11 the background. 12 piece of paper. 12 BY MR. EDWARDS: 13 Q. When you say they were very organized, 413 Q. Did you ever know of Nadia Marcenacova to 14 are we talking -- 14 engage in -- to be in the room with Mr. Epstein 15 A. Mr. Epstein and Sarah. 15 while any of these young girls were up there? 16 Q. Anybody else beside Mr. Epstein and 16 MR. CRITTON: Form. [17 Sarah, I quess beside Sarait thet woutd do te” 17 THE WITNESSYeatr18 scheduling to coordinate the times these girls 18 BY MR. EPSTEIN: 19 would come to the house? 19 Q. How often do you remember Nadia and Mr. 20 A. I'm sorry, anybody else you say? 20 Epstein being in the room with any of these young on Q. Right, aside from Sarah. 21° girls? io A. No, no. 22 A. Iwould say most of the time. 23 Q. And do you know what role, if any, Nadia 23 Q. Nadia would go up there too? 24 Marcenacova ever played in any of what would go on | 24 A. Yeah. 25 behind the bedroom door with Mr. Epstein? 25 Q. Did you ever believe that Nadia was 61 (Pages 238 to 241) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000307 GIUFFRE000996

Case 18-2868, Document 283, 08/09/2019, 2628241, Page386 of 883 Page 250 Page 252 1 Q. Would you know the name if I said it? 1 A. We discuss -- he asked me a lot of 2 A. Yeah. 2 questions, obviously he didn't know a lot of a Q. Bill Riley? 3. things about the case, and I told him who I was, 4 A. Yes. 4 what I did in the house. 5 Q. Okay. Have you ever spoken with an 5 Q._ He told you he didn't know a lot about 6 investigator Paul Lavery? 6 the case? - A. Could be, I'm not sure, Fi A. No, no, no. He asked me questions about 8 Q. Okay. So Bill Riley came by your house 8 sol got the feeling that Mr. Critton didn't know 9 personally? 9 as much as other lawyers. 10 A. Yes. 10 Q. Okay. Did you tell him what you told us 11 Q. And how tong did you meet with him? 11 here today? 12 A. Five minutes. He gave me his card, he 12 A. No. He asked me tell the truth, you 13 gave me Mr. Critton telephone number, he said 13 know, just go over there, you know, he advise me 14 don't talk to Mr. Goldberger. 14 like you're on your own, Alfredo, just tell the iS Q. Did he tell your why you should call Mr. 15 truth, you know. He didn't give me any advice. 16 Critton? 16 He paid for my gas. Thank you very much. Ly: A. No. Iassume that he was not on the case 17 And that's it, you know. 18 anymore, butI didn't ask questions but -- 18 The main thing | wanted to have a lawyer 19 Q. You assumed that who wasn't on the case 19 on my side but then I keep going to the first 20 anymore? 20 instance when my wife told me you don't need a 21 A. Mr. Guldberger, Jack Goldberger. 21. lawyer, and I'm here today to say that, I'm here, 22 Q. Okay. But what I'm asking you, I guess, 22 I'm speaking the truth. 23. is did this investigator, Mr. Riley, tell you why 23 Q. Okay. You mentioned there were five or 24 it was important for you to call any attorney 24 six computers in the house? 25 that's associated with Mr. Epstein, why was that 25 A. Yes. Page 251 Page 253 1 important? 1 Q. And do you know what happened to the 2 A. He didn't say that. He didn't say that. 2 computers? 3 He just said that get in touch and that's it. 3 A. No. 4 Because I said what am I going to do, because I 4 Q. You don't know where they are? 5 said I thought this was -- you know, but I didn't 5 A. (Shakes head.) 6 know I was going to be subpoena. And like I said 6 Q. Nobody has told you? 7 in the beginning of this deposition, I don't have 7 A. No. 8 an attorney so I don't have money, first of all, 8 Q. You also mentioned there were photographs 9 to pay for an attorney. First of all, I don't 9 in the house? 10 think I'm in trouble, but every time you hear high 10 A. Inthe computers in the files. 11 powered lawyers you feel intimidated so I said, 11 Q. Okay. But there were also still 12 listen, what am I going to do, and that was my 12 photographs around the house? 13 basic question. 13 A. Oh yes, yes. 14 Q. Okay. So then you spoke with somebody at | 14 Q. Some of the girls have made the 15 Mr. Critton's office and arranged to meet with him 15 allegation that there were photographs of them 16 personally? 16 nude in the house. Do you remember seeing that? 18 down with his assistant, the three of us. 18 one frame with probably 15 pictures, small 19 Q. So it was Mr. Critton, yourself, and 19 pictures. 20 somebody else? 20 MR. CRITTON: Repeat the question back. 21 A. Yes, 21. BY MR. EDWARDS: 22 Q. And you sat down for another two hour 22 Q. Okay. Some of the girls that have 23 period of time? 23 lawsuits against Mr. Epstein with allegations 24 A. Yes. 24 similar to the allegations that C. and T. have 25 Q. And what did you go over in that meeting? |25 made, which is that they were underage when Mr, 64 (Pages 250 to 253) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000310 GIUFFRE000999

Case 18-2868, Document 283, 08/09/2019, 2628241, Page387 of 883 Page 254 Page 256 1 Epstein was engaging in sex or sex acts with them, | 1 those photos? 2. also say that they have seen pictures of 2 A. One was a Columbian lady and one was -3 themselves in frames in Mr. Epstein's house naked. 3. one from Spain, beautiful girls, that, you know, * A. In his closet. 4 but they were not -- not the ones the girls we're S Q. Other than the picture -- and these are 5 talking about here. 6 girls who are making the allegation that they were 6 Q. Okay. When you were hired were you hired 7 underage and there were pictures of them nude in 7 by Mr. Epstein or were you hired by one of his 8 his house. 8 companies? 9 A. Ididn't see pictures of C. there. iS A. Mrs. Maxwell. 10 Q. I'm not talking about C. I'm saying 10 Q. So it was -- was it a company owned by 11 other girls that were underage or have made 1. Mrs, Maxwell? 12 allegations that they have seen pictures of 12 A. Not directly. My paycheck was Jeffrey 13 themselves in Mr. Epstein's house, 13 Epstein. I mean, I was hired by Mr. Epstein 14 MR. CRITTON: Form. 14 but -15 BY MR. EDWARDS: 15 Q. Okay. I just understood you to say you 16 Q. Where would those photos have been, or 16 were hired by Mrs. Maxwell. 17. did you see them? 17 A. Exactly, she told me you're hired but 18 A. Yes, I see them inside his closet. 18 you're going to get paid by Mr. Epstein. 19 Q. It's one mosaic? 19 Q. And he wrote you personal checks? 20 A. Yes, one mosaic. 20 A. No. The checks that came from New York, 21 Q. Other than there did you see any of these [21 Jeffrey Epstein Companics. 22 pictures of young girls nude anywhere else in the 22 Q. It was out of his company? 23 house? 23 A. Yes. 24 MR. CRITTON: Form. 24 Q. Which company; do you know? 25 THE WITNESS: Nude with an art, yes, but 25 A. 456 Madison Avenue. It's next to the New Page 255 Page 257 1 not pornography. You know, I saw them, they 1 York Palace now. 2 were all over the place. For instance, in 2 Q. The name of the company is 456 Madison 3 the back only showing part of the rear, you 3 Avenue? 4 know. 4 A. No, no, it's -- I got it on the tip of my 5 BY MR. EDWARDS: 5 tongue. Something like Caribbean or island 6 Q. But the photographs that I'm concerned 6 something investments, something like that. 7 with -- 7 Tf you call Lesley, her secretary, she 8 A. Not frontal pictures. 8 will tell you exactly. Because they answer the 9 Q. The photographs I'm concerned with are 9 phone like that, you know. 10 photographs of these West Palm Beach girls that 10 Q. What's Lesley's number? 11 were labeled as masseuses that are being displayed | 11 A, Lesley, I don’t have it. I can find out 12 around the house anywhere in some state of 12 for you. 13 undress 13 Q. Do you think you could get Lesley's 14 MR. CRITTON: Form. 14 number for us? 15 THE WITNESS: No, I don't remember that. 15 A. Yes. It's in Manhattan. 16 BY MR. EDWARDS: 16 Q. Does she work for this company in t @.—Okay-The omy girs that =the onty- +7 Manhattan? 18 photograph that you remember of young girls nude | 18 MR. CRITTON: Form. 19 was in a mosaic that is in his closet? 19 THE WITNESS: Manhattan, yes. 20 A. Yes. 20 BY MR. EDWARDS: val Q. Nothing that you remember that was on 2t Q. If the check was issued did Jeffrey 22 display? 22. Epstein actually sign it himself? | 23 A. Downstairs, yes, but they were not these 23 A. No, it came through the comptroller. | 24 girls, they were somebody else. 24 Q. Who was the comptroller? 25 Q. Okay. Do you know who was -- who were in | 25 A. Bella was the assistant comptroller and 65 (Pages 254 to 257) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000311 GIUFFRE00 1000

Case 18-2868, Document 283, 08/09/2019, 2628241, Page388 of 883 Page 266 Page 268 1 BY MR. LANGINO: 1 THE STATE OF FLORIDA, ) 2 Q. Are you currently in fear of Mr. Epstein? 2 COUNTY OF DADE. ) 3 A. Not at this particular moment but it's 3 4 something I have lo be worry about, yes. 4 : 5 Q. Are you personally afraid of criminal 5 I, the undersigned authority, certify 6 prosecution? 6 that ALFREDO RODRIGUEZ personally appeared before 7 A. No. 7 me on the 29th day of July, 2009 and was duly 8 Q. Do you believe that you did anything eo anor 9 illegal? 2 10 A. Illegal, no. i (i aa my hand and official seal this i MR. LANGINO: I have no turther ie ee 12 questions. Thank you. 13 13 MR. CRITTON: We're going to break in ia 1% about 15 minutes. Do you want to start and 15 : go for 15 minutes or do you want to -- it's MICELLE PAYNE, Court Reporter Up to your 16 Notary Public - State of Florida 7 MS. EZELL: I'll start. 7 ee 18 MR. WILLITS: When are we going to quit, 18 19 folks? 19 20 MR. CRITTON: In 15 minutes. 20 21 THE VIDEOGRAPHER: Might as well change | 21 22 tapes. 22 23 MR, EDWARDS: Bob has to get back so 23 24 we've agreed we're going to come back some =| 24 25 other time. 25 Page 267 Page 269 1 MR. WILLITS: Why don't we just stop now? a SER TUOA TE 2 MS, EZELL: Okay. The State Of Fiorida, 3 MR. EDWARDS: Rather than you start. ; COUR OF Pegs: ) + MS. EZELL: Yeah, I won't get very far. 5 1, MICHELLE PAYNE, Court Reporter and 5 MR EDWARDS: Sory to dothis wth you, | , Minehead 6 we didn't finish. and did stenographically report the videotaped 7 MR. CRITTON: So we're stopped? 7 eepston of ALFREDO RODRIGUEZ: at Fev of 8 MR. EDWARDS: We're stopped. 8 foregoing pages, numbered from 1 to 269, 9 THE VIDEOGRAPHER: Off the record. ; inclusive, are 2 true and sone transcription of 10 (Thereupon, the videotaped deposition was [ig ynamsirowrty that sau videotaped 11 adjourned at 5:30 p.m.) ceposition was taken at the time and place 12 ree e 11 hereinabove set forth and that the taking of said videotaped deposition was commenced and completed 13 12 as hereinabove set aut, 3 1 Turther certify that {am not 14 atomey of coool of any ofthe gates, nr a 1s 14 Ta relative or employee of any attorney or 16 counsel of party connected with the action, nor am 15 _Ifinancialy interested in the action. 17 T THe Toregorng CErMNCATION OF TNS 18 transcriot does not apply to any reproduction of 17 the same by any means unless under the direct. 19 control and/or direction of the certifying 8 renorter. oe 19 7 =SqreD ths 3ist day of Juy, 2009, 20 Eee ni ——— e ~THICHELLE PAYNE, Cour Reporter 2 24 23 ” 25 68 (Pages 266 to 269) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000314 GIUFFRE00 1003

Case 18-2868, Document 283, 08/09/2019, 2628241, Page389 of 883 I al Page 270 a UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 2 3 JANE NOE NO. 2, CASE NO: 08-CV-80119 4 Plaintiff, 5 Vs. 6 JEFFREY EPSTEIN, 7 Defendant . 8 r JANE DOE NO>3, CASE NO: 08-CV-80232 9 Plaintiff, 10 “i, CONDENSED 1l a JEFFREY EPSTEIN, 12 Defendant. 43 f 14 JANE DOE NO. 4, CASE NO: 08-€¥V-80380 is Plaintiff, 16 Vs. 17 JEFFREY EPSTEIN, 18 Defendant . 19 JANE DOE NO. 5, CASE NO: 08-CV-80381 20 Plaintiff, Pal Vs 22 JEFFREY EPSTEIN, 23 Defendant. Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000315 SSGFNAREO 1004

Case 18-2868, Document 283, 08/09/2019, 2628241, Page390 of 883 Poge 271 Page 273, 1 JANE COE NO. 6, CASE NO: 08-Cv-80994 1 IN THE CIRCUIT COURT OF THE 15TH 3 é Piointiff, JUDICIAL CIRCUIT IN AND FOR: sw 2 PALM BEACHG@:NEY, FLORIDA Se 3 CASE NO, S02088EAU3731900XM8 AB 5 Defendant, 4 ee Sy 6 BB, JANE DOE NO. 7, (CASE NO: 08-C¥-80993 5 7 Plaintiff, Plaintiff, 6 8 Vs. Vs. 7 i 9 JEFFREY EPSTEIN, ag UTTREY ErSrEIN, | 10 \ Defendant. Defendant, | u Op. Sa ay | 12 MA, CASE NO: 08-Cv-80811 10 13 Plait, it 14 Ws. 16) Deraneen 3 North Miami, Florida yoo ‘August 7, 2009 JANE OE, CASE NO: 08-Cv-80893 M4 4:15 p.m. to 5:30 p.m. 18 15 Paint, 16 CONTINUED 19 7 VIDEOTAPED ve 10 DEPOSITION 2 errReY EPSTEIN 8 of a j 20 ALFREDO RODRIGUEZ Defendant. a 22 22 taken on behalf of the Plaintiffs pursuant 23 23. toa Re-Notice of Taking Continued Videoteped 24 24 Deposition (Duces Tecum) 25 2 Page 272 Page 274 1 JANE DOE NO. II, (CASE NO: 08 CV 80469 3 ADPEARANCES: 3 eee 7 BSaEsinige 4 JEFFREY EPSTEIN, 4 18205 Biscayne Boulevard 5 Defendant. Suite 2218 / 5 Miami Florida 33169 6 Attorney fo pe, Doe 2, JANE DOE NO. 101 CASE NO: 08-CV-80591 : Sande z 8 ROTHSTEIN ROSENFELDT ADLER Plaintiff BY: BRAD J. EDWARDS, ESQ,, and 8 * CARA HOLMES, ESQ. Vs. Las Olas City Centre 9 10 Suite 1650 401 East Las Olas Boulevard JEFFREY EPSTEIN, uw Fort Lauderdale, Florida 33301 10 ‘Attorney for Jane Doe and E,W. Defendant. wz and LM, l 13 pteevs “ PODHURST ORSCCK wy (0. 102, CASE NO: 08-CV-80656 Se eaneu erelty este 3 15 25 West Flagler Street 14 Vs. Suite £00 15 JEFFREY EREETS) 16 Miami, Florio 33130 16 Defendant, pe ‘Attorney for jane Doe TOT and 102. af # Vv LEOPOLD-KUVIN 18 19 BY: ADAM J. LANGINO. ESQ. 19 2925 PGA Boulevarc 20 20 Suite 200 a Palm Beach Gardens, Florida 33410 21 Attorney for 8.3. 2 ze 23 7 24 24 25 25 2 (Pages 271 to 274) Kress Court Reporting, Inc, 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000316 GIUFFREOU 1005,

Case 18-2868, Document 283, 08/09/2019, 2628241, Page391 of 883 Paye 299 Page 301 1 A. I don't remember, Ma'am. He came from 1 video, even phones. 2 New Albany, Ohio. 2 Q. Would he also repair the televisions if 3 Q. From New 3 they needed work? 4 A. New Albany, Ohio. 4 A. No. 5 Q. New Albany, Ohio. Did he have his own 5 Q. No. Did you have any kind of intercom 6 business? 6 system in the housc? 7 A No; tie worked for Mr. Epstein. He will ie A. Yes, ma'am, 8 maintain all the computers. 8 Q. And what kind of yateiwas that? 9 Q. Was he theie everyday? 9 A. Itwas standard office equipment, Lucid 10 A. No, ma’am, 10 Technologies maybe, but it was an intercom like we il Q. Do you know whether at that time Mr. 11 using right now. 12 Epstein had an office in Palm Beach? 12 MS. EZELL: Just let the record reflect 13. A, Not outside tie house, no, 13 that the witness pointed to the telephone on 14 Q. Do you have any knowledge of whether 14 the table that has a speaker phone. 15 not.the video equipment was -- and I deivehhcw THE WITNESS: Yes, ma'am. 16 ‘the technical term, forgive me, but wes it the 16 BY MS, EZELL; 17 kind of equipment that would record for a certain 7 Q. And did you use that in your work? 18 amount of time and then record over that film? 18 A. Yes, ma'am. 19 A, [don't know. 19 Q. And what did you use it for? 20 MR. CRITTON: Form. 20 A, Mr. Epstein used to page me when he 21° BY MS. EZELL: 21 needed me. 22 Q. You don't know? 22 Q. Did you have one of those phones. in the 23 A. No, ma'am. 23 «kitchen? 24 MR. CRITTON: Just for clarification, I 24 A. Yes, ma'am. 25 may have misunderstood, but I thought he 25 Q. And was there one out in the staff haw Page 300 Page 302 1 said he didn’t even know the video equipment 1 as well? 2 existed until he read the FBI report. 2 A. Yes, ma'am. 3 MS. EZELL: He said he didn't know that 3 Q. Do you know where others were in the 4 it was upstairs and downstairs, I believe, 4 house? 5 MR. CRITTON: I thought he said he didn't 5 A. Probably have like 15 phones. We used to 6 know that it even existed. 6 have three in the staff house, one i the cabana, 7 MS, EZELL: I may be wrong, 7 two in the master bedroom, one in each room, 8 BY MS. EZELL: 8 kitchen, dining room, Mrs. Maxwell's office, the 9 Q. Did you know it existed before you read 9 garage. 10 the FBI report? 10 Q. Where was Mrs, Maxwell's office? i A. No, ma'am. 11 A. Under the stairs next to the | 12 Q. I'm sorry, then I was wrong. 12 Q. Can you give me s 13 How did you know then that the young 13 space that was? 14 technician from Ohio maintained the computers and | 14 A. It was probably -- we change the floor. 15 the video equipment? 15 Twelve by five, something like that. 16 A. Because we used to request -- there were 16 Q. And was the computer equipment in that 17” always problems with the computers so he came to | 17 space? 18 the house and he was the programmer. It was very | 18 A. Yes, ma'am. 19 sophisticated. 19 Q. Do you know whether Ms. Maxwell kept the 20 MR. CRITTON: Form to the last question, 20 names and telephone numbers of the girls who came}; aL move to strike the answer as nonresponsive. 21 to do massages? i 22 BY MS. EZELL: 22 A, Yes, ma'am. 23 Q. How did you know then that hegesitwined | 23 MR. CRITTON: Form, 24 the video equipment as well? 24 “BY MS. EZELL: 25 25 A. Because he was in charge of computers, = Do you know that because you saw the 9 (Pages 299 to 302) Kress. Geat-Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami,Reach. FL 33141 Hert a NON PARTY (VR) 000323 GIUFFRE001013

Case 18-2868, Document 283, 08/09/2019, 2628241, Page392 of 883 Page 303 Page 305 1 names and phone numbers? 1 computer? 2 MR. CRITTON: Form. 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, ma'am. 3 THE WITNESS: Yes, ma'am. 4 BY MS. EZELL: 4 BY MS. EZELL: ey Q. Do you know if she kept pictures of the 5 Q. And did she generally have phone numbers 6 girls an the computer? 6 for those girls? 7 A. Yes, she did. 7 A. Yes, ma'am, 8 Q. And you know that as well because you 8 Q. And were they generally picturesiaytius.~ 9 happen to see them? 9 girls? 10 A. Yes, ma'am. 10 MR. CRITTON: Form. il MR, CRITTON:; Form to the last two it “E WITNESS: No, ma'am. 12 questions. 12 BY MS. EZELL: 13. BY MS. EZELL: 13 Q. And did Ms. Maxwell have a list of the 14 Q. Were they similar to the pictures that 14 girls who came to give massages? 15 Ms, Kellen had on her computer? 45 MR. CRITTON: Form. 16 MR. CRITTON: Form. 16 THE WITNESS: Yes, ma'am. 17 THE WITNESS: Yes, ma'am. 17, BY MS, EZELL: 18 BY MS. EZELL: 18 Q. Did she have telephone numbers generally? 19 Q. Did the pictures that they kept there 19 A. Yes, ma'am, 20 look like pictures that were posed? 20 MR. CRITTON: Form. 21 A. ‘Eeiiseere more casual. 21 BY MS, EZELL: 22 Q. Did they look as though the person being 22 Q. Were there pictures on her computer of 23 photographed knew that they were being 23 the girls who came to give massages? 24 photographed? 24 MR. CRITTON: Form. 25 MR. CRITTON: Form. 25 BY MS. EZELL: Page 304 Page 306 1 THE WITNESS: No, ma'am. 1 Q. Ms. Maxwell I'm talking about. 2 BY MS. EZELL: 2 A. Yes, ma'am, = Q. And what can you tell me about that, what 3 Q. And were those pictures the more casual 4 lead you to draw that conclusion? 4 ones that you described when I asked whether or 2 A. They were probably taken in parties in 5 not the subject looked as though she knew she was 6 big reception or banquet. 6 being photographed? z MR. CRITTON: Let me offer as a 7 MR. CRITTON: Form. 8 suggestion, not that you have to accept or 8 THE WITNESS: I'm sorry, can you repeat? 9 that you would, you're using the term young 9 BY MS. EZELL: 10 girls generically, he has probably seen 10 Q. Yeah. The pictures of the young girls i many, many young girls, there was no -- 11 who came to the house to give massages triat were 12 you've used it interchi jth just 12 on Ms. Maxwell's computer, did they appear to have 13 young girls aie “ may have 13. been taken when the girls knew they were being 14 come to -- purportéd'te Give a massage and, 14 photographed? 15 therefore, that may be a different answer, 15 MR. CRITTON: Form. 16. 36 that's part of my form objection. 16 THE WITNESS: I don't think they knew 17 “MS-EZELE Okay, thank-you; 17 i : 18 BY MS, EZELL: 18 BY MS. EZELL: 19 Q. When I asked you about Ms. Kellen whether | 19 Q. I believe you said they were more casual 20 she had a list of the girls and telephone numbers, | 20 pictures. 21 I think I asked about those girls that came to al A. Yes, ma'am. 22 give massages, but let me go back ant lushask it % fe Did you notice any nude photographs in 23 that way. 3 pi@ures? zt Did you notice that Ms, Kellen had a list 24 A. Yes, ma'am. 25 _ of the airls that came to give massages on her 25 MR. CRITTON: Form for the last question, Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000324 GIUFFRE001014 10 (Pages 303 to 306)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page393 of 883 Page 471 1 THE STATE OF FLORIDA, ) 2 COUNTY OF DADE. ) 3 4 5 I, thé undersigned authdrityy certify 6 that ALFREDO ROSAS EZ personally appeared before 7 me on the 7th day of August, 2009 and was duly 8 sworn. 9 10 WITNESS my hand and official seal this ; 11 18th day of August, 2009. ‘ 12 13 14 15 MICHELLE PAYNE, Court Reporter 16 Notary Public - State of Florida 7 18 19 20 21 22 23 24 25 Page 472 1 CERTIFICATE The State Of Florida, 4 3 County Of page, ? $1, MCHELLE PAYNE, Cout Reporter ard Notary Publi in ard for the State of Florida at large, do hereby certify that I was authorized 10 and did stenagraphically report the deosition of ALFREDO RODRIGUEZ; that a review of the tanscript was not requested; and that wie foregoing pages, numbered froin 270 to 472, inclusive, are @ true and correct transcription of my stonagraphic notes of sad deposition. | further certify that said deposition was taken at the time end place herenabove set forth ‘and that the taking of sad deposition was ‘ornmveruen eind Cuinpleted ey hereluve se UU | funher ceaify that Lam not an ‘gttomey ¢ counsel of any of the arties. nor am. 1 a relative or employee of any attorney or ‘counsel of party connected with the action, nor arm | fiwancianty interestes in the action, TES PREG COST TUT transcript does not apply to any reproduction of the some by any means unless under the direct control andjor direction of the certifying reporter, DATED this 16th day of August, 2009. 52 (Pages 471 to 472) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000366 GIUFFRE001056

EXHIBIT 22 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page395 of 883 United States District Court For The Southern District of New York Giuffre v. Maxwell 15-cv-07433-RWS Ghislaine Maxwell’s Privilege Log Amended as of August 1, 2016 ***Per Local Rule 26.2, the following privileges are asserted pursuant to British law, Colorado law and NY law. ae OF PARTIES MATTER Ghislaine Maxwell Brett Jaffe. E Communication | Attorney-Client re: legal advice 2011.03.15 Brett Jaffe. Esq. Ghislaine Maxwell Attomey / Client Communication Attorney-Client re: legal advice 2015.01.02 E-Mails Ross Gow Ghislaine Maxwell Attorney Agent / Communication Attorney-Client Client re: legal advice 2015.01.02 E-Mail Ghislaine Maxwell Ross Gow ‘Attorney Agent / Communication | Attorney-Client Client re: legal advice 2015.01.02 E-Mail Ross Gow Ghislaine Maxwell Brian ‘Attorney Agent / Communication | Attorney-Client Basham _| Client re: legal advice 2015.01.06 E-Mail Ghislaine Maxwell Jeffrey Epstein Common Interest Communication Common Interest re: legal advice 2015.01.06 E-Mail Ghislaine Maxwell Jeffrey Epstein. Attorney / Client Communication Common Interest Alan Dershowitz, Esq. re: legal advice 2015.01.10 E-Mail Ghislaine Maxwell Philip Barden, Esq.. ‘Attorney / Client Communication | Attorney-Client Ross Gow re: legal advice 2015.01.10 E-Mail Ghislaine Maxwell Philip Barden, Esq. Client / Attorney Communication Attorney-Client re: legal advice 2015.01.09 - E-Mails Ross Gow Philip Barden, Esq. Agent / Attorney / Communication Attorney-Client 2015.01.10 Client re: legal advice 2015.01.11 E-Mail Ghislaine Maxwell Jeffrey Epstein Common Interest Communication Common Interest re: legal advice 12. 2015.01.11 Philip Barden, Esq. Ross Gow G. Attorney / Agent / Communication Attorney-Client Maxwell | Client re: legal advice 13. 2015.01.11 Philip Barden, Esq. Ghislaine Maxwell Ross ‘Attorney / Agent / Communication | Attorney-Client Gow Client re: legal advice 1 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page396 of 883 14. 2015.01.11 - | E-Mails 1059- Jeffrey Epstein Ghislaine Maxwell Common Interest Communication Common Interest Privilege 2015.01.17 1083 re: legal advice 15. 2015.01.13 E-Mail 1067- Ghislaine Maxwell Jeffrey Epstein Common Interest Communication Common Interest Privilege 1073 re: legal advice 16. 2015.01.13 E-Mail 1069- Philip Barden, Esq. Martin Weinberg, Esq. Common Interest Communication Common Interest Privilege 1073, re: legal advice 10761079 17: 2015.01.13 E-Mails 1068- Philip Barden, Esq. Ghislaine Maxwell Mark Attorney / Client Communication Attorney-Client 1069, Cohen re: legal advice 10741076 18. 2015.01.21 E-Mail 1088- Ross Gow Philip Barden, , Ghislaine Agent / Attorney / Communication Attorney-Client 1090 Maxwell Client re: legal advice 19. 2015.01.21 - | E-Mails 1084- Jeffrey Epstein Ghislaine Maxwell Common Interest Communication Common Interest Privilege 2015.01.27 1098 re: legal advice 20. 2015.01.21- | E-Mails 1099 Ghislaine Maxwell Jeffrey Epstein Common Interest Communication Common Interest Privilege 2015.01.27 re: legal advice 21. 2015.04.22 | E-mail Tpages | Jefirey Epstein Ghislaine Maxwell Common Interest Forwarding Common Interest Privilege message from Martin Weinberg, labeled “AttorneyClient Privilege” with attachment 22. Various E-mails Agent of Haddon, Agent of Haddon, Morgan & Agent of attorney and | Attorney work Attorney Work Product Morgan & Foreman; Foreman; Laura Menninger Attorney product Laura Menninger 23. Various E-mails Mary Borja; Laura Mary Borja; Laura Menninger Attorney Work Attorney work Attorney Work Product Menninger Product product 24. 2015.10.21 - | E-mail Darren Indyke; Laura | Darren Indyke; Laura Menninger Attorneys for par Common Interest | Attorney Work Product; 2015.10.22 chain with Menninger to Common Interest Agreement Common Interest Privilege attachment Agreement 25. 2015.01.06 Attorney/Client Document Attorney Work Product; prepared by Attorney-Client Ghislaine Communication Maxwell at the direction of Philip Barden CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page397 of 883 26. 2015.01.23 Attorney/Client Document prepared by Ghislaine Maxwell at the direction of Philip Barden Attorney Work Product; Attorney-Client Communication CONFIDENTIAL

EXHIBIT 23 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page399 of 883 Expert Report of Professor Terry Coonan, J.D. Pursuant to Federal Rule of Civil Procedure 26(a)(2)(B) Giuffre v. Maxwell Case No. 15-cv-07433-RWS

Case 18-2868, Document 283, 08/09/2019, 2628241, Page400 of 883 international commercial dimensions of the sex trafficking scheme recounted by Ms. Giuffre. It is both factually and legally correct to characterize what Ms. Giuffre experienced as victimization in a sex trafficking conspiracy. Conclusion 4 Virginia Roberts Giuffre’s account appears credible and consistent in its most salient parts with the testimony of other witnesses and with contemporary trends in U.S. sex trafficking. The description of exploitation recounted by Ms. Giuffre, while not the most common sex trafficking scenario (many cases involve even more brutal forms of pimp-driven prostitution) nonetheless is quite consistent with larger patterns of commercial sexual exploitation. The conspiracy in this case was premised upon the exploitation of minors and young women who seem to have had certain identifiable vulnerabilities that rendered them prone to exploitation. The criminal scheme that emerges from the depositions and police reports involved a very calculated pattern of recruiting, grooming, and an attempt to “normalize” the repeated exploitation of its victims. While the accounts of witnesses vary in some of their details, the essential elements of a sex trafficking conspiracy clearly emerge when viewed in the totality of the circumstances that are recounted in the case record. Ms. Giuffre refers to herself at times as a “‘sex slave.” This is not factually incorrect, given her experiences, though current U.S. law might prefer to characterize her as a victim of sex trafficking. Popular understandings of the term “sex slave” might still connote images of violent pimps, white slavery, or of victims chained to a bed ina brothel in the minds of some people. To call Ms. Giuffre a victim of sex trafficking would however very accurately convey the reality that she along with a great many other victims of contemporary forms of slavery are often exploited by the “invisible chains” of fraud and psychological coercion. 20

EXHIBIT 24 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page402 of 883 Expert Witness Report of Dr. Bernard J. Jansen Professor College of Information Sciences and Technology The Pennsylvania State University Regarding the case of: Virginia Giuffre Vo Ghislaine Maxwell (U.S. District Court for the Southern District of New York) 9 September 2016

Case 18-2868, Document 283, 08/09/2019, 2628241, Page403 of 883 I. INTRODUCTION le I have been retained by the law firm of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. to provide expert analysis and opinion on behalf of Ms. Virginia Giuffre in VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. CASE NO. 1:15cv-07433, which is pending in the United States District Court Southern District of New York. IL. QUALIFICATIONS 2. I am a tenured, full professor at the College of Information Sciences and Technology at The Pennsylvania State University, University Park, Pennsylvania, where I have been employed since 2001. I am the Director of the Information Searching and Learning Laboratory at the College of Information Sciences and Technology at The Pennsylvania State University. I am also a principal scientist at the Qatar Computing Research Institute. I was a Senior Fellow at the Pew Internet & American Life Project, which is part of the Pew Research Center, from 2010 through 2012. I was also a University Expert at the National Ground Intelligence Center from 2011 through 2014. Prior to my employment at The Pennsylvania State University, I was a Lecturer in the Computer Science Program at the University of Maryland (Asian Division) for 1 year. Before that I was an Assistant Professor and Lecturer in the Department of Electrical Engineering and Computer Science at the United States Military Academy, a.k.a. West Point, for 3 years. 3. In addition to my academic credentials, my professional experience includes 20 years of practice in the U.S. military, working primarily in a variety of technology-related and leadership positions. 4. Ihave authored approximately 250 academic publications, focusing on the areas of Web data, digital analytics, Web analytics, Web searching, Web search engines, social media analytics, and related areas. Approximately 200 of my publications address aspects of search 2

Case 18-2868, Document 283, 08/09/2019, 2628241, Page404 of 883 analytics, Web analytics, online advertising, search engines, or Web searching. My recent research work focuses on online news analytics, which is the investigation of the online qualitative and quantitative attributes of news stories, along with other digital content. I am also the editor-in-chief of the academic journal Information Processing and Management, and I was previously the editorin-chief for 5 years of the academic journal, Internet Research. I have authored, co-authored, or co-edited four books, including Web Search: Public Searching of the Web (2007), Understanding User — Web Interactions via Web Analytics (2009) and Understanding Sponsored Search (2011). A copy of my complete curriculum vitae, which includes a list of all publications I have authored in the past 10 years, is attached as Appendix A. 5; My fields of professional expertise include web analytics, search engines, web searching, social media, online advertising, and related areas. In the course of my academic career, Ihave worked with a variety of search engines and information searching applications in order to understand user searching behavior on the Web and other environments. For example, as part of my Master’s program in computer science, I designed and coded a text-based search engine. For my Doctorate program in computer science, I developed a program interface for Web search engines and implemented it on the Gigabyte search engine. In subsequent research, I have worked with the Microsoft Internet Information Services (IIS) and Verity commercial searching systems. 6. Concerning user searching behaviors on the Web using web analytics, I have worked directly with real-user searching data from several search engines, including AOL, Alta Vista, Dogpile, Excite, and MSN Live. I’ve also analyzed web data of visitor traffic and other attributes from a variety of websites and social media platforms. I’ve analyzed real-user data from online search marketing campaigns and user referral traffic to websites. I have conduct research and teaching concerning aspects of websites and social media platforms, including keyword

Case 18-2868, Document 283, 08/09/2019, 2628241, Page405 of 883 advertising. I’ve developed web analytics models and processes for analysis of business goals, and I have used web analytics data and commercial tools in both my research and teaching. I’ve also conducted other research on user searching and related online behaviors. I have advised governmental agencies and companies in consulting and expert witnessing matters. A list of cases in which I have testified as an expert in deposition or trial in the past four years is attached as Appendix B. I am being compensated for my work on this case at the rate of $300 per hour. Ill. ASSIGNMENT AND MATERIALS CONSIDERED 7. In providing my expert opinion, I have been asked to respond to the following question: 8. What is the dissemination of the statements from Ms. Maxwell referring to Ms. Giuffre’s declarations as “untrue” and “lies” from when the statements were made on 2 January 2015 to the date that I filed this report? 9. For brevity, I refer to references to the statements denoting Ms. Giuffre’s declarations as “untrue” and “lies”, any related accounts referring to those original statements, or similar statements from Ms. Maxwell or her representatives referring to Ms. Giuffre as the statements made against Ms. Giuffre, the statements from Ms. Maxwell’s message, or the message from Mr. Gow'. 10. My analysis is based on my experience, training, knowledge, and education and is formed through the application of that experience, training, knowledge, and education in the principles of web data collection, web analytics, web search, search engines, web sites, web traffic analysis, and related market analysis. IT, The materials that I considered in preparing this report are listed in Appendix C. * See, para. 30 and 32, Complaint, VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. CASE NO. 1:15-cv-07433, 4

Case 18-2868, Document 283, 08/09/2019, 2628241, Page406 of 883 IV. SUMMARY OF OPINIONS 12. Based on my research and analysis in connection with this assignment, which is described in more detail in the body of this report, along with my own experience, training, knowledge, and education as stated below, I have reached the following opinion: 13. The statements made against Ms. Giuffre have been disseminated to at least 115 online media or other sites in 178 separate stories or articles with a combined 66,909,965 potential unique visitors since 2 January 2015 to the date that I filed this report, inclusive. 14. This is a conservative estimate, and it is more likely than not, the statements made by Ms. Maxwell against Ms. Giuffre have received wider dissemination due to factors such as: a. l used a set of online websites to measure dissemination, and it is reasonable that I have not located all references to the statements made against Ms. Giuffre on every website by the time of the submission of this report. db. I examined only online sources referencing the statements made against Ms. Giuffre and not print or broadcast media dissemination of the statements made against Ms. Giuffre. c. Ihave not attempted to measure face-to-face dissemination of articles containing the statements against Ms. Giuffre. d. I do not have access to certain online sources where articles containing the statements against Ms. Giuffre may have been disseminated (e.g., email messages, personal social media messages, articles behind firewalls, etc.). e. There are possibly sites that have hosted the statements made against Ms. Giuffre that I could not locate or where the statements have been removed.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page407 of 883 f, There are sites that hosted the articles containing the statements made against Ms. Giuffre where the visitor data is not accessible or where I could not confirm the number of visitors. g. I did not consider the dissemination via social media platforms of articles containing the statements made against Ms. Giuffre. h. Many sites published multiple articles on multiple days that contained or referenced the statements made against Ms. Giuffre; however, I did not include these multiple publication dates in calculating unique daily visitors. i I did not include unique daily visitors to articles that link from that article to one or more of the articles containing the statements made against Ms. Giuffre. i. Finally, I did not include the counts of those who may have been searching and seen the statements made against Ms. Giuffre in the search results listing. Vv. BACKGROUND WEB ANALYTICS FOR TRAFFIC ANALYSIS 15: In the course of forming this opinion, I implemented numerous web analytics and related techniques commonly used in the industry. In order to more clearly discuss these techniques, I define the following terms: . Direct Traffic: visitors to a website that come from entering a website link into a browser location bar (e.g., not coming via a link on another website). . Dissemination: the act of spreading or the circulation of information or articles. . Domain: a specific Internet website that are administered as a unit and defined by an Internet Protocol (IP) address.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page408 of 883 . Reach: the percentage or number of people who visit a website out of the total targeted population. . Referral Traffic: visitors to a site that come from websites other than search engines. . Repeat Visits: visitor traffic to a website in a given period that just includes multiple visits from the same set of IP addresses (i.e., IP addresses with more than one visit); provides a count of the people who have visited a site more than once in a given period. An individual is usually defined by a combination of IP address and browser within a given period but can also be defined by more sophisticated methods. . Search Engine: a program and associated hardware and processes that allows people to find information on the Web, typically via the submission of queries consisting of terms. . Search Traffic: visitors to a site that come from search engines rather than from other websites or via direct navigation. . Search: a submission of a query to a search engine, usually in the form of terms forming a query. . Share: sharing of an article or webpage typically via some social media platform. . Social M content that is shared via a social networking website. . Unique Visits: visitor traffic to a website within a given period that includes only the first visit (i.e., subsequent visits are ignored), which excludes repeat visits; provides a count of the individuals who have visited a site in a given period.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page409 of 883 . Unique Daily Visitors: visitor traffic to a website who visits a site at least once in a given 24-hour period. Each visitor, to the site, is counted once during the reporting period, which means it excludes repeat visits; provides a count of the individuals who have visited a site on a given day. ° Visits: a count of all the traffic to a website in a given period, including both unique and repeat visits. . Web Analytics: the measurement, collection, analysis and reporting of web data. VI. METHODOLOGY 16. I was asked to determine the dissemination of articles containing the statements made against Ms. Giuffre. 17. In forming my opinion, I utilized accepted web analytics and related methodologies in developing my assessment. 18. To that end, I employed various publicly available online analytic services, as well as some subscription-based services in conducting my research, including: . Alexa: an online service that provides web traffic data and analysis. . Compete: an online service that provides web traffic data and analysis. . Google Keyword Tool: an online service that provides the number of searches for a given set of keywords in a given month on the Google search engine. . Google Trends: an online service that shows how often a particular term is relatively searched on the Google search engine in a given period. . SimiliarWeb: an online service that provides web traffic data and analysis. . SpyFu: an online service providing search data and analytics, including for both paid (i.e., advertisements) and organic (i.e., natural or algorithmic) channels. . W3Snoop: an online service that provides web traffic data and analysis.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page410 of 883 19. These tools offer a variety of data and analysis services, and they are frequently utilized by industry professionals in the search engine optimization, web analytics, and search engine marketing fields for market, customer, and competitive analysis. Furthermore, where possible, I did my own assessments, as outlined below, in order to validate the data and analysis results. 20. I also utilized search engines, primarily Google and Bing, to assess the dissemination of articles containing the statements made against Ms. Giuffre. 21. Whenever possible, I used multiple data sources, which is a data verification technique known as triangulation”, where one uses multiple and disparate sources for analysis and then compare the results from the separate analysis. If the results are similar, it reinforces the conclusion that the overall data analysis is valid. 22. In all of my assessments, I have used the most conservative numbers, meaning that I use the smallest value in arriving at the dissemination of articles containing the statements made against Ms. Giuffre. If I had not employed this conservative estimate, the number of potential dissemination of the articles containing the statements made against Ms. Giuffre would be 102,740,816 (i.e., more than 102 million) daily unique visitors. 23. In situations where I believed that I could not adequately verify the number of individuals or did not have confidence in the numbers in those situations, I did not include those numbers in the calculation of daily unique visitors. 24. My analysis is based on my experience, training, knowledge, and education and is formed through the application of that experience, training, knowledge, and education in the ? Triangulation (social science) http://en.wikipedia.org/wiki/Triangulation_%28social_science%29 9

Case 18-2868, Document 283, 08/09/2019, 2628241, Page411 of 883 principles of web data collection, web analytics, web search, search engines, web sites, and related areas. VII. DISSEMINATION OF THE STATEMENTS MADE AGAINST MS. GIUFFRE 25. My opinion is that articles containing the statements made against Ms. Giuffre have been disseminated to at least 115 online media and others sites in 178 separate stories or articles with a combine 66,909,965 unique daily visitors. 26. This is a conservative estimate, and it is more likely than not, the statements have received wider dissemination due to factors such as: a. lused a set of online websites (115) to calculate the dissemination of articles, and it is reasonable that I have not located all references to the statements made against Ms. Giuffre by the time of the submission of this report. So, there may be more sites with articles containing the statements made against Ms. Giuffre that are not included in my calculations. db. My focus of analysis was the online dissemination of the statements made against Ms. Giuffre. Therefore, I examined only online sources and not dissemination of the statements made against Ms. Giuffre via print or broadcast media. It is reasonable to assume that the statements made against Ms. Giuffre were disseminated via these other channels. c. Ihave not attempted to measure face-to-face dissemination of the statements made against Ms. Giuffre. Therefore, these sources of dissemination are not included in the count of daily unique visitors. d. I did not have access to certain online sources where the statements against Ms. Giuffre may have been disseminated (e.g., email messages, social media messages,

Case 18-2868, Document 283, 08/09/2019, 2628241, Page412 of 883 articles behind firewalls, etc.). Therefore, these sources are not included in the count of daily unique visitors. e. There may be sites that have hosted articles containing the statements made against Ms. Giuffre where the articles have been removed. Therefore, I did not include these sites in my calculation of the unique daily visitors. f. There are sites where the visitor data is not accessible or where I could not reasonably check the number of visitors. In these cases, even though I had confirmed the site had posted one or more articles containing the statements made against Ms. Giuffre, I did not include these sites in my calculation of the unique daily visitors. g. I did not consider the dissemination via social media platforms of articles containing the statements made against Ms. Giuffre. h. Many sites published multiple articles on multiple days that contain or reference the statements made against Ms. Giuffre; however, I did not use these multiple articles from the same site with different publication dates in my calculations in determining the number of daily unique visitors who have been exposed to the articles containing the statements made against Ms. Giuffre. i I did not include articles that link to one or more of the articles containing the statements made against Ms. Giuffre. Unless the article directly referenced the statements made against Ms. Giuffre, I did not include it in my analysis. i Finally, I did not include people who may been searching and may have seen the statements made against Ms. Giuffre in the search results, without needing to visit the actual articles posted on the websites.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page413 of 883 VIII. METHODOLOGY TO DETERMINE THE DISSEMINATION OF THE STATEMENTS MADE AGAINST MS. GIUFFRE 27. Ihave been informed that the statements made against Ms. Giuffre were originally contained in an email message from Mr. Ross Gow’, of Acuity Reputation, acting on behalf of Ms. Maxwell, that was sent on 2 January 2015 at 8:38 pm‘ to, based on the email addresses*, people at The Mail Online®, The Independent’, The Mirror®, The Times’, and the BBC". The email message from Mr. Gow contained the statements made against Ms. Giuffre. A screen shot of the email message is shown in Figure 1. 28. Figure 1: Email message from Mr. Ross Gow containing the statements made against Ms. Giuffre. 3 GM_00068 (Gow E-Mail) “Lam assuming, based on the location of Mr. Gow’s company, Acuity Reputation, that this is date-time stamp for the United Kingdom. 5 Note: For some reason, the contact at the Mail Online is on the ce: line, while the other recipients are in the to: line. Also, the email message is sent to two recipients at the BBC. © ntips://en, wikipedia org/wiki/Mail_Online 7 https://en.wikipedia.org/wiki/The Independent * https://en.wikipedia.org/wiki/Daily Mirror ° htips://en, wikipedia org/wiki/The_Times '° https://en.wikipedia.org/wiki/BBC_News

Case 18-2868, Document 283, 08/09/2019, 2628241, Page414 of 883 From: <soss@acuityreputation.com> Date; 2 January 2045 at 20:38 Subject; Ghislaine Maxwell To: Rossacuity Gow <foss@acultyreputation.com> bec; martin. 1obinson@mallonling.co.uk, P.Peachey@independent.co.uk, nick.sommerlad@mirror.co.uk, david brown@thetimes.co.uk, nick. alway@bbc.co.uk, jo-anne_pugh@bbc.co.uk To Whom It May Concer, Please find attached a quotable statement on behalf of Ms Maxwell. No further cormmunication will be provided by her on this matter. Thanks tor your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts ~50 not a new Individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue, Each time the story Is re told It changes with new salacious details about public figures and world leaders and now itis alleged by Ms Roberts that Alan Derschowitz Is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the Britisly press and elsewhere and reserves her right t seek redress at the repetition of such old defamatary claims. Sent from my BlackBerry” wireless device 29. I have been informed that the statements made against Ms. Giuffre were confirmed by Ms. Maxwell in a news article and video!! aired on 5 January 2015, which I have established by reviewing the video referenced in the news article!”. "! GIUFFRE001120 ? http://www.nydailynews.com/news/world/alleged-madame-accused-supplying-prince-andrew-article-1.2065505 13

Case 18-2868, Document 283, 08/09/2019, 2628241, Page415 of 883 30. Additionally, on 8 January 2015, agents reportedly acting on behalf of Ms. Maxwell made statements that the allegations against her were a “web of lies and deceit”!, which are similar to the statements made against Ms. Giuffre in the message from Mr. Gow. 31. Similarly, on 1 February 2015, like statements were quoted as “These allegations are untrue and defamatory”'+, which are similar to the statements made against Ms. Giuffre in the message from Mr. Gow. 32. Based on my investigation and research, news stories, articles, and postings containing direct reference to or quotes from the statements made against Ms. Giuffre appeared the same day (i.e., 2 January 2015) as the email from Mr. Gow, with several news organizations and other sites publishing other articles containing direct reference to or quotes from the statements made against Ms. Giuffre in the immediately following days. News articles containing direct reference to or quotes of the statements made against Ms. Giuffre have continued to appear in news articles and other postings nearly up to the date that I submitted this report. 33. A timeline of events relating to the dissemination of the statements made against Ms. Giuffre is shown in Figure 2. 34. Figure 2: Timeline of events relating to the dissemination of the statements made against Ms. Giuffre from 2 January 2015 onwards. 33 https://www.thesun.co.uk/archives/news/6754/prince-andrews-pal-ghislaine-groped-teen-girls/ '* http://www.mirror.co.uk/news/uk-news/prince-andrews-pal-ghislaine-maxwell-5081971 14

Case 18-2868, Document 283, 08/09/2019, 2628241, Page416 of 883 Duringthe month of January, considerablenews coverage with articlesreferencingthe statements made against Ms. Giuffre appearing Inavariety of news outlets, including The Daily Ms. Maxwell confirms the statements made against Ms. Mail, the New York Daily News, and Page Six. Giuffre ina New Daily News video on 5 January 2015 The firstnews articles referencingthe statements made against Ms. Giuffre appear on 2 January 2015 i Continued news coverage with articles referencingthe statements made against Ms. Giuffre appearingin a variety of news outlets from February through April, including the Guardian and 88C. 1 ' a oy Dec Jan Feb = Mar Apr 2015 ~ 2016 ~ 2016 ~ 2016 ~ 2016 == - —} 1 ' ' t 1 i 1 1 1 1 1 I 1 i I 1 It ' t t 1 1 1 L ' ' I Continued news coverage with articles referencing the statements made ageinst¥Ws. Giuffrefrom February through fori, including Reuters, YahoolNews, and AOL i Duringthe month of January, extensive news coverage with articles referencing the Mr. Gow sends email containingthe statements made againstMs. Gluffreto contacts at The Mail Online, The Independent, The Mirror, The Times, and the BBC on 2 January 2015 at &:38 pm, statements made against Ms. Giuffre appearing ! News. inavatietyas nevis outlets, Including the Dally Duringthe month of September, considerable Mail, the Huffington Post, the International die ovens With apliclee dering Business time, The Mirror, The Guardian, The sSscinsrts wide agave Mercidieepaaiine Daily Record, The Express, The IrishTimes, the ia Vary GF ice Githetn eluding teveily New York Daily News, The New Zealand Herald, ail: sFe Murroi the ew Tor Dally Neos The Telegraph, The Daily Beast, Racar Online, : Newsday, and Page Six. and Page Six 35: Concerning the procedure employed in determining the dissemination of the statements made against Ms. Giuffre, nearly every major news site!> that I investigated, along with other specific news sites in the United States, the United Kingdom, Canada, and Australia, as well as other countries, have carried some aspects of the overall story related to Ms. Giuffre and/or Ms. Maxwell, or other parties involved. 36. In fact, there are tens of thousands of news articles and postings concerning the general story from news outlets worldwide, with combined potential viewership in the multimillions, as searches on the major search engines, such as Google and Bing, show. 'S Including the largest online news sites, such as Yahoo! News, Google News, Huflington Post, CNN, NY Times, Fox News, NBC News, Daily Mail, Washington Post, The Guardian, Wall Street Journal, ABC News, BBC News, USA Today, LA Times (see http:/www.ebizmba.com/articles/news-websites) 15

Case 18-2868, Document 283, 08/09/2019, 2628241, Page417 of 883 37. However, I was not interested in news articles that just discussed the story in general or other aspects of the story. Also, I was not interested in those articles where Ms. Maxwell or those acting on her behalf, such as Mr. Gow, would just generally deny the allegations in the complaint'*. I was specifically interested in only those articles that referenced directly or quoted the statements made against Ms. Giuffre in the 2 January 2015 email message from Mr. Gow, Ms. Maxwell’s subsequent confirmation of the statements, or similar statements as those in the message from Mr. Gow. Naturally, this narrow focus is a smaller subset of news articles than are the articles addressing the overall story. 38. To isolate these articles of interest, I generated a series of 10 queries!” that specifically targeted news articles from the case that addressed the statements made against Ms. Maxwell (e.g., Ghislaine Maxwell obvious lies) to retrieve a set of articles that directly related to the statements made against Ms. Giuffre!*. I employed a modified snowball technique”, starting with one seed query, adding and modifying terms, until I was not retrieving new results. I also located some articles via navigating from the set of retrieved articles. 39. I set the search range date from 2 January 2015 onward, so articles prior to that date were not included in the search results. For each article used in my analysis, I also verified the date that the article was published to ensure it was published on or after 2 January 2015 and that the articles directly referenced in some way the statements made against Ms. Giuffre. 40. | Anexample of a search engine results page in response to one of these queries is shown in Figure 3. ‘© Complaint, VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. CASE NO. 1:15-cv-07433. "' Ghislaine Maxwell obvious lies, Ghislaine Maxwell Roberts obvious lies cnn, Ghislaine Maxwell Virginia Roberts, Giuffre Maxwell obvious lies, new york daily news alleged madam andrews, Prince Andrew Maxwell Roberts, Prince Andrew obvious lies, prince andrew's sex slave scandal who is maxwell, Ross Gow obvious li slave obvious lies 'S In addition to the queries, I located some articles via direction navigation. '* https://en.wikipedia.org/wiki/Snowball_sampling 16

Case 18-2868, Document 283, 08/09/2019, 2628241, Page418 of 883 Al. Figure 3: Google News search results for the search Ghislaine Maxwell obvious lies with a date delimiter beginning on 2 January 2015. Google Ghislaine Maxwell obvious lies u g All images = News Videos += Shopping © More~ _ Search tools Allnews+ Jan2,2015-Today~ Sorted byrelevance Clear Af Socialite wants defamation lawsuit by ‘sex slave’ tossed New York Daily News - Jan 15, 2016 Ghislaine Maxwell's lav/yers are pushing to dismiss a defamation lawsuit brought ... of being pimped out to Epstein were “shown to be untrue” and “obvious lies. Sex-Trafficking Denials Aren't Libel, Brit Says Courthouse News Service - Jan 14, 2016 Ghislaine Maxwell denies calling Virginia Roberts a liar Daily Mail - Jan 15, 2016 Lawyers for British Socialite Accused of Pimping 'Sex Slave’ To ... Jewish Business News - Jan 15, 2016 Alleged Epstein madam denies calling teen 'sex slave' a liar Highly Cited - Page Six - Jan 14, 2016 Explore in depth (3 more articles) | Jeffrey Epstein sex slave accuser sues Brit socialite New York Daily News - Sep 21, 2015 Ghislaine Maxwell, after walking out the side door of her E65St. townhouse in ... cites statements by Maxwell's spokesman calling Giuffre's claims “obvious lies.” 42. I then personally verified that each article, by reviewing each article, used in my analysis directly referenced in some way the statements made against Ms. Giuffre. 43. So, articles relating to the overall story that did not mention Ms. Maxwell’s statements made against Ms. Giuffre were not included in the analysis. Articles relating to the overall story that referred to Ms. Maxwell simply denying the charges were not included. 44. Talso personally performed a site search” of the top 15 online media sites worldwide”! of articles related to the case, and I reviewed the results to identify if any of these 2 hutps://www.google.com/advaneed_search 1! Yahoo! News, Google News, Huffington Post, CNN, NY Times, Fox Ni Street Journal, ABC News, BBC News, USA Today, LA Times (see http:/www.ebizmba.com/articles/news-websites) 17 s, NBC News, Daily Mail, Washington Post, The Guardian, Wall

Case 18-2868, Document 283, 08/09/2019, 2628241, Page419 of 883 articles referred to the statements against Ms. Giuffre. I also did the same for many countryspecific news sites in the United States, the United Kingdom, Canada, and Australia. 45. In the end, I had a set of 178 online news and other articles from 2 January 2105 to the date that I filed this report that specifically referenced the statements made against Ms. Giuffre to conduct my analysis, as outlined below. 46. Each of these 178 online articles was posted online. The 178 online articles were distributed among 115 unique domain websites (i.e., some websites posted multiple articles that contain the statements made against Ms. Giuffre). These 115 domains are: http://beforeitsnews.com http://boltonbnp. blogspot.com http://businessnewsusa.org ttp://dukefmduluth.com ttp://dukefmfargo.com ttp://home.bt.com ttp://jewishbusinessnews.com http://jewishnews.timesofisrael.com http://kdal610.com http://kfgo.com http://motivatornews.com ttp://mrharrywales.tumblr.com ttp://muhammad-ali-ben-marcus. blogspot.com ttp://news.sky.com http://news.trust.org http://newsbite.it http://newstoday.club http://normanfinkelstein.com ttp://onewayempire.com ttp://pagesix.com ttp://planetinvestigations.com http://softwaresuites.ne http://thisviral.com http://townhall.com http://ugandansatheart. blogspot.com ttp://uk.reuters.com . ttp://whatiswrongwiththispicture2012.blogspot.com . ttp://whbl.com . ttp://whtc.com

Case 18-2868, Document 283, 08/09/2019, 2628241, Page420 of 883 http://wibqam.com http://wife.com http://wincountry.com http://wkzo.com ttp://worlddailynews.info ttp://wsau.com ttp://wtag.com http://wtvbam.com http://www.anorak.co.uk http://www.aol.co.uk http://www.asianimage.co.uk ttp://www.bailiwickexpress.com ttp://www.bannednews.net ttp://www.bbc.com ttp://www.belfasttelegraph.co.uk http://www.bournemouthecho.co.uk http://www. businessinsider.com http://www. business-standard.com http://www.capitalbay.news ttp://www.clactonandfrintongazette.co.uk ttp://www.courthousenews.com ttp://www.dailylife.com.au ttp://www.dailymail.co.uk http://www.dailyrecord.co.uk http://www.darkpolitricks.com http://www.dudleynews.co.uk ttp://www.eveningtimes.co.uk ttp://www.express.co.uk ttp://www.faceiraq.com ttp://www.ghanagrio.com http://www.ghanareview.com http://www.govtslaves.info http://www.headlines-news.com http://www.huffingtonpost.co.uk ttp://www.ibtimes.co.uk ttp://www.independent.ie ttp://www.infiniteunknown.net http://www. iol.co.za http://www. irishexaminer.com http://www. irishmirror.ie http://www. irishtimes.com ttp://www.itv.com ttp://www. lancashiretelegraph.co.uk ttp://www.lse.co.uk 19

Case 18-2868, Document 283, 08/09/2019, 2628241, Page421 of 883 http://www.mgtowhq.com http://www.mirror.co.uk http://www.msn.com http://www.nationalenquirer.com ttp://www.newindianexpress.com ttp://www.newscopia.com ttp://www.newsday.com http://www.newsgrio.com http://www.nigeriadailynews.news http://www.nydailynews.com http://www.nzherald.co.nz ttp://www.oneworldofnations.com ttp://www.oxfordmail.co.uk ‘ttp://www.pressreader.com ttp://www.reuters.com http://www.scmp.com http://www.scotsman.com http://www.somersetlive.co.uk http://www.srnnews.com ttp://www.swindonadvertiser.co.uk ttp://www.telegraph.co.uk ttp://www.theargus.co.uk ttp://www.theboltonnews.co.uk http://www.thedailybeast.com http://www.thetelegraphandargus.co.uk http://www.thetruthseeker.co.uk ttp://www.twimovies.news ttp://www.westernmorningnews.co.uk ttp://www.wirralglobe.co.uk ttp://www.yorkpress.co.uk http://www. yorkshirepost.co.uk https://blairzhit.wordpress.com https://bol.bna.com https://ca.news.yahoo.com ttps://circusbuoy.wordpress.com ttps://quartetbooks. wordpress.com ttps://thetruth24.info https://www.eveningtelegraph.co.uk https://www.theguardian.com https://www.thesun.co.uk https://www.yahoo.com ttp://ferddyjay.blogspot.com 20

Case 18-2868, Document 283, 08/09/2019, 2628241, Page422 of 883 47. As seen from the list of domains that have published articles or stories containing references to the statement made against Ms. Giuffre, many of these domains are those of major news organizations or sources, including AOL News, BBC, Huffington Post, International Business Times, Irish Times, MSN News, National Enquirer, New York Daily News, New Zealand Herald, Page Six, Radar Online, Reuters, The Daily Beast, The Daily Mail, The Express, The Guardian, The Mirror, The Sun, The Telegraph, Yahoo! News, etc. 48. I then used a variety of web analytics traffic services and other sources to get the unique daily visitor traffic for each of these domains. I used multiple services when available to verify the unique daily visitor traffic for each of these domains, as these traffic services may use different techniques to arrive at their traffic numbers. 49. In cases of conflicting unique daily visitor traffic numbers, I utilized the most conservative (i.e., smallest) number. 50. In cases where I determined I could not get unique daily visitor traffic numbers or the unique daily visitor traffic were not reliable, in my opinion, I did not include the unique daily visitor traffic numbers for that domain in the numbers. This usually occurred for the sites with a smaller number of daily visitors or sites with an extremely large number of daily visitors. 51. Unique daily visitors measure is an industry standard web analytics metric for measuring people that visit a website in a given day, also known as unique audience’. It is generally averaged out over multiple days with a given period, such as week or month, as there are normal daily fluctuations. 52. Table 1 shows the unique daily visitor traffic for the listed domains that posted articles or stories referencing the statements made against Ms. Giuffre and the associated unique http://digitalmeasurement.nielsen.com/files/metrics-guidelines.pdf 21

Case 18-2868, Document 283, 08/09/2019, 2628241, Page423 of 883 daily visitor traffic for each of those domains, along with number of articles containing the statements made against Ms. Giuffre posted on that site. 3. Table 1: Domains that published articles or stories containing the statements made against Ms. Giuffre with the domain’s number of unique daily visitors and the number of articles containing the statements made against Ms. Giuffre published on that domain from 2 January 2015 to the date that I filed this report”. Domain Unique | Number of No. Domain Visitor Traffic Articles (aily) Published 1 | http://beforeitsnews.com 193,333 2 | http://boltonbnp.blogspot.com* 3 | http://businessnewsusa.org* 4 | http://dukefmduluth.com* 5 | http://dukefmfargo.com* 6 | http://home.bt.com 800,000 7 | http://jewishbusinessnews.com 5,000 8 | http://jewishnews.timesofisrael.com* 9 | http://kdal610.com 257 10 | http://kfgo.com 1,600 11 | http://motivatornews.com* = 12 | http://mrharrywales.tumblr.com* 13 | http://muhammad-ali-ben-marcus.blogspot.com* 14 | http://news.sky.com 523,333 15 | http://news.trust.org* 16 | http://newsbite.it* 17 | http://newstoday.club* 18 | http://normanfinkelstein.com 1,987 19 | http://onewayempire.com* z 20 | http://pagesix.com 320,000 21 | http://planetinvestigations.com* 22 | http://softwaresuites.ne* S 23 | http://thisviral.com* S 24 | http://townhall.com 236,667 25 | http://ugandansatheart.blogspot.com* 26 | http://uk.reuters.com 153,333 mele fell elulelele fe le frmlelele [ele le lr lelelele lela 27 | http://whatiswrongwiththispicture2012.blogspot.com* 23 Note: Some outlets, I was able to get self-reported visitor numbers, such as the https://www.theguardian.com_ 22

Case 18-2868, Document 283, 08/09/2019, 2628241, Page424 of 883 Domain Unique | Number of No. Domain Visitor Traffic Articles (Daily) Published 28 | http://whbl.com 12,252 29 | http://whtc.com 1,207 30 | http://wibqam.com* 31 | http://wife.com 990 32 | http://wincountry.com 503 33 | http:/Avkzo.com 573 34 | http://worlddailynews.info* = 35 | http://wsau.com 2,653 36 | http://wtaq.com* Z: 37 | http://wtvbam.com* = 38 | http://www.anorak.co.uk 7,150 39 | http://www.aol.co.uk 423,333 40 | http://www.asianimage.co.uk 1,293 41 | http://www.bailiwickexpress.com 29,633 42 | http://www.bannednews.net* 43 | http://www.bbe.com 12,950,000 44 | http://www.belfasttelegraph.co.uk* = 45 | http://www.bournemouthecho.co.uk* 46 | http://www. businessinsider.com 3,866,667 47 | http://www.business-standard.com* 48 | http://www.capitalbay.news* E 49 | http://www.clactonandfrintongazette.co.uk 50 | http://www.courthousenews.com 11,333 51 | http://www.dailylife.com.au 80,000 52 | http://www.dailymail.co.uk 14,276,667 53 | http://www.dailyrecord.co.uk 145,048 54 | http://www.darkpolitricks.com* = 55 | http://www.dudleynews.co.uk* 56 | http://www.eveningtimes.co.uk 3,667 57 | http://www.express.co.uk 1,686,667 58 | http://www.faceiraq.com* = 59 | http://www.ghanagrio.com* 60 | http://www.ghanareview.com* = 61 | http://www. govtslaves.info* = 62 | http://www.headlines-news.com* mlelefwlwlelelelaleleleleleluwlalelulelelelelelelelelele [rmlelelelelelelelelelele 63 | http://www.huffingtonpost.co.uk 750,000 64 | http://www. ibtimes.co.uk 1,380,000 65 | http://www.independent.ie* 66 | http://www.infiniteunknown.net 3,183 67 | http://www.iol.co.za 233,333 23

Case 18-2868, Document 283, 08/09/2019, 2628241, Page425 of 883 Domain Unique | Number of No. Domain Visitor Traffic Articles @aily) Published 68 | http://www. irishexaminer.com* = 1 69 | http://www. irishmirror.ie 100,000 3 70 | http://www. irishtimes.com 323,333 1 71 | http:/;www.itv.com 1,026,667 2 72 | http://www.lancashiretelegraph.co.uk* = 1 73 | http://www.lse.co.uk 70,000 1 74 | http://;www.mgtowhq.com* - 1 75 | bttp://www.mirror.co.uk 3,860,000 10 76 | http://www.msn.com? 77 | http://www.nationalenquirer.com 60,000 78 | http://www-newindianexpress.com* 79 | http://www.newscopia.com* 80 | http:/Avww.newsday.com 132,250 81 | http://www.newsgrio.com 132,250 82 | http://www.nigeriadailynews.news 16,236 83_| http://www.nydailynews.com 2,100,000 84 | http://www.nzherald.co.nz 686,667 85 | http://www.oneworldofnations.com* 86 | http://www.oxfordmail.co.uk* 87 | http://www.pressreader.com 110,000 88 http://www.reuters.com 2,363,333 89 | http:/;www.scmp.com* 90 | http://www.scotsman.com 125,393 91 | http://www.somersetlive.co.uk* 92 | http://www.smnews.com* 93 | http://www.swindonadvertiser.co.uk 22,077 94 | http://www.telegraph.co.uk 5,506,667 95 | http://www.theargus.co.uk 59.281 96 | http://www.theboltonnews.co.uk 40,000 97 | http://www.thedailybeast.com 1,636,667 98 | http://www.thetelegraphandargus.co.uk 46,667 99 | http://www.thetruthseeker.co.uk 2RIST 100 | http://www.twimovies.news* 101 | http://www.westernmomingnews.co.uk* + 102 | http:/Avww.wirralglobe.co.uk* 103 | http://www. yorkpress.co.uk* 104 | http://www. yorkshirepost.co.uk* e 105 | https://blairzhit.wordpress.com* 106 | https://bol.bna.com* a 107 | https://ca.news.yahoo.com? = wlepefefelwirmfufelfrofelelelelelalelelelala|m[elele |e] elrofelel|e 24

Case 18-2868, Document 283, 08/09/2019, 2628241, Page426 of 883 Domain Unique | Number of No. Domain Visitor Traffic Articles Q@aily) Published 108 | https://circusbuoy.wordpress.com* = 1 109 | https://quartetbooks.wordpress.com* - 1 110 | https://thetruth24.info* - 1 111 | https:/Awww.eveningtelegraph.co.uk* = 2 112 | https:/www.theguardian.com 8,872,392 6 113 | bttps:/www.thesun.co.uk 1,496,667 1 114 | https://www.yahoo.com® = 1 115 | http://ferddyjay.blogspot.com* : 1 66,909,965 178 *~ Unique daily visitor traffic not available > _ Unique daily visitor traffic not verifiable 54. Lused each domain’s unique daily visitor count to calculate the dissemination of the articles containing the statements against Ms. Giuffre to various websites and potentially to visitors to that site (i.e., as visitors to the news sites, these individuals could have been exposed to the articles containing the statements made against Ms. Giuffre), using the unique daily visitor number only once for each domain, regardless whether that domain published more than one article referring to the statements made against Ms. Giuffre. IX. RESULTS FOR ANALYSIS OF THE DISSEMINATION OF THE STATEMENTS MADE AGAINST MS. GIUFFRE 55. Based on my analysis as outlined above, my opinion is that the statements against Ms. Giuffre have been disseminated to at least 115 online media and other sites with 178 stories or articles with a combined 66,909,965 (more than 66 million) unique daily visitors traffic. 56. [note that for many of the 178 articles containing the statements made against Ms. Giuffre, one could get gist of the story of the article directly from the article headline. I point this out as it is well known that people skim online news sites”*, so titles such as these ™ Sce for example: Aikat, D. News on the web: usage trends of an on-line newspaper. Convergence: The Intemational Joumal of Research into New Media Technologies 4. 4 (Dec. 1998), 94-110. 25

Case 18-2868, Document 283, 08/09/2019, 2628241, Page427 of 883 would have substantial impact on visitors to that site. Examples of such articles headlines (examples of actual headlines from the 178 articles) are: . British socialite to face Epstein accuser's defamation lawsuit . Alleged Epstein madam denies calling teen ‘sex slave’ a liar . Sex-Trafficking Denials Aren't Libel, Brit Says . U.S. woman who claimed she was forced to have sex with Prince Andrew sues British socialite for denying that she recruited her to be a sex slave . British 'madam' accused of recruiting teenage ‘sex slave' Virginia Roberts for Prince Andrew's friend Jeffrey Epstein denies calling her a liar . Ghislaine Maxwell denies calling Virginia Roberts a liar . Bill Clinton Pedophile Sex Scandal: Socialite Denies Calling ENQUIRER Source A Liar, Woman files defamation suit against British publishing magnate . Jeffrey Epstein sex slave accuser sues Brit socialite for defamation . Lawyers for British socialite accused of pimping ‘sex slave' to Jeffrey Epstein push to dismiss defamation lawsuit. 57. This is a conservative estimate, and more likely than not, articles containing the statements made against Ms. Giuffre have been disseminated to more individuals. X. WHY THE ESTIMATE IS LOW 58. This (66,909,965 individual unique daily traffic) is a conservative estimate, and it is more likely than not, the statements have received wider dissemination due to factors such as: a. Although I spend considerable effort to locate published articles that contained the statements made against Ms. Giuffre, it is reasonable to assume that I have not located all such articles by the time of the submission of this report. So, there are possibly more 26

Case 18-2868, Document 283, 08/09/2019, 2628241, Page428 of 883 sites with articles containing the statements made against Ms. Giuffre that are not included in my calculations, which would increase the dissemination of the articles. b. The focus of my analysis was the dissemination of online articles containing the statements made against Ms. Giuffre, and I examined only online sources and not print or broadcast media. Many of the media outlets that I did identify have consider print distribution®>, which are not included in my calculations, for example, such as: e The Sun (print circulation) 1,741,838 e Daily Mail (print circulation) 1,562,361 e The Daily Telegraph (print circulation) 472,936 e The Times (print circulation) 402,752 e The Guardian (print circulation) 161,152 c. In my analysis, I did not attempt to measure face-to-face dissemination that may have occurred after individuals may have read articles containing the statements made against Ms. Giuffre, which would increase the count. d. Naturally, I could not access certain online sources where the statements made against Ms. Giuffre may have been disseminated (e.g., email messages, social media messages, articles behind firewalls, etc.). Therefore, these numbers are not included in my calculations. e. Also, there are possibly sites that have hosted articles containing the statements made against Ms. Giuffre where the articles have been removed. Therefore, they are not included in my calculations. 25 www.theguardian,com/media/2016/mar/17/independent-mirror-express-and-star-suffer-sharp-fall-in-traffic 27

Case 18-2868, Document 283, 08/09/2019, 2628241, Page429 of 883 £ For sites where one or more of the articles containing the statements made against Ms. Giuffre are posted but where I could not locate or not determine reliable daily unique visitor traffic, I have not included these sites in my calculations. There are 59 (of the 115 sites, 51.3%) where I could not get or not get verifiable traffic data. For example, the traffic numbers for the MSN News (Microsoft) and Yahoo! News are not separated by news and other services, such as search, so I did not include these in the number of people to which the articles containing the statements made against were disseminated. g. I did not include the dissemination of the articles containing the statements made against Ms. Giuffre directly to social media platforms. However, many of the articles containing the statements made against Ms. Giuffre do include counts of the number of times that individuals shared the article to a social media networks, as shown in Table 2. i. Table 2: Number of social media shares by published article containing the statements made against Ms. Giuffre. Shares Date Domain 12576 | 2-Jan-15 | https://www.theguardian.com 201 | 3-Jan-15 | http://muhammad-ali-ben-marcus.blogspot.qa 1600 | 3-Jan-15 | http:/Avww.dailymail.co.uk 4000 | 3-Jan-15 | http://www.dailymail.co.uk 130 | 3-Jan-15 | http://www.huffingtonpost.co.uk 45 | 3-Jan-15 | http:/Avww.ibtimes.co.uk 6436 | _3-Jan-15 | http://www.mirror.co.uk 55 | 4-Jan-15 | http://newsbite.it 56| 4-Jan-15 | http://ugandansatheart. blogspot.com 1813 | 4-Jan-15 | http://www.dailyrecord.co.uk 9 | 4-Jan-15 | http:/;vww.express.co.uk 560 | 4-Jan-15 | http://www.huffingtonpost.co.uk 24| 4-Jan-15 | http://www.ibtimes.co.uk 54| 4-Jan-15 | http://www.ibtimes.co.uk 198 | 4-Jan-15 | http://www. irishmirror.ie 198 | _4-Jan-15 | http://www.mirror.co.uk 174 | 4-Jan-15 | http://www.nigeriadailynews.news 51 | 4-Jan-15 | http://www.nzherald.co.nz 28

Case 18-2868, Document 283, 08/09/2019, 2628241, Page430 of 883 Shares Date Domain 216 | 4-Jan-15 | http://www.telegraph.co.uk 177 | _4-Jan-15 | https://www.theguardian.com 193 | 4-Jan-15 | https://www.theguardian.com 105 | 5-Jan-15 | http://www.dailylife.com.au 192 | _5-Jan-15 | http://www.dailyrecord.co.uk 7 | 5-Jan-15 | http://www.mirror.co.uk 1052 | 5-Jan-15 | http://www.mirror.co.uk 96 | 5-Jan-15 | http://www.nydailynews.com 115 | 5-Jan-15 | https://www.theguardian.com 45 | 6-Jan-15 | http:/Avww.dailymail.co.uk 17 | 8-Jan-15 | http://www.nydailynews.com 114 | 10-Jan-15 | http://www.dailymail.co.uk 1 | 10-Jan-15 | http://www.infiniteunknown.net 1466 | 10-Jan-15 | https://www.theguardian.com 1 | 13-Jan-15 | http://whatiswrongwiththispicture2012.blogspot.ga 256 | 22-Jan-15 | http://www.dailyrecord.co.uk 120 | 22-Jan-15 | http://www.huffingtonpost.co.uk 319 | 22-Jan-15 | http://www. irishmirror.ie 338 | 22-Jan-15 | http://www.mirror.co.uk 21 | 1-Feb-15 | http://www.mirror.co.uk 342 | 7-Feb-15 | https://www.theguardian.com 107 | 21-Sep-15 | http://www.nydailynews.com 33 | 22-Sep-15 | http://www.dailymail.co.uk 205 | 22-Sep-15 | http://www.mirror.co.uk 1 | 15-Jan-16 | http://jewishbusinessnews.com 13 | 15-Jan-16 | http://www.dailymail.co.uk 17 | 15-Jan-16 | http://www.nationalenquirer.com 2 | 15-Jan-16 | http:/;vww.nydailynews.com 7 n.d. http://www.govtslaves.info 33,758 ii. As shown in Table 2, the articles containing the statements made against Ms. Giuffre have been shared 33,758 times, mostly on Facebook. iii. Given that the median number of Facebook ‘friends’ is 200°, this equates to a possible 6,751,600 individuals, in addition to the 33,758 individuals who originally shared © hutp://www.pewresearch.org/fact-tank/2014/02/03/6-new-facts-about-facebook/ 29

Case 18-2868, Document 283, 08/09/2019, 2628241, Page431 of 883 the articles, to which the articles containing the statements made against Ms. Giuffre could have been disseminated, assuming these individuals are all unique and have not already read one of the articles. iv. However, I did not include these social media shares in my calculations. v. Since news article viewing follows a power law”’ distribution?®, there is no direct linear ratio of number of social media shares to readership. There is published research that does report average of views of an article on a news website and also average social media shares”’. In a direct calculation with numbers from this article*°, 23 articles views per social media share, using 33,758 social media shares, this would be 776,434 article views. However, this ratio would vary by website, number of daily unique visitors, type of news article, time for accumulating shares, and possibly other factors. Plus, this number would not account for the people receiving the social media share that viewed the title, post, and snippet but did not click on the share to view the article on the website, thereby undercounting views of the articles. vi. Also, given the topical nature of the underlying news story, one could expect lower social media sharing but higher article viewing, as people will tend to read articles on such topics privately but not share on social media*!. So, I would expect the social media number itself to be an undercount. h. I did not include articles that link to one of the articles containing the statements made against Ms. Giuffre in my calculations of dissemination. Unless the article 7 hutps://en.wikipedia.org/wiki/Power_law * See for example, Tatar, A., de Amorim, M. D., Fdida, S., & Antoniadis, P. (2014). A survey on predicting the popularity of web content. Journal of Intemet Services and Applications, 5(1), 1 » See for example, Castillo, C., El-Haddad, M., Pfeffer, J., & Stempeck, M. (2014, February). Characterizing the life cycle of online news stories using social media reactions, In Proceedings of the 17th ACM conference on Computer supported cooperative work & social computing (pp. 211223), ACM. » Castillo, C., El-Haddad, M., Pfeffer, J., & Stempeck, M. (2014, February), Characterizing the life cycle of online news stories using social media reactions. In Proceedings of the 17th ACM conference on Computer supported cooperative work & social computing (pp. 211-223). ACM. » See for example, Agarwal, D., Chen, B. C., and Wang, X, Multi-faceted ranking of news articles using post-read actions. In Proc. of CIKM, ACM (2012), 694-703, 30

Case 18-2868, Document 283, 08/09/2019, 2628241, Page432 of 883 directly mentioned the statements made against Ms. Giuffre, I did not include that article in my calculations. So, unless the linking article actually mentioned, referenced, or quoted the statements made against Ms. Giuffre, I did not include it in the calculations. i Many sites published multiple articles on multiple days that quoted or referenced the statements made against Ms. Giuffre; however, I did not use these multiple publication dates from the same site in my calculations of unique visitor traffic. If a domain published only one article containing the statements against Ms. Giuffre, then I directly used the unique daily visitors number. If a domain published multiple articles concerning the statements against Ms. Giuffre, I did not count the traffic for the subsequent articles containing the statements made against Ms. Giuffre, even though research shows that repeat traffic to websites is generally only about 30%”, meaning that 70% of the traffic would be unique. However, I was not comfortable using this figure given the natural of these sites, which might have higher repeat visitors day-to-day. Therefore, I did not include the unique visitors to multiple articles in my calculations. i. Finally, I did not include the count of people who may been searching and may have seen the statements made against Ms. Giuffre in the search results, without needing to visit the actual articles, as shown in Figure 4. k. Figure 4: Example of search results with the statements made against Ms. Giuffre appearing in the result snippets, requiring no need to visit the articles themselves. » Teevan, J., Adar, E., Jones, R. and Potts, M. (2006). History repeats itself: repeat queries in Yahoo's logs. In Proceedings of the 29th annual international ACM SIGIR conference on Research and development in information retrieval (SIGIR '06). ACM, New York, NY, USA, 703-704. 31

Case 18-2868, Document 283, 08/09/2019, 2628241, Page433 of 883 le © & httpsy/www.google.com/#q=Ghislaine+ Maxwell +ok tie Google Ghislaine Maxwell obvious lies All mag idec Shopping More» — Seareh tools More images for Ghislaine Maxwell obvious lies Ghislaine Maxwell denies calling Virginia Roberts a liar | Daily Mail .. www dailymail.co.uk/,./Bnitish-madam-accused- ecruiting: teenage-sex-sla.. > Daily Mail Jan 15, 2076 - Ghislaine Max f recruiting Virginia Roberts as saying Roberts’ allegations wet oO Ghislaine Maxwell still has connections despite link to Prince Andrew ... www dailymail.co.uk/... /Ghistaine-Maxwell-s-link-sex-scandal-court-papers... + Daily Mai a cs jell stands accused of ‘procuring’ girls. including .. Ms Maxwell has callea here obvious lies’. wife the Prince has put out British socialite to face Epstein accuser's defamation lawsuit | Reuters www. reuters. com/article/us-maxwell- ne Jawsuit-idUSKCNOW34ZN * Re socialite Ghislaing M {defamation fot caling her allegations lies, been Fr "claims are obvious ties Ghislaine Maxwell denies being a madam for paedophile Jeffrey ... www. acess co.uk» News» World + ( - a jell's original responsé claims are obvious Nes and|bhould be treated as such and Jeffrey Epstein sex slave accuser sues Brit socialite - NY Daily News www.nydailynews.com/.. /jeffrey-epstein-sex-slave-accuser-sue.. * New York Daily New 2015 - She says Ghis} ncounters with the New York _ by vel's spokesman calling Glutre’s s “obvious lies Socialite wants defamation lawsuit by 'sex slave’ tossed - NY Daily News wn to be untrue,” and that hj jo the lies and defamatory .. “(The woman's) XI. ACCURACY OF THE TRAFFIC _NUMBERS _ AN DITIO! VERIFICATION 32

Case 18-2868, Document 283, 08/09/2019, 2628241, Page434 of 883 59. Concerning the accuracy of the analysis, the number of domains where the statements made against Ms. Giuffre have been disseminated is reliable, as this is straightforward to verify (i-e., the article is either posted on a site or it is not). If anything, this is an undercount, as some domains, for example, may have removed such articles, making them no longer available. There are possibly articles containing the statements that I have not been able to locate by the time that I submitted this report. 60. Concerning traffic numbers for domains, a unique visitor is typically identified by an identifier stored in a text file, which is based on an individual computer’s browser, although more sophisticated methods are also being used. In locating traffic numbers for the domains, I used multiple services when available and attempted to verify via other sources. In case with varying traffic data, I utilized the most conservative (i.e., smallest) number available. 61. Lalso verified findings from my analysis via other methods and my own experience and training. For example, there are periods of increased publishing of articles containing the statements made against Ms. Giuffre and related stories. One would expect, increases in associated searching during these periods. Using the Google Keyword Tool, which provides search volume for search queries by month, I examined search volume from January 2015 to the date that I filed this report. There was an 54,518% increase in search volume for the keywords Virginia Giuffre Virginia Roberts Ghislaine Maxwell in January 2015, relative to the prior 7 months, in the US, and a 44,822% increase for the United Kingdom (UK) in January 2015, relative to the prior 7 months. This is in line with the increase in posting of articles during the same month’. So, one sees the expected increase in searching for key terms based on the increase posting of articles. 33 Note: use the US and the UK as sample countries since there are aspect of the story that relate to each country. 33

Case 18-2868, Document 283, 08/09/2019, 2628241, Page435 of 883 62. Figure 5 shows increase in searching volume in January 2015 for the US and UK relative to the previous 7 months. 63. Figure 5: Increase in search volume in January 2015 for the US and UK relative to the previous 7 months for the keyphrase Virginia Giuffre Virginia Roberts Ghislaine Maxwell. USA UK 350000 — e000 ein Sikes 140000 250000 7 200000 150000 000 100000 wouan 0000 20000 se 319 0 0 Average Searching Volume [une- _Searchire Volume lienuary 2015) June Searching Volume Uanuary 2035) December 2014 XII SUMMARY 64. The statements made against Ms. Giuffre have been disseminated to at least 115 online media or other sites in 178 separate stories or articles with a combined 66,909,965 individual unique visitors from 2 January 2015 to the date that I filed this report, inclusive. More likely than not, this is a conservative estimate. 65. Right to Amend: Although I have had access to materials publicly available pertaining to claims in this dispute, I have not been able to review all the material by the deadline for completion of this report. I reserve the right to review and rely on any such material, including at the time of trial. I also reserve the right to issue a supplemental or an amended report if my review of such material results in any significant change or addition to my opinion. 34

Case 18-2868, Document 283, 08/09/2019, 2628241, Page436 of 883 Respectfully submitted, DATED: 09 September 2016 By Dr. Bernard J. Jansen Professor College of Information Sciences and Technology The Pennsylvania State University University Park, PA, 16802 Phone: 434-249-8687 Email: jjansen@acm.orq URL: http://ist.psu.edu/faculty pages/jjansen/ 35

Case 18-2868, Document 283, 08/09/2019, 2628241, Page437 of 883 Appendix A Curriculum Vitae Full Professor College of Information Sciences and Technology The Pennsylvania State University University Park, Pennsylvania 16802, USA Voice: +1-434-249-8687 Fax: 814-865-6426 Email: jiansen@acm.org LinkedIn: www. linkedin.com/in/jjansen/ Blog: http://jimjansen.blogspot.com/ Principal Scientist, Social Computing Group, Qatar Computing Research Institute (QCRI), Hamad Bin Khalifa University, Doha, Qatar Affiliate Appointment, Department of Computer Science and Engineering, The Pennsylvania State University Affiliate Appointment, Department of Industrial and Manufacturing Engineering, The Pennsylvania State University Director, Information Searching and Learning Laboratory, College of Information Sciences and Technology (ISL), The Pennsylvania State University Current Advisory Boards e The Pennsylvania Technical Assistance Program (PennTAP) (http://penntap.psu.edu/) e CLAK Impressions (http://www.linkedin.com/company/clak-impressions) e —Innoblue (http:/Avww.linkedin.com/company/innoblue) Research Research Goal: Increase the effectiveness and efficiency for accomplishing information tasks by improving the interaction among people, information, and technology Research Interests: | study the uses and affordances of the Web for information searching and ecommerce, with a focus on interactions among the person, information, and technology. Current active research areas are Web searching, information retrieval, keyword advertising, online marketing, and online social networking within the ecommerce domain. e Sponsored search and keyword advertising e Social media as an information source e Information searching and Web information retrieval Short Bio: Jim has authored or co-authored 250 or so research publications, with articles appearing in a multi-disciplinary and extremely wide range of journals and conferences. He is author of the book, Understanding Sponsored Search: A Coverage of the Core Elements of Keyword 36

Case 18-2868, Document 283, 08/09/2019, 2628241, Page438 of 883 Research Advertising (Cambridge University Press), author of the book Understanding User - Web Interactions Via Web Analytics, co-author of the book, Web Search: Public Searching of the Web, and co-editor of the book Handbook of Research on Weblog Analysis. Jim is a full professor with the College of Information Sciences and Technology at The Pennsylvania State University and a Principal Scientist in the social computing group of the Qatar Computing Research Institute, Hamad bin Khalifa University. He is a graduate of West Point and has a PhD in computer science from Texas A&M University, along with master degrees from Texas A&M (computer science) and Troy State (international relations). Jim is editor-in-chief of the journal, Information Processing & Management (Elsevier), a member of the editorial boards of seven international journals, former editor-in-chief of the journal, Internet Research (Emerald), and he has served on the research committee for the Search Engine Marketing Professional Organization (SEMPO). He has received several awards and honors, including an ACM Research Award and six application development awards, along with other writing, publishing, research, teaching, and leadership honors. He has served as a Senior Fellow at the Pew Research Center with the Pew Internet and American Life Project and a university expert with the National Ground Intelligence Center. He is a Principle Scientist at the Qatar Computing Research Institute. He has done several consulting projects (log analysis, statistical analysis) and expert witnesses cases (patent litigation, civil litigation, and class action suits) in the areas of keyword advertising, web analytics, co-registration, domain parking, webpage access, webpage history, and online advertising click fraud. Education Ph.D. Computer Science, August 1999 - May 1996 Texas A&M University, College Station, Texas 77843 Dissertation: A Software Agent for Performance Improvement of an Existing Information Retrieval System Advisor: Dr. Udo Pooch M.CS. Computer Science, May 1996 - June 1994 Texas A&M University, College Station, Texas 77843 Research Area: Network Performance and Monitoring M.S. International Relations, August 1994 - June 1992 Troy State University, European Division Research Thesis: National Competitive Advantage B.S. Computer Science, May 1985 - June 1981 United States Military Academy, West Point, New York 10996 Engineering Sequence: Electrical Engineering

Case 18-2868, Document 283, 08/09/2019, 2628241, Page439 of 883 5 5 Current - 2014 Full Professor, College of Information Sciences and Technology, The Pennsylvania State University, University Park, PA, 16802, USA. Current-2015 Principal Scientist, Qatar Computing Research Institute (QCRI), Hamad Bin Khalifa University, Doha, Qatar 2014 - 2011 University Researcher, National Ground Intelligence Center, 2055 Boulders Road, Charlottesville, VA 22911 2014 - 2009 Associate Professor, College of Information Sciences and Technology, The Pennsylvania State University, University Park, PA, 16802, USA. 2012 - 2010 Senior Fellow, Pew Internet and American Life Project, Pew Research Center, 1615 L Street, NW Suite 700 Washington, DC 20036 2009 - 2003 Assistant Professor, College of Information Sciences and Technology, The Pennsylvania State University, University Park, PA, 16802, USA. (Previously, School of Information Sciences and Technology) 2003 - 2001 Instructor, School of Information Sciences and Technology, The Pennsylvania State University, University Park, PA, 16802, USA 2000 - 1999 Lecturer, Computer Science Program, University of Maryland (Asian Division), Seoul, 104-022, Republic of Korea 1999 - 1998 Assistant Professor, Department of Electrical Engineering and Computer Science, United States Military Academy, West Point, New York, 10996 1998 - 1996 Lecturer, Department of Electrical Engineering and Computer Science, United States Military Academy, West Point, New York, 10996, USA. Honors and Awards 2016 2016 President's Award for Engagement with Students, The Pennsylvania State University, University Park, Pennsylvania. 2015 Best Paper: Liu, Z. and Jansen, B. J. (2015) Subjective versus Objective Questions: Perception of Question Subjectivity in Social Q&A. 2015 International Conference on Social Computing, Behavioral-Cultural Modeling, and Prediction (SBP15). Washington DC, p. 131-140. 31 Mar.-3 Apr. 2011 Teaching and Learning with Technology Fellow at Penn State (May 2011 — May 2012). Teaching research fellowship to develop subject-based learning apps that leverage cellular technology, the contextual (location-aware) attributes of mobile technology, and social media. See tit.its.psu.edu/2011/07/24/jim-jansen/

Case 18-2868, Document 283, 08/09/2019, 2628241, Page440 of 883 Honors and Awards 2011 2010 2008 2008 2007 2004 2003 2003 2002 2002 Paper Award: The article, The Seventeen Theoretical Constructs of Information Searching and Information Retrieval, published in Journal of the American Society for Information Science and Technology selected as John Wiley Best JASIST Paper Award 2011 (see http:/Awww.asis.org/awards/jasis_paper.html). Emerald Literati Network 2010 Award for Excellence for Outstanding Reviewer for the journal Internet Research (http://info.emeraldinsight.com/authors/literati/index.htm) Best Paper, Jansen, B. J., Zhang, M., and Schultz, C. (2008) The Effect of Brand on the Evaluation of IT System Performance. Proceedings of the Southern Association for Information Systems Conference, Richmond, VA, USA 13-15 March 2008 Presented with a Google Faculty Research Award ($50,000) Article selected as Highly Commended Winner at the Emerald Literati Network Awards for Excellence 2007. Spink, A. and Jansen, B. J. (2006) Searching multiple federate content Web collections, Online Information Review. 30(5), 485-495. Worldwide press coverage for book Web Search: Public Searching of the Web, coauthored with Dr. Amanda Spink. Including AP, Yahoo! News, CNN, MSN, and numerous other television, radio, Web, and print outlets. Worldwide press coverage and interviews 6/30/2003-7/3/2003 reference article: Jansen, B. J., and Spink, A. (2003) An analysis of Web pages retrieved and viewed, 1C’03: Internet Computing: Web Mining Session, Las Vegas, 4-6 June, 2003. Including: BBC, Irish Radio, Washington Times, Psychology Today, and several U.S. radio stations. ISI Most Highly Cited Articles in Field of Web Searching for the manuscript Jansen, B. J., Spink, A., and Saracevic, T. (2000) Real Life, Real Users, and Real Needs: A Study and Analysis of User Queries on the Web, \nformation Processing & Management. 38(2), 207-227. The article was identified in May 2003 by ISI Essential Science Indicators to be one of the most cited papers in the research area of Web Searching Behavior. Highly Commended Article invited for journal publication. Jansen, B. J. (2002) Towards Implementing a Cognitive Model of Searching, Proceedings of the ELearning 2002 Conference (Web Track), Montreal, Canada. 15-19 October. Two Crystal Awards of Excellence for outstanding software development in the communications field.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page441 of 883 Honors and Awards 2002 2002 2002 2002 2001 2000 1998 1997 1992 1992 Worldwide press coverage and interviews 3/31/02- 4/5/02 reference article: Spink, A., Jansen, B. J., Wolfram, D., and Saracevic, T. (2002). From e-sex to e-commerce: Web search changes, IEEE Computer, 35(3), 133-135. Including: Associated Press, BBC, CBC, MSNBC, Wall Street Journal, New York Times, PC World, CNN, Chinese People’s Daily, Toronto Star, US News and World Report, San Francisco Chronicle, The Independent (UK), Business Week, Washington Post, Financial Times (UK), Information Week, Web, TV, newspaper (200+) and magazine media. Award of Distinction for interactive Web site development. Two Awards of Excellence for exceptional multimedia application development. US Army War College Team of the Year for outstanding contributions as team manager. U.S. Army Visual Information Award for multimedia development. Highly Commended Award by MCB Publishers, for: Spink, A., Bateman, J., and Jansen, B. J. (1999) Searching the Web: A survey of Excite users, Journal of Internet Research: Electronic Networking Applications and Policy, 9(2), 117-128. Top Paper Award for: Spink, A., Bateman, J., and Jansen, B. J. (1998) Users’ searching behavior on the Excite Web search engine, 1999 World Conference on the WWW and Internet, Orlando, Florida. ACM Student Research Award for: Jansen, B. J. (1997) Simulated Annealing for Query Results Ranking, Computer Science Education Conference, San Jose, CA. 28 — 30 February. Writing and Research Award, U.S. Marine Corps University. Research Award from U.S. Army Trainer Journal Books Jansen, B. J. (2011). Understanding Sponsored Search: Coverage of the Core Elements of Keyword Advertising. Cambridge University Press: Cambridge, UK. Jansen, B. J. (2009) Understanding User — Web Interactions via Web Analytics. MorganClaypool Lecture Series. Marchionini, G. (Ed). Morgan-Claypool: San Rafael, CA. Jansen, B. J., Spink, A., and Taksa, |. Editors. (2009) Handbook of Research on Web Log Analysis, Hershey, PA: Idea Group Publishing. 40

Case 18-2868, Document 283, 08/09/2019, 2628241, Page442 of 883 Books Spink, A., and Jansen, B. J. (2004) Web Search: Public Searching of the Web, Dordrecht: Kluwer Academic Publishers. Parts of Books Jansen, B. J. (2016) Log Analysis. Research Methods in Library and Information Science. Libraries Unlimited. Mukherjee, P, Kozlek, B., Gyorke, A., Camplese, C. and Jansen, B. J. (2014) Leveraging Mobile Technology to Enhance Both Competition and Cooperation in an Undergraduate STEM Course. \Innovative Practices in Teaching Information Sciences and Technology: Experience Reports and Reflections. p. 167-178. New York: Springer. Reddy, M. C., Jansen, B. J., Spence, P. R. (2010) Collaborative Information Behavior: Exploring Collaboration and Coordination During Information Seeking and Retrieval Activities. Foster, J. (Ed.), Collaborative Information Behavior: User Engagement and Communication Sharing. p. 73 - 88. Hershey, PA: IGI. Booth, D., and Jansen, B. J. (2009) A review of methodologies for analyzing Websites. |n B. J. Jansen, A. Spink & I. Taksa (Eds.), Handbook of Web Log Analysis. p. 143-164. Hershey, PA: IGI. Jansen, B. J. (2009) The methodology of search log analysis. In B. J. Jansen, A. Spink & I. Taksa (Eds.), Handbook of Web log analysis. p. 100-123. Hershey, PA: IGI. Jansen, B. J., Taksa, I., and Spink, A. (2009) Research and methodological foundations of transaction log analysis. In B. J. Jansen, A. Spink & |. Taksa (Eds.), Handbook of Web Log Analysis. p. 1-17. Hershey, PA: IGI. Rainie, L., and Jansen, B. J. (2009) Surveys as a complementary method to Web log analysis. In B. J. Jansen, A. Spink & |. Taksa (Eds.), Handbook of Web Log Analysis. p. 3964. Hershey, PA: IGI. Taksa, |., Spink, A., and Jansen, B. J. (2009) A review of methods in presented in the handbook of weblog analysis. In B. J. Jansen, A. Spink & |. Taksa (Eds.), Handbook of Web Log Analysis. p. -358. Hershey, PA: IGI. Zhang, M., and Jansen, B. J. (2009) Using action-object pairs as a conceptual framework for transaction log analysis. In B. J. Jansen, A. Spink & Taksa, |. (Eds.), Handbook of Web Log Analysis. p. 416-435. Hershey, PA: IGI. Jansen, B. J. and Spink, A. (2008) Logfile analysis. In International Encyclopedia of Communication. Editors: Robin Mansell. Oxford: Blackwell Press. 6. p. 2730-2734. 41

Case 18-2868, Document 283, 08/09/2019, 2628241, Page443 of 883 Parts of Books Jansen, B. J. and Spink, A. (2008) How to Define Searching Sessions on Web Search Engines. In Lecture Notes in Artificial Intelligence, LNAI 4198, Advances in Web Mining and Web Usage Analysis. Editors: Olfa Nasraoui, Osmar Zaiane, Myra Spiliopoulou, Bamshad Mobasher, Philip Yu, Brij Masand. p. 92 — 109. Berlin Heidelberg: Springer-Verlag. Jansen, B. J., Berkheiser, W, Spink, A., and Pedersen, J. (2007) How people search for governmental information on the Web. In: Encyclopedia of Digital Government. Editors: AriVeikko Anttiroiko and Matti Malkia. p. 933-939. Hershey, PA: Idea Group Publishing. Wolfe, R., Jansen, B. J., and Spink, A. (2006) Semantics and the medical Web: A review of barriers and breakthroughs in effective healthcare query. In: Advances in Electronic Business. Vol. Il. Editors: E. Li and D.C. Timon. p. 267-279. Hershey, PA: Idea Group Publishing. Jansen, K. J., Corley, K. G., and Jansen, B. J. (2006) E-Survey methodology: A review, issues, and implications. \n clopedia of Electronic Surveys ai leasurements (EESM)U. Editors: Jason D. Baker and Robert Woods. p. 1-8. Hershey, PA: Idea Group Publishing. Jansen, B. J. and Spink, A. (2004) An analysis of documents viewing patterns of Web search engine users, In Web Mining: Applications and Techniques. Editor: Anthony Scime. p. 339-354. Hershey, PA: Idea Group Publishing. Jansen, B. J. (2004) The use of query operators and their effect on the results of Web search engines, In Issues of Human Computer Interaction. Editor: Dr. Anabela Sarmento. p. 50-72. Hershey, PA: Idea Group Publishing. Refereed Journal Articles Coughlin, D. and Jansen, B. J. (2016) Modeling Journal Bibliometrics to Predict Downloads and Inform Purchase Decisions at University Research Libraries. Journal of the Association for Information Science and Technology. Liu, Z., and Jansen, B. J. (2016) ASK: A Taxonomy of Information Seeking Posts in Social Question and Answering. Journal of the Association for Information Science and Technology. Liu, Z., and Jansen, B. J. (2016) Understanding and Predicting Question Subjectivity in Social Question and Answering. IEEE Transactions on Computational Social Systems. 3(1), 32-41. Ortiz-Cordova, A. and Jansen, B. J. (2016) Associating Searching on Search Engines to Subsequent Searching on Sites. International Journal of Information Systems in the Service Sector. 8(2), 30-43. 42

Case 18-2868, Document 283, 08/09/2019, 2628241, Page444 of 883 Refereed Journal Articles Coughlin, D., Campbell, M., and Jansen, B. J. (2015) A Web Analytics Approach for Appraising Electronic Resources in Academic Libraries. Journal of the Association for Information Science and Technology. 67(3), 518-534. Ortiz-Cordova, A., Yang, Y., and Jansen, B. J. (2015) External to Internal Search: Associating Searching on Search Engines with Searching on Sites. Information Processing & Management. 51(5), 718-736. Mukherjee, P, Kozlek, B., Jansen, B. J., Gyorke, A., and Camplese, C. (2014) Designing a Mobile and Socially Networked Learning Assistant for a University-level Keyword Advertising Course. MERLOT Journal of Online Learning and Teaching. 10(3), 351-373. Yang, Y., Qin, R., Zhang, J., Zeng, D., and Jansen, B. J. (2014) Budget Planning for Coupled Campaigns in Sponsored Search. International Journal of Electronic Commerce. 18(3), 3966. Mukherjee, P. and Jansen, B. J. (2014) Performance Analysis of Keyword Advertising Campaign Using Gender-Brand Effect of Search Queries. Electronic Commerce Research and Applications. 13(2), 139-149. Jansen, B. J., Liu, Z., and Simon, Z. (2013) The Effect of Ad Rank on Performance of Keyword Advertising Campaigns. Journal of the American Society for Information Science and Technology. 64(10), 2115-2132. Jansen, B. J., Moore, K., and Carman, S. (2013) Evaluating The Performance of Demographic Targeting Using Gender in Keyword Advertising. \Information Processing & Management. 49(1), 286-302. Jansen, B. J., Zhang, L, and Mattila, A. S. (2012) Investigating Brand Knowledge of Web Search Engines: User Reactions to Search Engine Logos. Electronic Commerce Research. 12(4), 429-454. Zhang, L, Jansen, B. J., Mattila, A. S. (2012) A Branding Model for Web Search Engines. International Journal of Internet Marketing and Advertising. 7(3), 195 — 216. Ortiz-Cordova, A. and Jansen, B. J. (2012) Classifying Web Search Queries in Order to Identify High Revenue Generating Customers. Journal of the American Society for Information Science and Technology. 63(7), 1426 — 1441. Zhang, M., Jansen, B. J., and Chowdhury, A. (2011) /nfluence of Business Engagement in Online Word-of-mouth Communication on Twitter: A Path Analysis. Electronic Markets: The International Journal on Networked Business. 21(3), 161-175. Jansen, B. J., Sobel, K., and Zhang, M. (2011) The Brand Effect of Key Phrases and Advertisements in Sponsored Search. International Journal of Electronic Commerce. 6(1), 77106. 43

JASIST Best Paper Highly Cited Case 18-2868, Document 283, 08/09/2019, 2628241, Page445 of 883 Refereed Journal Articles Jansen, B. J., Liu, Z., Weaver, C., Campbell, G. and Gregg, M. (2011) Real Time Search on the Web: Queries, Topics, and Economic Value. Information Processing & Management. 47(4), 491-506. Jansen, B. J., Sobel, K. and Cook, G. (2011) Classifying Ecommerce Information Sharing Behaviour by Youths on Social Networking Sites. Journal of Information Science. 37(2), 120136. Jansen, B. J. and Schuster, S. (2011) Bidding on the Buying Funnel for Sponsored Search Campaigns. Journal of Electronic Commerce Research. 12(1), 1-18. Kuthuria, A., Jansen, B. J., Hafernik, C. (2010) K-means Clustering to Determine User Intent of Web Queries. Journal of Internet Research: Electronic Networking Applications and Policy. 20(5), 563-581. Rosso, M. A. and Jansen, B. J. (2010) Brand Names as Keywords in Sponsored Search Advertising. Communications of the Association for Information Systems. 27(1), Article 6. Available at: http://aisel.aisnet.org/cais/vol27/iss1/6 Jansen, B. J., and Rieh, S. (2010) The Seventeen Theoretical Constructs of Information Searching and Information Retrieval. Journal of the American Society for Information Science and Technology. 61(8), 1517-1534. Jansen, B. J., Tapia, A. H., and Spink, A. (2010) Searching for salvation: An analysis of US religious searching on the World Wide Web, Religion. 40(1), 39-52. Jansen, B. J., Zhang, M, Sobel, K, and Chowdury, A. (2009) Twitter Power: Tweets as Electronic Word of Mouth. Journal of the American Society for Information Science and Technology. 60(11), 2169-2188. Recognized as one of the top 10 most highly cited papers in JASIST published since 2001 http://www.asis.org/Bulletin/Aug-12/AugSep12_Bar-llan.html Jansen, B. J., Booth, D. and Smith, B. (2009) Using the taxonomy of cognitive learning to model online searching. Information Processing & Management. 45(6), 643-663. Tjondronegoro, D., Spink, A., and Jansen, B. J. (2009) A Study and Comparison of Multimedia Web Searching: 1997-2006. Journal_of the American Society for Information Science_and Technology. 60(9), 1756-1768. Jansen, B. J., Zhang, M., and Schultz, C. (2009). Search engine brand and the effect on user perception of searching performance. Journal of the American Society for Information Science and Technology. 60(8), 1572-1595. Flaherty, T. B., Jansen, B. J., Hofacker, C., and Murphy, J. (2009). Insights on the Google Online Marketing Challenge and Its Successful Classroom Implementation. Journal of Online Learning and Teaching, 5(2), 446-457.

Highly Cited Case 18-2868, Document 283, 08/09/2019, 2628241, Page446 of 883 Refereed Journal Articles Jansen, B. J., Booth, D. L., and Spink, A. (2009). Patterns of query modification during Web searching. Journal of the American Society for Information Science and Technology. 60(7), 1358-1371. Jansen, B. J., Flaherty, T.B., Baeza-Yates, R., Hunter, L., Kitts, B., and Murphy, J. (2009). The Components and Impact of Sponsored Search. IEEE Computer. 42(5) 98-101. Rosso, M., McClelland, M. K., Jansen, B. J., and Fleming, S. W. (2009) Using Google AdWords in the MBA MIS Course. Journal of Information System Education. 20(1), 41-50. Zhang, Y., Jansen, B. J., and Spink, A. (2009) Identification of factors predicting clickthrough in Web searching using neural network analysis. Journal of the American Society for Information Science and Technology. 60(3), 557-570. Zhang, Y., Jansen, B. J., and Spink, A. (2009) Time Series Analysis of a Web Search Engine Transaction Log, ion Processi lement. 45(2), 230-245. Jansen, B. J. and Spink, A. (2009) Investigating Customer Click through Behavior with Integrated Sponsored and Non-Sponsored Results, International Journal of Internet Marketing and Advertisement, 5(1/2), 74-94. Jansen, B. J., Ciamacca, C., and Spink, A. (2008) An Analysis of travel searching on the Web, Journal of Information Technology and Tourism. 10(2), 101-118. Jansen, B. J. and Mullen, T. (2008) Sponsored search: An overview of the concept, history, and technology, \International Journal of Electronic Business. 6(2), 114 — 131. Spink, A., and Jansen, B. J. (2008) Trends in searching for business and e-commerce information on Web search engines, |nternational Journal of Electronic Commerce. 9(2), 154161. Jansen, B. J., Booth, D., and Spink, A. (2008) Determining the informational, navigational, and transactional intent of Web queries, Information Processing & Management. 44(3), 12511266. The most cited article in IP&M published since 2008 (http:/Avww.journals.elsevier.com/information-processing-and-management/most-citedarticles/) Jansen, B. J. (2008) Searching for digital Images on the Web, Journal of Documentation. 64(1), 81-101. Jansen, B. J. and Eastman, C. (2008) Limitations of advanced searching techniques on Web search engines, Journal of Electronic Resources in Law Librarianship. 1(1), 55-81. 4S

Highly Cited Case 18-2868, Document 283, 08/09/2019, 2628241, Page447 of 883 Refereed Journal Articles Reddy, M. C. and Jansen, B. J. (2008) A model for understanding collaborative information behavior in context: A study of two healthcare teams, Information Processing & Management. 44 (1), 256-273. One of the Top 25 most cited articles in IP&M published since 2008 (http:/Awww.journals.elsevier.com/information-processing-and-management/most-citedarticles/) Jansen, B. J., Zhang, M., and Spink, A. (2007) Patterns and transitions of query reformulation during Web searching, \nternational Journal of Web Information Systems. 3(4), 328-340. Jansen, B. J., Brown, A., and Resnick, M. (2007) Factors relating to the decision to click-on a sponsored link, Decision Support Systems. 44(1), 46-59. Jansen, B. J. and Spink, A. (2007) Sponsored search: Is money a motivator for providing relevant results?, IEEE Computer. 40(8), 50-55. Jansen, B. J. (2007) Click fraud. IEEE Computer. 40(7), 85-86. Jansen, B. J. (2007) The comparative effectiveness of sponsored and non-sponsored results for Web ecommerce queries, ACM Transactions on the Web. 1(1), Article 3. Jansen, B. J., Spink, A., Blakely, C., and Koshman, S. (2007) Defining a session on Web search engines, Journal of the American Society for Information Science and Technology. 58(6), 862-871. Jansen, B. J., Spink, A., and Koshman, S. (2007) Web searcher interactions with the Dogpile.com meta-search engine, Journal of the American Society for Information Science and Technology. 58(5), 744-755. Jansen, B. J., Mullen, T., Spink, A., and Pederson, J. (2006) Automated gathering of Web information: An in-depth examination of agents interacting with search engines, ACM Transactions on Internet Technology. 6(4), 442-464. Jansen, B. J. and Resnick, M. (2006) An examination of searcher’s perceptions of nonsponsored and sponsored links during ecommerce Web searching, Journal of the American Society for Information Science and Technology. 57(14), 1949-1961. Koshman, S. Spink, A., Jansen, B. J., Park, M., and Fields, C. (2006) Web Searching on the Vivisimo search engine, Journal of the American Society for Information Science and Technology. 57(14), 1875-1887. Spink, A., Jansen, B. J., Blakely, C., and Koshman, S. (2006) Overlap among major search engines, Journal of Internet Research: Electronic Networking Applications and Policy. 16(4), 419-426. 46

Paper Award Most Accessed Case 18-2868, Document 283, 08/09/2019, 2628241, Page448 of 883 Refereed Journal Articles Jansen, B. J. (2006) Search log analysis: What is it; what’s been done; how to do it, Library and Information Science Research, 28(3), 407-432. Spink, A., and Jansen, B. J. (2006) Searching multiple federate content Web collections, Online Information Review. 30(5), 485-495. Spink, A., Partridge, H., and Jansen, B. J. (2006) Sexual/pornographic Web searching: Trends analysis, First Monday. 11(9). http://www.firstmonday.org/issues/issue1 1_9/spink/index.html. Jansen, B. J. (2006) Paid search, IEEE Computer. 39(7), 88-90. Spink, A., Jansen, B. J., Blakely, C., and Koshman, S. (2006) A study of results overlap and uniqueness among major Web search engines, Information Processing & Management. 42(5), 1379-1391. Jansen, B. J. (2006) Using temporal patterns of interactions to design effective automated searching assistance systems, Communications of the ACM. 49(4), 72-74. Jansen, B. J. and Molina, P. (2006) The effectiveness of Web search engines for retrieving relevant ecommerce links, Information Processing & Management. 42(4), 1075-1098. Jansen, B. J. and McNeese, M. D. (2005) Evaluating the effectiveness of and patterns of interactions with automated assistance in IR systems, Journal of the American Society for Information Science and Technology. 56(14), 1480-1503. Jansen, B. J. and Spink, A. (2005) How are we searching the World Wide Web?: An analysis of nine search engine transaction logs, \nformation Processing & Management. 42(1), 248263. Routinely listed as one of the most downloaded articles published in IP&M (http:/Awww.journals.elsevier.com/information-processing-and-management/mostdownloaded-articles/) Spink, A., Park, M., Jansen, B. J., and Pedersen, J. (2005) Multitasking during Web search sessions, Information Processing & Management. 42(1), 264-275. Jansen, B. J., Jansen, K. J., and Spink, A. (2005) Using the Web to look for work: Implications for online job seeking and recruiting, Journal of Internet Research: Electronic Networking Applications and Policy. 15(1), 49-66. Jansen, B. J., Spink, A, and Pederson, J. (2005) Trend analysis of AltaVista Web searching, Journal of the American Society for Information Science and Technology. 56(6), 559-570. Jansen, B. J. (2005) Seeking and implementing automated assistance during the search process, Information Processing & Management. 41(4), 909-928. 47

Highly Cited Highly Cited Case 18-2868, Document 283, 08/09/2019, 2628241, Page449 of 883 Refereed Journal Articles Jansen, B. J., Spink, A., and Pederson, J. (2005) The effect of specialized multimedia collections on Web searching, Journal of Web Engineering. 3(3/4), 182-199. Spink, A. and Jansen, B. J. (2005) A study of Web search trends, Webology. 1(2), Article 4, Available at: http://www.webology.ir/2004/v1n2/a4.html. Jansen, B. J. and Spink, A. (2004) An analysis of Web searching by European Alltheweb.com users, Information Processing & Management. 41(2), 361-381. Spink, A., Jansen, B. J., and Pedersen, J. (2004) Searching for people on Web search engines, Journal of Documentation. 60, (3), 266-278. Spink, A., Yang, Y., Jansen, B. J., Nvkanen, P., Ozmutlu, S., and Ozmutlu, C. (2004) Medical and health Web searching: an exploratory study, Health Information and Libraries Journal. 21(1), 44-51. Jansen, B. J. and Pooch, U. (2004) /mproving IR system performance using software integration, Journal of Internet Research: Electronic Networking Applications and Policy. 14(1), 19-33. Spink, A., Koricich, A., and Jansen, B. J. (2004) Sexual searching on Web search engines, Cyber-psychology and Behavior. 7(1), 65-72. Eastman, C. and Jansen, B. J. (2003) Coverage, relevance, and ranking: the impact of query operators on Web search engine results, ACM Transactions on Information Systems. 21(4), 383-411. Spink, A., Jansen, B. J., Wolfram, D., and Saracevic, T. (2002) From e-sex to e-commerce: Web search changes, IEEE Computer. 35(3), 107-111. Wolfram, D., Spink, A., Jansen, B. J., and Saracevic, T. (2001) Vox populi: The public searching of the Web, Journal of the American Society for Information Science and Technology. 52(12), 1073-1074. Jansen, B. J. and Pooch, U. (2001) Web user studies: A review and framework for future work, Journal of the American Society for Information Science and Technoloay. 52(3), 235246. Recognized as one of the top 10 most highly cited papers in JASIST published since 2001 http:/www.asis.org/Bulletin/Aug-12/AugSep12_Bar-llan.html Spink, A., Wolfram, D., Jansen, B. J., and Saracevic, T. (2001). Searching of the Web: the public and their queries, Journal of the American Society for Information Science and Technology. 52(3), 226-234. Recognized as the most highly cited paper in JASIST published since 2001 http://www.asis.org/Bulletin/Aug-12/AugSep12_Bar-llan.html 48

ISI Paper Award Paper Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page450 of 883 Refereed Journal Articles Brown, G., Fisher, M., Stoll, N., Beeksma, D., Black, M., Taylor, R., Choe, S., Williams, A., Bryant, W., and Jansen, B. J. (2000) Leveraging a Y2K evaluation to improve information systems architecture, Communications of the ACM. 43(10), 90-97. Jansen, B. J., Spink, A., and Saracevic, T. (2000) Real life, real users, and real needs: A study and analysis of user queries on the Web, \nformation Processing & Management. 36(2), 207-227. Jansen, B. J., Goodrum, A., and Spink, A. (2000) Searching for multimedia: video, audio, and image Web queries, World Wide Web Journal. 3(4), 249-254. Spink, A., Jansen, B. J., and Ozmutlu, C. (2000) Use of query reformulation and relevance feedback by Web users, Journal of Internet Research: Electronic Networking Applications and Policy. 10(4), 317-328. Schmoyer, T. and Jansen, B. J. (2000) An adaptive hypermedia system for improving an organization's customer support, WebNet Journal. 2(4), 30-35. Jansen, B. J. (2000) An investigation into the use of simple queries on Web IR systems, Information Research: An Electronic Journal. 6(1). http://informationr.net/ir/6-1/paper87 .html Spink, A., Bateman, J., and Jansen, B. J. (1999) Searching the Web: A survey of Excite users, Journal of Internet Research: Electronic Networking Applications and Policy. 9(2). 117128. Spink, A., Bateman, J., and Jansen, B. J. (1998) Searching heterogeneous collections on the Web: Behavior of Excite users, Information Research: An Electronic Journal. 5(2). http://informationr.net/ir/4-2/paper53.html Jansen, B. J. (1997) Using an intelligent agent to enhance the performance of an information retrieval engine, First Monday. 2(3). http://www. firstmonday.dk/issues/issue2_3/jansen/index.html Book Reviews Jansen, B. J. (2008) Book review: Making Sense of Data: A Practical Guide to Exploratory Data Analysis and Data Mining by Glenn J. Myatt. Wiley. 2007 pages 280. $74.95. Information Processing & Management. 44(2), 978-979. Jansen, B. J. (2007) Book review: The Long Tail: Why the Future of Business is Selling Less or More. By Chris Anderson. Hyperion: New York. 2006. $24.95 ISBN: 1-4013-0237-8. Information Processing & Management. 43(4), 1147-1148. 49

Case 18-2868, Document 283, 08/09/2019, 2628241, Page451 of 883 Book Reviews Jansen, B. J. (2007) Book review: The Craft of Research, 2nd edition (Chicago Guides to Writing, Editing, and Publishing) (Paperback) by Wayne C. Booth, Joseph M. Williams, Gregory G. Colomb. Paperback: 336 pages. University of Chicago Press; 2nd edition. ISBN: 0226065685. Information Processing & Management. 43(3), 827-828. Jansen, B. J. (2007) Book review: Effective Expert Witnessing, Fourth Edition, by Jack V. Matson, Suha F. Daou, and Jeffrey G. Soper. 160 pages. CRC. ISBN: 0849313015. $99.95. Information Processing & Management. 43(3), 830-831. Jansen, B. J. (2007) Book review: Messages, Meanings and Symbols: The Communication of Information. By Charles T. Meadow. Lanham, MD: Scarecrow Press, 2006. 264 pp. $40.00 (paper). ISBN 0-8108-5271-3. Library and Information Science Research. 29(2), 303-304. Jansen, B. J. (2006) Book review: The Search: How Google and Its Rivals Rewrote the Rules of Business and Transformed our Culture. by John Battelle. Penguin Group. 311 pages. Cost: $25.95. ISBN: 1591840880. Information Processing & Management. 42(5), 1399-1401. Jansen, B. J. (2006) Book review: Theories of Information Science Behavior. 2005, Edited by Karen E. Fisher, Sanda Erdelez, and Lynn (Ed.) McKechnie. ASIST Monograph Series. Information Today, Inc. Medford, New Jersey. 431 pages. Cost: $49.50. Information Processing & Management. 42(5), 1392-1395. Jansen, B. J. (2005) Book review: Mining the Web: Discovering Knowledge from Hypertext Data, 2002. Soumen Chakrabarti. Morgan-Kaufmann Publishers, 352 pages. Cost: $54.95. ISBN: 1-55860-754-4. Information Processing & Management. 42(1), 317-318. Non-refereed Articles Jansen, B. J., Chowdhury, A., and Cook, G. (2010) The Ubiquitous and Increasingly Significant Status Message. Interactions. May/June, 15-17. Jansen, B. J., Hudson, K., Hunter, L., Liu, F., and Murphy, J. (2008) The Google Online Marketing Challenge: Real-World Learning with Real Clients, Real Money, and Real Advertising Campaigns, Journal of Interactive Advertising. 9(1), http:/www.jiad.org/article109 Jansen, B. J. (2008) Sponsored search, International Journal of Electronic Business. 6(2), 112-113. Edmonds, A., Hawkey, K., Jansen, B. J., Kellar, M., and Turnbull, D. (2007) Editorial for Special Issue on Logging Traces of Web, Journal of Web Engineering. 6(3), 193-195. Jansen, B. J. (2006) Paid search as an information seeking paradigm, Bulletin of the American Society for Information Science and Technology. 32(2), 7-8. Spink, A., Ozmutlu, S., Ozmutlu, H. C., and Jansen, B. J. (2002) U.S. versus European Web searching trends, SIGIR Forum. 32(1), 30-37. 50

Case 18-2868, Document 283, 08/09/2019, 2628241, Page452 of 883 Non-refereed Articles Jansen, B. J., Riedt, R., and Turner, J. (2002) Hitting the moving technology target, SIGNAL: International Journal of AFCEA. 56(80), 65. Schmoyer, T. and Jansen, B. J. (2001) Personalized computer interaction improves customer service, SIGNAL: International Journal of AECEA. 55(9), 63-65. Jansen, B. J. and Spink, A. (2000) Methodological approach in discovering user search patterns through Web log analysis, Bulletin of the American Society for Information Science and Technology. 27(1), 15-17. Jansen, B. J., Spink, A., Bateman, J., and Saracevic, T. (1998) Real life information retrieval: A study of user queries on the Web, SIGIR Forum. 32(1), 5-17. 128. Crow, D. and Jansen, B. J. (1998) Seminal works in computer human interaction, SIGCHI Bulletin. 30(3), 24-28. Jansen, B. J. (1998) The graphical user interface: An introduction, SIGCHI Bulletin. 30(2), 22-26. Manuscripts Accepted for Publication Liu, Z., and Jansen, B. J. (forthcoming) Predicting the Response Rate in Social Question and Answering on Sino Weibo. Information Processing & Management. Liu, Z., and Jansen, B. J. (forthcoming) /dentifying the Desire to Help: Predicting User Willingness for Knowledge Sharing in Social Question and Answer. \nformation Processing & Management. Manuscripts Submitted for Publication Mukherjee, P. and Jansen, B. J. (under review) Brand Conversing and Brand Searching: A Temporal Analysis of Social Media and Search Concerning Super Bowl 2015 Commercials. Internet Research. Refereed Conference Proceedings Brown, A., Lush, B., and Jansen, B. J. (under review) Pixel Efficiency Analysis: A Methodology for Quantitative Web Analytics for Academic Library and Other Non-commercial Websites. The First International Conference on Information Systems and Applications (ICISA2016), Manama, Kingdom of Bahrain. 17-18 Nov.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page453 of 883 Refereed Conference Proceedings Kwak, H., An, J. and Jansen, B. J. (2017) Automatic Generation of Personas Using YouTube Social Media Data. Hawaii International Conference on System Sciences (HICSS-50). Waikoloa, Hawaii. 4-7 January. Gao, Y., Reddy, M., and Jansen, B. J. (2017) ShopWithMe!: Collaborative Information Searching and Shopping for Online Retail. Hawaii International Conference on System Sciences (HICSS-50). Waikoloa, Hawaii. 4-7 January. Whitman, A. and Jansen, B. J. (2016) Commercial Consequences of Amazon’s Community Forums: The Case of the Kindle. The Second International Workshop on Online Social Networks Technologies (OSNT-2016), 13th ACS/IEEE International Conference on Computer Systems and Applications AICCSA 2016. 29 November - 2 December. An, J., Kwak, H. and Jansen, B. J. (2016) Validating Social Media Data for Automatic Persona Generation. The Second International Workshop on Online Social Networks Technologies (OSNT-2016), 13th ACS/IEEE International Conference on Computer Systems and Applications AICCSA 2016. 29 November - 2 December. Das, A., Das, S.S., Ziegelmayer, J.L., Jansen, B. J. (2016) Attention Allocation and Choice: An Eye-Tracking Study. Annual Meeting of the Society for Judgment and Decision Making (SJDM2016). Boston, Massachusetts, 18-21 November. Brown, A., Lush, B., and Jansen, B. J. (2016) Pixel Efficiency Analysis: A Quantitative Web Analytics Approach. 2016 Annual Meeting of the Association for Information Science and Technology, Copenhagen, Denmark, 14-18 Oct. Mukherjee, P. and Jansen, B. J. (2016) Formality Identification in Social Media Dialogue. 2016 International Conference on Social Computing, Behavioral-Cultural Modeling, and Prediction (SBP16). Washington DC p. 375-380. 21 June-1 July. Wong, J.S., Pursel, B., Divinsky, A., and Jansen, B. J. (2016) An Analysis of Cognitive Learning Context in MOOC Forum Messages. ACM Conference on Human Factors in Computing Systems (CHI2016), San Jose, CA, USA, 7-12 May. Gao, Y, Reddy, M., and Jansen, B. J. (2016) Shopping as Searching: Collaborative Web Search in the Ecommerce Domain. ACM Conference on Human Factors in Computing Systems (CHI2016), San Jose, CA, USA, 7-12 May. Mukherjee, P. and Jansen, B. J. (2016) Second Screen Interaction Analysis for IRL Events: Phase-Category Investigation of the Super Bow! 2015 Social Soundtrack. The 7" International Conference on Information and Communication Systems (ICICS 2016). Irbid, Jordan. 5-7 April. Mukherjee, P. and Jansen, B. J. (2015) Correlation of Brand Mentions in Social Media and Web Searching Before and After Real Life Events: Phase Analysis of Social Media and Search Data for Super Bowl 2015 Commercials. International Workshop on Event Analytics Using Social Media Data, IEEE International Conference on Data Mining (ICDM2015) Atlantic City, New Jersey. 14-17 Nov., p. 21-26.

Paper Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page454 of 883 Refereed Conference Proceedings Wong, J.S., Pursel, B., Divinsky, A. and Jansen, B. J. (2015) Analyzing MOOC Discussion Forum Messages to Identify Cognitive Learning Exchanges. 2015 Annual Meeting of the Association for Information Science & Technology. St. Louis, Mo. 6-10 Nov. Liu, Z., and Jansen, B. J. (2015) Analysis of Question and Answering Behavior in Question Routing Services. 21*' International Conference on Collaboration and Technology (CRIWG 2015). Yerevan, Armenia. 22 — 25 Sept., p.72-85. Liu, Z., and Jansen, B. J. (2015) A Taxonomy for Classifying Questions Asked in Social Question and Answering. ACM CHI Conference on Human Factors in Computing (CHI 2015), Seoul, South Korea, 18-23 Apr. Coughlin, D. and Jansen, B. J. (2015) Predicting Downloads of Academic Articles To Inform Online Content Management. 6" International Conference on Information and Communication Systems (ICICS2015). Amman, Jordan. 8-9 Apr. Wong, J.S., Pursel, B., Divinsky, A. and Jansen, B. J. (2015). An Analysis of MOOC Discussion Forum Interactions from the Most Active Users. 2015 International Conference on Social Computing, Behavioral-Cultural Modeling, and Prediction (SBP15). Washington DC, p. 452-457. 31 Mar.-3 Apr. Liu, Z., and Jansen, B. J. (2015) Subjective versus Objective Questions: Perception of Question Subjectivity in Social Q&A. 2015 International Conference on Social Computing, Behavioral-Cultural Modeling, and Prediction (SBP15). Washington DC p. 131-140. 31 Mar.-3 Apr. Mukherjee, P. and Jansen, B. J. (2015) Analyzing Second Screen Based Social Soundtrack of TV Viewers from Diverse Cultural Settings. 2015 International Conference on Social Computing, Behavioral-Cultural Modeling, and Prediction (SBP15). Washington DC p. 375380. 31 Mar.-3 Apr. Ortiz-Cordova, A. and Jansen, B. J. (2015) The Relationship Between Searching on Search Engines and Searching on Sites. \nternational Conference on Information Systems and Technologies (ICIST’2015). Istanbul, Turkey. 21-23 March. Mukherjee, P. and Jansen, B. J. (2015) Evaluating Pattern for Group Interactions using Second Screens. In Computing, Networking and Communications Workshop (CNC), 2015 International Conference on Computing, Networking and Communications, Anaheim, CA. 1619 Feb. Mukherjee, P. and Jansen, B. J. (2015) Evaluating Classification Schemes for Second Screen Interactions, 2015 International Conference on Computing, Networking and Communications, Anaheim, CA. 16-19 Feb. Mukherjee, P., Wong, J.S., and Jansen, B. J. (2014) Patterns of Social Media Conversations Using Second Screens. The Sixth ASE International Conference on Social Computing (SocialCom 2014). Stanford, CA. 27-31 May.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page455 of 883 Refereed Conference Proceedings Liu, Z., and Jansen, B. J. (2014) Predicting Potential Responders in Social Q&A Based on non-QA Features. ACM CHI Conference on Human Factors in Computing (CHI 2014), p. 2131-2136. Toronto, Canada. 26 April - 1 May. Ortiz-Cordova, A. and Jansen, B. J. (2014) Linking External and Internal Search: Investigating the Site Searching Patterns of Referred Searchers. ACM CHI Conference on Human Factors in Computing Systems (CHI 2014), p. 1345-1350. Toronto, Canada. 26 April 1 May. Mukherjee, P. and Jansen, B. J. (2014) Significance of Second Screen Interaction during Television Viewing. The 2013 International Conference on Social Computing, BehavioralCultural Modeling, and Prediction (SBP), Washington DC. 2-4 April. Coughlin, D. M., Campbell, M. C., and Jansen, B. J. (2013) Measuring the Value of Library Content Collections. 76th Annual Meeting of the American Society for Information Science and Technology (ASIST 2013). Montreal, Canada. 1-6 November. Mukherjee, P. and Jansen, B. J. (2013) Gender-Brand Effect of Search Queries on Sponsored Search Performance. 76th Annual Meeting of the American Society for Information Science and Technology (ASIST 2013). Montreal, Canada. 1-6 November. Ortiz-Cordova, A. and Jansen, B. J. (2013) Site-Searching Strategies of Searchers Referred from Search Engines. 76th Annual Meeting of the American Society for Information Science and Technology (ASIST 2013). Montreal, Canada. 1-6 November. Liu, Z. and Jansen, B. J. (2013) Question and Answering Made Interactive: An Exploration of Interactions in Social Q&A. Proceedings of the International Conference on Social Intelligence and Technology 2013 (SOCIETY 2013), p. 1-10. State College, Pennsylvania USA, 8 -9 May. Hafernik, C. and Jansen, B. J. (2013) Understanding the specificity of web search queries. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI2013), p. 1845-1850. Paris France, 27 April —- 2 May. Mukherjee, P. and Jansen, B. J. (2013) The gender-brand effect of key phrases on user clicks in sponsored search. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI 2013), p. 1845-1850. Paris France, 27 April — 2 May. Liu, Z. and Jansen, B. J. (2013) Analysis of Factors Influencing the Response Rate in Social Question and Answering. 16th ACM Conference on Computer Supported Cooperative Work and Social Computing (CSCW 2013), p. 1263-1274. 23-27 February. San Antonio, Texas. Liu, Z. and Jansen, B. J. (2012) Almighty Twitter, What Are People Asking For?. 75th Annual Meeting of the American Society for Information Science and Technology (ASIST 2012), p.110. 26-30 October. Baltimore, MD.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page456 of 883 Refereed Conference Proceedings Carman, S., Strong, R., Chandra, A.., Oh, S., Spangler, S., Anderson, L., and Jansen, B. J. (2012) Predictive Value of Comments in the Service Engagement Process. 75th Annual Meeting of the American Society for Information Science and Technology (ASIST 2012). 2630 October. Baltimore, MD. Purao, S., Storey, V., Maass, W., Jansen, B. J., and Reddy, M. (2012) An Integrated Conceptual Model to Incorporate Information Tasks in Workflow Models. 31st International Conference on Conceptual Modeling (ER 2012). 15-18 October. Florence, Italy. Hafernik, C.T., Cheng, B., Francis, P. and Jansen, B. J. (2011) Mapping User Search Queries to Product Categories. 74th Annual Meeting of the American Society for Information Science and Technology (ASIST 2011). 9-13 October. New Orleans, LA. Jansen, B. J., Liu, Z. and Simon, Z. (2011) Investigating the Effect of Results Ranking in Sponsored Search. 4th Annual Meeting of the American Society for Information Science and Technology (ASIST 2011). 9-13 October. New Orleans, LA. Tapia, A., Bajpai, K., Jansen, B. J., Yen, J., Giles, C., and Mitra, P. (2011) Seeking the Trustworthy Tweet: Can Microblogged Data Fit the Information Needs of Disaster Response and Humanitarian Relief Organizations. Proceedings of the 8th International Conference on Information Systems for Crisis Response and Management (ISCRAM 2011), 8-11 May, Lisbon, Portugal. Caragea, C., McNeese, N., Jaiswal, A., Traylor, G., Kim, H.W., Mitra, P., Wu, D., Tapia, A.H., Giles, L., Jansen, B. J., and Yen, J. (2011) Classifying Text Messages for the Haiti Earthquake. Proceedings of the 8th International Conference on Information Systems for Crisis Response and Management (ISCRAM 2011), 8-11 May, Lisbon, Portugal. Jansen, B. J. Sobel, K. and Cook, G. (2011) Being Networked and Being Engaged: The Impact of Social Networking on eCommerce Information Behavior. Proceedings of the iConference 2011, 8-11 February, Seattle, WA, USA. Jansen, B. J. and Booth, D. (2010) Classifying Web Queries by Topic and User Intent. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI2010), p. 4285-4290. Atlanta, GA, 10 — 15 April. Jansen, B. J. Sobel, K. and Cook, G. (2010) Gen X and Y's Attitudes on Using Social Media Platforms for Opinion Sharing. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI2010), p. 3853-3858. Atlanta, GA, 10 — 15 April. Jansen, B. J., Campbell, G. and Gregg, M. (2010) Real Time Search User Behavior. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI2010), p. 3961-3966. Atlanta, GA, 10 -— 15 April. Jansen, B. J. and Solomon, L. (2010) Gender Demographic Targeting in Sponsored Search. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI2010), p. 831-840. Atlanta, GA, 10 — 15 April.

Best Paper Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page457 of 883 Refereed Conference Proceedings Jansen, B. J., Zhang, M., Booth, B. Park, D., Zhang, Y., Kathuria, A. and Bonner, P. (2009) To What Degree Can Log Data Profile a Web Searcher? Proceedings of the American Society for Information Science and Technology 2009 Annual Meeting. Vancouver, British Columbia. 6-11 November. Srivatsan, V. R., Purao, S., Jansen, B. J., and He, J. (2009) Systems Developers Define their Own Information Needs. 15th Americas Conference on Information Systems. San Francisco, California. 06-09 August. Jansen, B. J., Zhang, M, Sobel, K, and Chowdhury, A (2009) Micro-blogging as Online Word of Mouth Branding. ACM Conference on Computer Human Interaction (CHI2009). p. 38593864. Boston, Massachusetts. 4 - 9 April. Jansen, B. J., Booth, D. and Spink, A (2009) Predicting Query Reformulation During Web Searching. ACM Conference on Computer Human Interaction (CHI2009). p. 3907-3912. Boston, Massachusetts. 4 - 9 April. Zhang, M. and Jansen, B. J. (2009) Influences of Mood on Information Seeking Behavior. ACM Conference on Computer Human Interaction (CHI2009. p. 3395-3400. Boston, Massachusetts. 4 - 9 April. Spink, A. and Jansen, B. J. (2008) The 8th International We-B (Working For E-Business) Conference 2008. Melbourne, Australia. 28 — 30 November. Reddy, M., Jansen, B. J., and Krishnappa, R. (2008) The Role of Communication in Collaborative Information Searching. 2008 Annual Meeting of the American Society for Information Science and Technology. 24-29 October Columbus, Ohio. Jansen, B. J., Zhang, M., and Schultz, C. (2008) The Effect of Brand on the Evaluation of IT System Performance. Proceedings of the Southern Association for Information Systems Conference, Richmond, VA, USA 13-15 March 2008. Tjondronegoro, D., Spink, A., & Jansen, B. J. (2007) Multimedia Searching on the Dogpile Web Meta-Search Engine. ADCS 2007: Australian Document Computing Symposium. Melbourne, Australia. 10 December. Spink, A., and Jansen, B. J. (2007) Commerce Related Web Search: Current Trends, The 18" Australasian Conference on Information Systems. Toowoomba, Australia. 5-7 December. Zhang, Y. and Jansen, B. J. (2007) An Analysis of Searchers’ Perceptions of Sponsored and Non-Sponsored Links Using Nested Design, 2007 Annual Meeting of the American Society for Information Science and Technology. Milwaukee, Wisconsin, 18-25 October. Jansen, B. J. (2007) Investigating the Relevance of Sponsored Results, The 30" Annual International ACM Special Interest Group on Information Retrieval. Conference (SIGIR), p. 859 — 860, Amsterdam, the Netherlands. 23-27 July.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page458 of 883 Refereed Conference Proceedings Jansen, B. J., Smith, B., and Booth, D. (2007) Viewing Online Search Within a Learning Paradigm, The 30" Annual International ACM Special Interest Group on Information Retrieval. Conference (SIGIR), p. 859 — 860. Amsterdam, the Netherlands. 23-27 July. Jansen, B. J., Zhang, M., and Zhang, Y. (2007) Brand Awareness and the Evaluation of Search Results, 16th International World Wide Web Conference (WWW2007), p. 1139 — 1140. Banff, Canada. 8-12 May. Jansen, B. J., Smith, B., and Booth, D. (2007) Understanding Web Search via a Learning Paradigm, 16th International World Wide Web Conference (WWW2007), p. 1207 — 1208. Banff, Canada. 8-12 May. Jansen, B. J., Booth, D., and Spink, A. (2007) Determining the User Intent of Web Search Engine Queries, 16th International World Wide Web Conference (WWW2007), p. 1149 — 1150. Banff, Canada. 8-12 May. Jansen, B. J., Zhang, M., and Zhang, Y. (2007) The Effect of Brand Awareness on the Evaluation of Search Engine Results, Conference on Human Factors in Computing Systems (SIGCHI), Work-in-Progress, p. 2471 — 2476. San Jose, California. 28 April - 3 May. Spink, A., and Jansen, B. J. (2006) Changing Web search trends from 1997 to 2006, Information Online 2007: 13th Exhibition and Conference. Sydney, Australia. 30 January - 1 February. Yan, S., Giles, C. and Jansen, B. J. (2006) Formal Definitions of Web Information Search, American Society for Information Science & Technology 2006 Annual Meeting, p. 1-10. Austin, Texas. 3 - 8 November. Zhang, M., Jansen, B. J., and Spink, A. (2006) /nformation Searching Tactics of Web Searchers, American Society for Information Science & Technology 2006 Annual Meeting. Austin, Texas, p. 1-10. 3 - 8 November. Koshman, S. Spink, A., Jansen, B. J., Blakely, C., and Weber, J. (2006) Metasearch Result Visualization: An Exploratory Study, 2006 Annual Conference of the Canadian Association for Information Science, p. 1-10. Toronto, Canada. 1-3 June. http://cais-acsi.ca/proceedings/2006/koshman_2006.pdf Jansen, B. J., Spink, A., Blakely, C., and Koshman, S. (2006) /nvestigating Usage of the Vivisimo Clustering Search Engine Interface, The Twelfth Australasian World Wide Web Conference (AUSWEB 06). Noosa Lakes, Australia. 1 -5 July. http://ausweb.scu.edu.au/aw06/papers/refereed/spink/index.html Spink, A., Jansen, B. J., Blakely, C., and Koshman, S. (2006) Overlap Among Major Web Search Engines, IEEE Information Technology: New Generations (ITNG) 2006. p. 370 — 374. Las Vegas, NV. 10 — 12 April.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page459 of 883 Refereed Conference Proceedings Jansen, B. J., Spink, A., Blakely, C., and Koshman, S. (2005) Web Searcher Interactions with Multiple Federate Content Collections, Proceedings of the 10th Australasian Document Computing Symposium. Sydney, Australia. 12 December. Jansen, B. J., Koshman, S., and Spink A. (2005) An Analysis of Repeat Users of Vivisimo.com, American Society for Information Science & Technology 2005 Annual Meeting. Charlotte, North Carolina. 28 October — 2 November. Doran, S. G., de Ycaza, S., Eastman, C. and Jansen, B. J. (2005) Finding Nutrition Information on the Web: Coverage vs. Authority, American Society for Information Science & Technology 2005 Annual Meeting. Charlotte, North Carolina. 28 October — 2 November. Spink, A., Koshman, S. and Jansen, B. J. (2005) Tracking Web Search Trends from 1997 to 2005, Internet Research 6.0: Internet Generations Association of Internet Researchers. Chicago, IL. 5 — 9 October. Resnick, M, and Jansen, B. J. (2005) An Empirical Study of Paid Search in Product Search and Purchase, The Human Factors and Ergonomics Society 49th Annual Meeting. p. 14291433. Orlando, Florida. 26-30 September. Sharma, H. and Jansen, B. J. (2005) Automated Evaluation of Search Engine Performance via Implicit User Feedback, The 28th Annual International ACM SIGIR Conference on Research and Development in Information Retrieval. p. 649-650. Salvador, Brazil. 15-19 August. Morgan, A., Jansen, B. J., and Trauth, E. (2005) Exploring Individual User Attitudes Towards Performance with Web Search Engines: An Extension Study, Proceedings of the Eleventh Americas Conference on Information Systems. p. 2317 — 2324. Omaha, Nebraska. 11-14 August. Koshman, S. Spink, A., and Jansen, B. J. (2005) Using Clusters on the Vivisimo Web Search Engine, HCI International 2005. p. 742-747. Las Vegas, Nevada. 22-25 July. Sengupta, S. and Jansen, B. J. (2005) Designing a Value Based Search Engine Using Evolutionary Strategies, IEEE 6th International Conference on Information Technology, Coding and Computing, p. 800-805. Las Vegas, Nevada. 11-13 April. Spink, A., Koshman, S., Park, M., Field, C. and Jansen, B. J. (2005) Multitasking Web Search on Vivisimo.com. IEEE 6th International Conference on Information Technology, Coding and Computing. p. 486-490. Las Vegas, Nevada, 11-13 April. Eastman, C. and Jansen, B. J. (2004) The Appropriate (and Inappropriate) Use of Query Operators and Their Effect on Web Search Engine Results, American Society for Information Science & Technology 2004 Annual Meeting, p. 274-279. Providence, Rhode Island. 13-18 November.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page460 of 883 Refereed Conference Proceedings Spink, A., Park, M., Jansen, B. J., and Pederson, J. (2004) Information Task Switching and Multitasking Web Search, Proceedings of the American Society for Information Science & Technology 2004 Annual Meeting, p. 213-217. Providence, Rhode Island. 13-18 November. Jansen, B. J. and McNeese, M. D. (2004) Investigating Automated Assistance and Implicit Feedback for Searching Systems, Proceedings of the American Society for Information Science & Technology 2004 Annual Meeting, p. 280-286. Providence, Rhode Island. 13-18 November. Jansen, B. J. and McNeese, M. D. (2004) Evaluating the Effectiveness of Automated Assistance for Web Searching, Proceedings of the Human Factors and Ergonomics Society 48th Annual Meeting, p. 1518-1522. New Orleans, Louisiana. 20-24 September. Spink, A., Park, M., Jansen, B. J., and Pederson, J. (2004) Multitasking Web Search on AltaVista, Proceedings of the IEEE 5th International Conference on Information Technology, Coding and Computing, p. 309-313. Las Vegas, Nevada. 5-7 April. Jansen, B. J., Spink, A., and Pederson, J. (2003) An Analysis of Multimedia Searching on AltaVista, Proceedings of the 5th ACM SIG Multimedia International Workshop on Multimedia Information Retrieval, p.186-192. Berkeley, California. Jansen, B. J. (2003) Designing Automated Help Using Searcher System Dialogues, Proceedings of the 2003 IEEE International Conference on Systems, Man & Cybernetics, p. 744-749. Washington, D.C. 5-8 October. Jansen, B. J., Spink, A., and Pederson, J. (2003) Web Search Agents: What Are They Doing Out There? Proceedings of the 2003 IEEE International Conference on Systems, Man & Cybernetics, p. 1410-1416. Washington, D.C. 5-8 October. Jansen, B. J., Spink, A., and Pederson, J. (2003) Monsters at the Gates: When Softbots Visit Web Search Engines, Proceedings of the 4” International Conference on Internet Computing, Lap. p. 620-626. Vegas, Nevada. 23-26 June. Spink, A., Abbas, M., and Jansen, B. J. (2003) Accessing E-commerce Web Information: Implications for Bridging the Digital Divide, The 2003 Canadian Association for Information Science Conference, p. 213-221. Halifax, CA. 28 May-1 June. Jansen, B. J. and Spink, A. (2003) An Analysis of Web Information Seeking and Use: Documents Retrieved Versus Documents Viewed, Proceedings of the 4” International Conference on Internet Computing, p. 65-69. Las Vegas, Nevada, 23-26 June. Jansen, B. J. (2003) Operators Not Needed? The Impact of Query Structure on Web Searching Results, Information Resource Management Association International Conference, p. 814-817. Philadelphia, PA, 18-21 May. Duran, S., Eastman, C., and Jansen, B. J. (2003) Nutritional Information on the Web: An Analysis of Information Sought and Information Provided, Information Resource Management Association International Conference, p. 106-108. Philadelphia, PA. 18-21 May. 59

Paper Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page461 of 883 Refereed Conference Proceedings Jansen, B. J. and Spink, A. (2003) Retrieving and Viewing Web Documents, The 2003 National Online Meeting, p. 55-57. New York, New York, 6-8 May 2003. Jansen, B. J. and Eastman, C. (2003) The Effects of Search Engines and Query Operators on Top Ranked Results, The IEEE 4th International Conference on Information Technology, Coding and Computing, p. 135-139. Las Vegas, Nevada, 28-30 April. Jansen, B. J. and Kroner, G. (2003) The Impact of Automated Assistance on the Information Retrieval Process, The ACM SIGCHI 2003 Conference on Human Factors in Computing Systems, p. 1004-1006. Fort Lauderdale, Florida, 5-10 April. Jansen, B. J. (2002) Towards Implementing a Cognitive Model of Searching, Proceedings of the E-Learning 2002 Conference (Web Track), p. 493-521. Montreal, Canada, 15-19 October. Jansen, B. J. (2002) A Preliminary Mapping of Web Queries Using Existing Image Query Schemes, Proceedings of the E-Learning 2002 Conference (Web Track), p. 485-492. Montreal, Canada, 15-19 October. Jansen, B. J., Spink, A., and Pfaff, A. (2000) Linguistic Aspects of Web Queries, Proceedings of the Annual Meeting of the American Society of Information Science, p. 169-176. Chicago, IL. 13-16 November. Jansen, B. J., Spink, A., Goodrum, A., and Pfaff, A. (2000) Web Query Structure: Implications for IR System Design, Proceedings of the 4" World Multiconference on Systems, Cybernetics and Informatics, p. 50-55. Orlando, FL. 23-26 July. Jansen, B. J. (1999) A Software Agent for Performance Improvement of Existing Information Retrieval Systems, Proceedings of the 1999 International ACM Conference on Intelligent User Interfaces, p. 122-123. Los Angeles, CA. 5-8 January. Smith, T. L., Ruocco, A., and Jansen, B. J. (1999) Digital Video in Education, Proceedings of the ACM Computer Science Education Conference, p. 122-126. New Orleans, LA. 21-25 February. Jansen, B. J., Spink, A., and Saracevic, T. (1999) The Use of Relevance Feedback on the Web: Implications for Web IR System Design, 1999 World Conference on the WWW and Internet, Honolulu, Hawaii. 24-30 October. Jansen, B. J. and Pooch, U. (1999) A Software Agent for Performance Improvement of an Existing Information Retrieval Engine, 5" International Conference on Information Systems Analysis and Synthesis, p. 58-60. Orlando, Florida. 31 July-4 August. Adams, W. J., Jansen, B. J., and Smith, T. L. (1999) Planning, Building, and Using a Distributed Digital Library, Third International Conference on Concepts in Library and Information Science, p. 10-18. Dubrovnik, Croatia. 23-26 May. 60

Paper Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page462 of 883 Refereed Conference Proceedings Smith, T. L., Wolfe, D., and Jansen, B. J. (1999) Digital Video in a Twenty-First Century Classroom, Proceedings of the Information Resources Management Association Conference, Hershey, PA. 16-19 May. Adams, W. J. and Jansen, B. J. (1998) Distributed Digital Library architecture: The Key to Success for Distance Learning, Proceedings of the IEEE Conference on Research Issues in Data Engineering, p. 2-8. Orlando, Florida. 23-24 February. Spink, A., Chang, C., Goz, A., and Jansen, B. J. (1998) User' Interactions with the Excite Web Search Engine: A Query Reformulation and Relevance Feedback Analysis, Proceedings of the Canadian Association of Information Science Conference, p. 342-354. Vancouver, Canada. 5 —10 June. Jansen, B. J., Spink, A., and Saracevic, T. (1998) Searchers, the Subjects They Search, and Sufficiency: A Study of a Large Sample of Excite Searches, Proceedings of the 1998 World Conference on the WWW and Internet, Orlando, Florida. Spink, A., Bateman, J., and Jansen, B. J. (1998) Users’ Searching Behavior on the Excite Web Search Engine, 1998 World Conference on the WWW and Internet, Orlando, Florida, November. Howard, R. and Jansen, B. J. (1998) A proxy server experiment: an indication of the changing nature of the Web, Proceedings of the Seventh International Conference on Computer Communications and Networks, p. 646-649. Lafayette, Louisiana. 12-15 November. Adams, W. J., Jansen, B. J., and Zoller, R. (1998) Usability Measurements in an Undergraduate Programming Course, Software Engineering Conference, Las Vegas, Nevada. Jansen, B. J., Spink, A., and Saracevic, T. (1998) Failure analysis in Query Construction: Data and Analysis from a Large Sample of Web Queries, Proceedings of the 3° ACM Conference on Digital Libraries, p. 289-290. Pittsburgh, PA. 23-26 July. Spink, A., Bateman, J., and Jansen, B. J. (1998) User's Searching Behavior on the EXCITE Web Search Engine, Proceedings of the 19th National Online Meeting, p. 375-386. New York, NY. 12-14 May 1997. Adams, W. J., Howard, R., and Jansen, B. J. (1998) Distributed Digital Libraries: The Key to Success for Distance Learning, Computers and Technology in Education, 1 -5 May. Cancun, Mexico. Jansen, B. J. (1997) An Information Retrieval Application for Simulated Annealing, Proceedings of the 2nd ACM Conference on Digital Libraries, p. 259-260. Philadelphia, PA. 25-28 July. Jansen, B. J. (1997) Simulated Annealing for Query Results Ranking, Computer Science Education Conference, San Jose, CA. 28 — 30 February. 61

Case 18-2868, Document 283, 08/09/2019, 2628241, Page463 of 883 Refereed Conference Proceedings Spink, A., Burkett, L., Spaid, N., Bateman, J., and Jansen, B. J. (1997) Why Users Search the World Wide Web (WWW): The EXCITE Study, First Internet Librarian Conference, Monterey, CA. 16-18 November. Adams, W. J. and Jansen, B. J. (1997) /nformation Technology and the Classroom of the Future, Proceedings of the Society for Information Technology in Education Conference, Orlando, Florida. 7 May. Hamilton, J. A. and Jansen, B. J. (1997) Tactical Network Simulation in the US Army, Simulation Multi-Conference, Atlanta, Georgia. January. Jansen, B. J. and Hamilton, J. A. (1997) Modeling and Simulating an Army Information Support Structure, Simulation Multi-Conference, Atlanta, Georgia. January. Papers Presented at Technical and Professional Meetings An, J., Cho, H.Y., Kwak, H., and Jansen, B. J. (2016) Towards Automatic Persona Generation Using Social Media. The Third International Symposium on Social Networks Analysis, Management and Security (SNAMS 2016), The 4th International Conference on Future Internet of Things and Cloud. 22-24 August. Mukherjee, P. and Jansen, B. J. (2016) The Changing Nature of Viewership: Formality of Social Media Conversations. Workshop on Following user pathways: Using cross platform and mixed methods analysis in social media studies. ACM Conference on Human Factors in Computing Systems (CHI2016), San Jose, CA, USA, 7-12 May. Kwon, S., Abbar, S. and Jansen, B. J. (2016) /dentifying Virality Attributes of Arabic Language News Articles. Qatar Foundation Annual Research Conference 2016 (ARC'16), Doha, Qatar. 22 March. An, J., Kwan, H., Cho, H., Hassen, M.Z., and Jansen, B. J. (2016) Efforts Towards Automatically Generating Personas in Real-time Using Actual User Data. Qatar Foundation Annual Research Conference 2016 (ARC'16), Doha, Qatar. 22 March. Mukherjee, P. and Jansen, B. J. (2015) Correlation of Brand Mentions in Social Media and Web Searching Before and After Real Life Events: Phase Analysis of Social Media and Search Data for Super Bowl 2015 Commercials. 1st International Workshop on Event Analytics using Social Media Data at The IEEE International Conference on Data Mining series (ICDM 2015), Atlantic City, New Jersey, USA, 14 Nov. Mukherjee, P. and Jansen, B. J. (2015) Analyzing the Social Soundtrack From Second Screens Before, During, and After Real-life Events. The First International Workshop on Online Social Networks Technologies, 2015 IEEE Jordan Conference on Applied Electrical Engineering and Computing Technologies (AEECT), Dead Sea, Jordan. 3-5 Nov. 62

Case 18-2868, Document 283, 08/09/2019, 2628241, Page464 of 883 Papers Presented at Technical and Professional Meetings Jansen, B. J., Wong, J. S., Jablokow, K.W., Divinsky, A., Liu, Z., and Pursel, B. (2014) Classifying MOOC Discussion Forum Posts as Information Seeking Interactions and Levels of Cognitive Learning. Workshop on Learning at Scale at ACM CHI Conference on Human Factors in Computing Systems, (CHI 2014), Toronto, CA. 26 April - 1 May. Liu, Z. and Jansen, B. J. (2012) Factors Influencing the Response Rate in Social Question and Answering Behavior. Workshop on Social Media Question Asking at 16th ACM Conference on Computer Supported Cooperative Work and Social Computing (CSCW 2013). 23-27 February. San Antonio, Texas. Jansen, B. J. (2012) Gender Demographic Targeting in Sponsored Search. INFORMS International 2012. 24-27 June. Beijing, China. Jansen, B. J. (2012) Using Mobile Apps to Enhance Classroom Learning. Teaching and Learning with Technology, University Park, PA, 24 March Rosso, M. and Jansen, B. J. (2010) Smart Marketing or Bait & Switch? Competitors’ Brands as Keywords in Online Advertising. 4th Workshop on Information Credibility on the Web (WICOW 2010). World Wide Web Conference (WWW 2010), Raleigh, NC. 26-30 April. Jansen, B. J. (2009) System Controlled Assistance for Improving Search Performance. Human-Computer Interaction and Information Retrieval. Workshop. Washington, DC. 23 October. Jansen, B. J., Zhang, M, Sobel, K, and Chowdury, A, (2009) The Commercial Impact of Social Mediating Technologies: Micro-blogging as Online Word-of-Mouth Branding. ACM Conference on Computer Human Interaction (CHI2009). Boston, Massachusetts. 4 - 9 April. Neale, L., Hunter, L., Jansen, B. J., Murphy, J. (2008) The Google Online Marketing Challenge: A Global Teaching and Learning Initiative. 2008 Society for Marketing Advances Annual Conference. 4-9 November. St Petersburg, Florida. Jansen, B. J., Rosso, M., Russell, D., and Detlor, B. (2008) The Google Online Marketing Challenge: A Multi-Disciplinary Global Teaching and Learning Initiative Using Sponsored Search. 2008 Annual Meeting of the American Society for Information Science and Technology. 24-29 October Columbus, Ohio. Jansen, B. J. (2008). Viewing Searching Systems as Learning Systems. Second Workshop on Human-Computer Interaction and Information Retrieval. 23 October. Redmond, Washington. Murphy, J., Canhoto, A., Hofacker, C., Hunter, L., Jansen, B. J., and Voorhees, C. (2008) The Google Online Marketing Challenge: A Global Teaching and Learning Initiative. 2008 American Marketing Association Summer Marketing Educators' Conference. 8-11 August. San Diego, California. 63

Case 18-2868, Document 283, 08/09/2019, 2628241, Page465 of 883 Papers Presented at Technical and Professional Meetings Reddy, M. and Jansen, B. J. (2008) Learning about Potential Users of Collaborative Information Retrieval Systems. Workshop on Collaborative Information Retrieval, Joint Conference on Digital Libraries (JCDL 2008). 19 June. Pittsburgh, Pennsylvania. Jansen, B. J., Bhavnani, S., Murray, G. C., Spink, A. and Wolfram, D. (2007) Web Log Analysis Panel, 2007 Annual Meeting of the American Society for Information Science and Technology. Milwaukee, Wisconsin. 18-25 October. Spink, A. and Jansen, B. J. (2007) Web Research - Results from Large-Scale Web Data Analysis, ARC Research Network Enterprise Information Infrastructure Workshop on Data From the Field. Sydney, Australia. 24th May. Jansen, B. J. and Spink, A. (2007) The Effect on Click-through of Combining Sponsored and Non-Sponsored Search Engine Results in a Single Listing, 16th International World Wide Web Conference (WWW2007) Workshop on Sponsored Search Auctions. Banff, Canada. 812 May. Paper: http://opim.wharton.upenn.edu/ssa3/pdf/submission_96.pdf Jansen, B. J. (2007) Preserving the Collective Expressions of the Human Consciences, 16th International World Wide Web Conference (WWW2007) Workshop on Query Log Analysis: Social and Technical Challenges. Banff, Canada. 8-12 May. Paper: http://www2007.org/workshops/paper_58.pdf Slides: http://querylogs2007.webir.org/slides/JimJansenQL2007.pdf Jansen, B. J., Smith, B., and Booth, D. (2007) Learning as a Paradigm for Understanding Exploratory Search, Conference on Human Factors in Computing Systems (SIGCHI ), Workshop on Exploratory Search Interfaces. San Jose, California. 28 April - 3 May. Spink, A., Alvarado-Albertorio, F., and Jansen, B. J. (2007) Web Search Behavior: What is Normative?, Society of Australasian Social Psychologists (SASP) Conference. Brisbane, Australia. 12 — 15 April. Jansen, B. J. and Spink, A. (2006) Characteristics of searching on Web meta-search engines, American Society for Information Science and Technology: Human Computer Interaction Workshop. Austin, TX. 3-9 November. Jansen, B. J. (2006) /mplications of Trust of Sponsored Links for E-commerce Web Searching, 6th Annual SIG-USE Research Symposium. American Society for Information Science and Technology (ASIS&T) Annual Conference. Austin, TX. 4 November. Spink, A. and Jansen, B. J. (2006) Web Searching: Trends and Impacts, Oxford Internet Institute International Symposium. Journal of Information, Communication, Society: 10th Anniversary International Symposium. University of York, UK. 20 —- 22 September. http://www. york.ac.uk/res/siru/icsspinketal.htm

Case 18-2868, Document 283, 08/09/2019, 2628241, Page466 of 883 Papers Presented at Technical and Professional Meetings Jansen, B. J., Spink, A., Kathura, V., and Koshman, S. (2006) How to Define Searching Sessions on Web Search Engines, Workshop on Web Mining and Web Usage Analysis. The 12th ACM SIGKDD International Conference on Knowledge Discovery and Data Mining (KDD 2006). Philadelphia, Pennsylvania. 20-23 August. Jansen, B. J. (2006) Adversarial Information Retrieval Aspects of Sponsored Search, Second International Workshop on Adversarial Information Retrieval on the Web (AIRWeb 2006). The 29th Annual International ACM SIGIR Conference on Research & Development on Information Retrieval (SIGIR2006). Seattle, Washington. 6-11 August. Jansen, B. J., Ramadoss, R. Zhang, M., and Zang, N. (2006) Wrapper: An Application for Evaluating Exploratory Searching Outside of the Lab, SIGIR 2006 Workshop on Evaluating Exploratory Search Systems. The 29th Annual International ACM SIGIR Conference on Research & Development on Information Retrieval (SIGIR2006). Seattle, Washington. 6-11 August. Buzikashvili, N. and Jansen, B. J. (2006) Limits of the Web Log Analysis Artifacts, Workshop on Logging Traces of Web Activity: The Mechanics of Data Collection, The Fifteenth International World Wide Web Conference (WWW 2006). Edinburgh, Scotland. 22-26 May. Jansen, B. J. (2006) The Wrapper: An Open Source Application for Logging User — System Interactions during Searching Studies, Workshop on Logging Traces of Web Activity: The Mechanics of Data Collection. The Fifteenth International World Wide Web Conference (WWW 2006). Edinburgh, Scotland. 22-26 May. Jansen, B. J., Rieh, S.Y., Spink, A., Wang, P., and Wolfram, D. (2005) Panel Presentation: Internet Usage Transaction Log Studies: The Next Generation, American Society for Information Science & Technology 2005 Annual Meeting. Charlotte, North Carolina. 28 October — 2 November. Toms, E.L., Jansen, B. J., and Muresan, G. (2005) Pane/ Presentation: Evaluating Success in Search Systems, American Society for Information Science & Technology 2005 Annual Meeting. Charlotte, North Carolina. 28 October — 2 November. Jansen, B. J. (2005) A Multi-Disciplinary, Multi-Level, and Multi-Spectrum View of Interaction, The First Conference of the i-School Community: Bridging Disciplines to Confront Grand Challenges. 28-30 September 2005, State College, PA. Jansen, B. J. and Resnick, M. (2005) Examining Searcher Perceptions of and Interactions with Sponsored Results, Workshop on Sponsored Search Auctions, The Sixth ACM Conference on Electronic Commerce (EC'05). Vancouver, Canada. 5-8 June. Jansen, B. J. (2005) Automated Searching Assistance for Exploratory Search, Seminar on Exploratory Search Interfaces at the University of Maryland sponsored by the HumanComputer Interaction (HCI) Lab. College Park, Maryland. 2 June. 65

Case 18-2868, Document 283, 08/09/2019, 2628241, Page467 of 883 Papers Presented at Technical and Professional Meetings Shingle, A. Jansen, B. J., and Spink, A. (2005) Television Advertising of Prescription Drugs: A Study of Its Effect on Consumer Web Searching, |EEE 6th International Conference on Information Technology, Coding and Computing. Las Vegas, Nevada, 11-13 April, 2005. Jansen, B. J., Spink, A., and Pederson, J. (2004) An Analysis of Multimedia Searching on AltaVista, Presentation at Workshop on User Searching, World Wide Web Conference, New York, New York, 18 May 2004. De Ycaza, S., Doran, S., Eastman, C., and Jansen, B. J. (2003) Nutritional Information on the Web: An Analysis of Information Sought and Information Provided, South Carolina Nutrition Research Summit, Columbia, SC. 17 October 2004. Jansen, B. J. (1998) An Analysis of User Queries on the Web: The Implications for the Design of Military Information Retrieval Systems, Fifth Annual US Army Research Laboratory and United States Military Academy Technical Symposium, West Point, New York. Jansen, B. J. (1997) Simulated Annealing in Information Retrieval, Fifth Annual US Army Research Laboratory and United States Military Academy Technical Symposium, West Point, New York. Adams, W. J. and Jansen, B. J. (1997) /ntegrating Usability Design Principles into an Existing Engineering Curriculum, The American Society for Engineering Education National Conference, Milwaukee, Wisconsin. Jansen, B. J. and Adams, W. L. (1997) Integrating User Centered Design into an Introductory Engineering Course, American Society for Engineering Education Zone 1 Meeting, West Point, New York. Scholarly Reports Jansen, B. J. (2011) The civic and community engagement of religiously active Americans. Pew Internet & American Life Project, Pew Research Center. 13 December. http://pewinternet.org/Reports/201 1/Social-side-of-religious.aspx Jansen, B. J. (2010) 65% of Internet Users Have Paid for Online Content. Pew Internet & American Life Project, Pew Research Center. 30 December. http://www. pewinternet.org/Reports/2010/Paying-for-Content.aspx Jansen, B. J. (2010) Use of the internet by higher income households. Pew Internet & American Life Project, Pew Research Center. 24 November. http://www.pewinternet.org/Reports/201 0/Better-off-households.aspx Jansen, B. J. (2010) Online Product Research. Pew Internet & American Life Project, Pew Research Center. 29 September. http://pewinternet.org/Reports/2010/Online-Product-Research.aspx 66

Case 18-2868, Document 283, 08/09/2019, 2628241, Page468 of 883 Funded Projects, Grants, Commissions, and Contracts 2015 - 2014 Title: Web Analytics for a Research University Library Granting Agency: Penn State, University Library Total Amount: $19,717 Role: Principal Investigator 2015 - 2013 Title: Exploring Scholarly Discourse in MOOC Discussion Forums Granting Agency: Penn State, Center for Online Innovation in Learning Total Amount: $30,383 Role: Principal Investigator 2014 - 2010 Title: Broadband to Support SMEs in Pennsylvania Granting Agency: Commonwealth of Pennsylvania Total Amount: $500,000 Role: Faculty Investigator ($70,000) 2014 - 2010 Title: Semantic CiteSeerX Granting Agency: National Science Foundation Total Amount: $1,100,000 Role: Principal Investigator ($130,000) 2011 - 2008 Title: Affective and Cognitive Factors Affecting the Evaluation of Search Engines by Users Granting Agency: Google Amount: $50,000 Role: Principal Investigator 2011 - 2009 Title: Using Keyword Advertising for Economic and Workforce Development Granting Agency: The Pennsylvania State University Amount: $25,000 Role: Principal Investigator 2011 - 2010 Title: Toolkits for Deployable Best Practices Granting Agency: Office of Naval Research STTR Phase II Total Amount: $750,000 Role: Principal Investigator ($87,500) 2011 - 2010 Title: RAPID: Text Message-based Infrastructure for Emergency Response Granting Agency: National Science Foundation Total Amount: $75,000 Role: Principal Investigator ($15,000) 67

Case 18-2868, Document 283, 08/09/2019, 2628241, Page469 of 883 Funded Projects, Grants, Commissions, and Contracts 2009 - 2008 Title: Toolkits for Deployable Best Practices Granting Agency: Office of Naval Research STTR Phase | Total Amount: $100.000 Role: Principal Investigator ($15,000) 2009 - 2007 2009 - 2006 2008 - 2005 Title: REU Supplement for CRI: Collaborative: Next Generation CiteSeer Granting Agency: National Science Foundation Amount: $12,000 Role: Co-Principal Investigator ($12,000). Title: Synchronized Interactions Among Users, Systems, and Information Granting Agency: Air Force Research Lab Amount: $463,000 Role: Principal Investigator ($463,000). Title: The Next Generation CiteSeer Granting Agency: National Science Foundation Amount: approximately $1,444,984 Role: Co-principal Investigator with Dr. Lee Giles, Dr. Susan Gauch, and Dr. Jack Carroll ($48,701) 2009 - 2007 Title: Triggers in Collaborative Information Searching Granting Agency: National Science Foundation Amount: $76,000 Role: Co-principal Investigator with Dr. Madhu Reddy ($18,119) 2009 - 2008 2007 - 2006 Title: REU Supplement for Triggers in Collaborative Information Searching Granting Agency: National Science Foundation Amount: $12,000 Role: Co-principal Investigator with Dr. Madhu Reddy ($6,000) Title: REU Supplement for CRI: Collaborative: Next Generation CiteSeer Granting Agency: National Science Foundation Amount: $9,000 Role: Co-Principal Investigator ($9,000). 2005 - 2004 Title: Design of Tools for Information Seeking, Management, and Analysis for a Lessons Learned Knowledge System Granting Agency: US Marine Corps Research University Amount: $500,000 Role: Co-Principal Investigator ($83,957) 68

Case 18-2868, Document 283, 08/09/2019, 2628241, Page470 of 883 Funded Projects, Grants, Commissions, and Contracts 2005 Title: Knowledge Management Granting Agency: US. Department of Defense, Defense Threat Reduction Agency (DTRA) Amount: $625,832 Role: Co-Principal Investigator ($18,439). 2006 - 2005 Title: REU Supplement for CRI: Collaborative: Next Generation CiteSeer Granting Agency: National Science Foundation Amount: $6,000 Role: Co-Principal Investigator ($6,000). 1998 -1996 Title: The use of software agents in information retrieval. Granting Agency: Army Research Laboratory Amount: $68,000 Role: Principal Investigator ($68,000) 1998 Title: Information Searching on Web Search Engines Granting Agency: Army Research Laboratory Amount: $5,000 Role: Principal Investigator ($5,000) 1997 Title: Software agents for information retrieval. Granting Agency: Army Research Laboratory Amount: $5,000 Role: Principal Investigator ($5,000) Software Developed Software Development: Client-side Application for Automated Searching: that automates searching tactics via user implicit feedback. Software Development: Application for Real-time Evaluation of Search Engine Performance: that automates the evaluation of Web search engines. Teaching At The Pennsylvania State University (current — 2002), | have taught a variety of information technology-related courses, including the undergraduate capstone project leadership course, the introductory freshman course, online marketing, graduate seminar course, and a graduate course on human information interaction. Additionally, | have mentored students in a variety of independent studies and have been on several course development committees. At The Pennsylvania State University (current — 2002): 69

Case 18-2868, Document 283, 08/09/2019, 2628241, Page471 of 883 Teaching e Committee Lead, curriculum development team for a college-level executive masters program. e Committee Lead, curriculum development committee for re-design of the undergraduate senior — level capstone course. e Committee Member, curriculum development team for re-design of the undergraduate freshmen level introductory course. e Committee Member, curriculum development team for the establishment of a university-wide Business Analytics minor e Faculty Lead, development team for the establishment of a university-wide professional library certification program e Committee Member, curriculum development team for the establishment of a college Entrepreneurship minor e Course Development: (1) undergraduate capstone course in IT project management, (2) graduate course in information searching, (3) undergraduate course in keyword advertising, (4) graduate course in web analytics, (5) undergraduate course in entrepreneurship technology 2015 — Mentor for one team in the Google Final 15 in The Google Online Marketing Challenge for 2014. The team was in the top fifteen from 4,000 teams from around the world (top 0.4%). Mentor for team in the Google Non-profit Challenge for 2014. The teams were the top more than 4,000 teams from around the world (top 0.4%). 2014 — Mentor for three teams in the Global Final 15 in The Google Online Marketing Challenge for 2013. The teams were in the top fifteen from 4,000 teams from around the world (top 0.4%). Mentor for two teams in the Google Media Marketing Challenge for 2013. The teams were the top more than 4,000 teams from around the world (top 0.4%). 2013 — Mentor for one team in the Global Final 15 in The Google Online Marketing Challenge for 2012. The team was in the top fifteen from more than 4,000 teams from around the world (top 0.4%). 2012 — Mentor for three teams in the Global Final 15 in The Google Online Marketing Challenge for 2011. The three teams were in the top fifteen from 4,000 teams from around the world (top 0.4%). 2010 — Mentor for two teams in the Global Final 15 in The Google Online Marketing Challenge for 2009. The two teams were in the top fifteen from 3,000+ teams from around the world (top 0.5%). Had eight other teams get honorable mention by placing in the Top 100 Global Teams and five other teams place in the Top 10% of all teams. 70

Case 18-2868, Document 283, 08/09/2019, 2628241, Page472 of 883 Teaching 2010 — Mentor for two student teams that took 1*' and 3” in the Penn State IdeaPitch Competition, which is a university wide Penn State entrepreneurship competition. 2009 — Mentor for three teams in the Global Final 15 in The Google Online Marketing Challenge for 2009. The three teams were in the top fifteen from 2,107 teams from around the world. Had seven other teams get honorable mention by placing in the top 50 teams in the Americas region. 2009 - Schreyer Honors College Teaching Grant Recipient for developing multi-disciplinary keyword advertising, marketing, and technology course. 2008 — Mentor for the winning team in the Americas region in The Google Online Marketing Challenge for 2008. One of the top four teams from 1,620 teams from around the world. Won a trip to the GooglePlex with the students, plus the students all won laptops. Had two other teams get honorable mention by placing in the top 50 teams in the Americas region. 2008 — Selected as Faculty Marshall by Student Marshall of Computer Science and Engineering Department, College of Engineering, The Pennsylvania State University as faculty member who had the biggest impact on student's academic career 2008 — Professor of the Year nominee for College of Information Sciences and Technology, The Pennsylvania State University, 16802 2003 Selected as Faculty Marshall by Student Marshall of School of Information Sciences and Technology, The Pennsylvania State University as faculty member who had the biggest impact on student’s academic career Guest lecturer for a month (2000) at the Korean Military Academy in Seoul, Republic of Korea. At the University of Maryland (Asian Division) (2000 — 1999), taught courses on Web/Internet and multimedia design. At the United States Military Academy (1999 — 1996), | taught several computer sciencerelated courses including introductory programming, advanced programming, microcomputing, and databases. Also, mentored students in a variety of independent studies. As executive officer for the department (1999 — mid 1997), was responsible for course scheduling, instructor assignments, classroom allocation, student counseling, as well as many other duties concerning the day-to-day operation of the department. 71

Case 18-2868, Document 283, 08/09/2019, 2628241, Page473 of 883 Membership on Degree Committees The Pennsylvania State University College of Information Sciences and Technology Chair or Co-Chair Partha Mukherjee (Committee Chair) (PhD degree expected in 2016) Alex Brown (Committee Chair) (M.S. degree expected in 2016) Zhe Liu (Committee Chair) (PhD degree conferred in 2014) Dan Coughlin (Committee Chair) (PhD degree conferred in 2014) Carolyn Hafernik (Committee Chair) (M.S. degree conferred in 2013) Adan Ortiz-Cordova (Committee Chair) (M.S. degree conferred in 2013) Jian-Syuan Wong (Committee Chair [until 2016]) (PhD degree expected in 2018) Steve Carmen (Committee Chair [until 2013]) (M.S. degree conferred in 2013) Kathleen Moore (Committee Chair [until 2012]) (PhD degree expected in 2015) Mimi Zhang (Committee Chair) (PhD degree conferred in 2010) Mike Hills (Committee Chair) (PhD degree conferred in 2010) Hyun-Woo Kim (Committee Co-Chair) (M.S. degree conferred in 2010) Young Shin Kim (Committee Co-Chair) (M.S. degree conferred in 2010) Committee Member Eric McMillan (Committee Member) (PhD degree expected in 2017) Nathan McNeese (Committee Member) (PhD degree conferred in 2014) Patricia Spence (Committee Member) (PhD degree conferred in 2013) Arvind Karunakaran (Committee Member) (M.S. degree conferred in 2011) Yusuf Raza (Committee Member) (M.S. degree conferred in 2009) Sharoda Paul (Committee Member) (PhD degree conferred in 2009) Allison Morgan (Committee Member) (PhD degree conferred in 2008) Mithu Bhattacharya (Candidacy Committee Member, 2005) Scott Robertson (Candidacy Committee Chair, 2004) The Pennsylvania State University Workforce Education and Development Program, College of Education John Dolan (Committee Co-Chair [until 2012]) (PhD degree expected in 2013) The Pennsylvania State University School of Hospitality and Management Lu Zhang (Committee Co-Chair) (M.S. degree conferred in 2009) The Pennsylvania State University Department of Industrial and Manufacturing Engineering Himanshu Sharma (Committee Chair) (M.S. degree conferred in 2005) Sourav Sengupta (Committee Chair) (M.S. degree conferred in 2005) Ying Zhang (Committee Chair) (M.S. degree conferred in 2008) The Pennsylvania State University Department of Electrical Engineering Vijay Mohan (Committee Co-Chair) (M.S. degree conferred in 2009) Dheepak Ramaswamy (Committee Co-Chair) (M.S. degree conferred in 2009) Ashish Kathuria (Committee Chair) (M.S. degree conferred in 2007) 72

Case 18-2868, Document 283, 08/09/2019, 2628241, Page474 of 883 Membership on Degree Committees The Pennsylvania State University Department of Computer Science and Engineering Yanjun Gao (Committee co-Chair) (PhD degree expected in 2018) Chandrika Gopalakrishna (Committee Chair) (M.S. degree conferred in 2008) The University of Pittsburgh School of Information Sciences Department of Library and Information Science Zhen Yue (Committee Member) (Ph.D. degree conferred in 2014) Minsoo Park (Committee Member) (Ph.D. degree conferred in 2008) Rutgers, the State University of New Jersey School of Communication, Information and Library Studies Yuelin Lee (Committee Member) (Ph.D. degree conferred in 2008) The Pennsylvania State University Schreyer Honors College, thesis advising Megan Krause (B.S. degree expected 2107) Allie Whitman (B.S. degree expected 2106) Adan Ortiz-Cordova (B.S. degree conferred 2011) Bradley Shively (B.S. degree conferred 2010) Kate Sobel (B.S. degree conferred 2010) Steven Troxell (B.S. degree conferred in 2008) Steven Clancy (B.S. degree conferred in 2007) Paulo Molina (B.S. degree conferred in 2004) Chris Catalano (B.S. degree conferred in 2004) Andy Shingle (B.S. degree conferred in 2004) Supervision of Other Undergraduate Research Student Degree Major University Role Arielle Amchin BS Marketing Penn State Research Mentor Arun Das BS cs Brown University Research Mentor Manisha BS MIS Carnegie Mellon Qatar Research Mentor Dareddy Satyajit BS cs Bharati Vidyapeeth ri University as Reseaich' Mentor Will Berkheiser BS IST Penn State Work Study Mentor http://studentaid.psu.edu/typesof-aid/work-study-andemployment/work-study/about Pat Bonner BS IST Penn State Research Mentor Danielle Booth BS IST Penn State Research Mentor Anna Brown BS IST Penn State Research Mentor Nicole Butera BS Chemistry Penn State Women in Science and Engineering Research 73

Case 18-2868, Document 283, 08/09/2019, 2628241, Page475 of 883 Supervision of Other Undergraduate Research Student Chris Ciamacca Karen Lee Dana Kracow Daehee Park Melissa Reizner Mitchell Rukat Paul Rinaldi Simone Schuster Laura Solomon Meng Ting Sun Pete Smith Megan Tan Courtney Weaver Degree Major University Role (WISER) Mentor http://pa.spacegrant.org/wiser BS IST Penn State Research Mentor BS IST Penn State Research Mentor BS IST Penn State Research Mentor BS IST Penn State Research Mentor BS IST Penn State Reseuian enter BS IST Penn State Research Mentor BS IST Penn State Research Mentor BS Advertising Penn State Research Mentor BS Advertising Penn State Research Mentor BS Accounting Penn State Research Mentor BS IST Penn State Research Mentor BS Marketing Penn State Research Mentor BS IST Penn State Research Mentor Professional Service Editorial Boards Current — 2016 Current — 2016 Current — 2012 Current — 2011 Current — 2009 Current — 2009 Current — 2006 Current — 2006 Current — 2004 2016 — 2011 2011 - 2004 Editor-in-chief, Information Processing & Management (Elsevier) Editorial Board Member, Information Discovery and Delivery Editorial Advisory Board Member, Social Networks Editorial Advisory Board Member, International Journal of Electronic Business Editorial Advisory Board Member, Journal of the American Society for Information Science and Technology Editorial Advisory Board Member, Future Internet Editorial Panel, International Journal of Internet Science Editorial Advisory Board Member, Information Research Editorial Advisory Board Member, Information Processing & Management Editor-in-chief, Internet Research (Emerald) Editorial Advisory Board Member, Journal of Internet Research 74

Case 18-2868, Document 283, 08/09/2019, 2628241, Page476 of 883 Professional Service Editorial Boards 2010 - 2004 Editorial Advisory Board Member, Library and Information Science Journal 2008 - 2004 Associate Editor (Book Reviews), Information Processing & Management 1996 -1998 Student Editor, SIG Computer Human Interaction SIGCHI Bulletin Professional Service Tenure Letters 2016 External Tenure Letter Writer for faculty member of School of Business, McMaster University 2016 External Tenure Letter Writer for faculty member of Department of Library and Information Science, The Catholic University of America 2015 External Tenure Letter Writer for faculty member of School of Communication and Information, Rutgers University 2013 External Tenure Letter Writer for faculty member of College of Information Science and Technology, Drexel University 2013 External Tenure Letter Writer for faculty member of Graduate School of Management, University of Haifa 2012 External Tenure Letter Writer for faculty member of Faculty of Social Sciences, BarIlan University 2012 External Tenure Letter Writer for faculty member of Henry B. Tippie College of Business, The University of lowa 2012 External Tenure Letter Writer for faculty member of School of Business, North Carolina Central University 2010 External Tenure Letter Writer for faculty member of School of Business Administration, Bar Ilan University, Israel 2009 External Tenure Letter Writer for faculty member of Computer Information Systems Department, Bentley University 75

Reviewer Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page477 of 883 Professional Service Ad hoc Reviewing 2016 2015 2014 2013 2012 2011 2010 2009 Reviewer, IEEE Systems, Man and Cybernetics, Computers in Human Behavior, International Journal of Human Computer Interaction, Cornell Hospitality Review Reviewer, Transactions on Intelligent Systems and Technology, Journal of Organizational Computing and Electronic Commerce, European Journal of Marketina, Journal of Information Management, Transactions on Management Information Systems Reviewer, MIS Quarterly, Journal of Organizational Computing and Electronic Commerce, Computers in Human Behavior, Journal of Documentation, IEEE Systems. Man and Cybernetics, Tourism Management Reviewer, Technological Forecasting & Social Change, IEEE Systems, Man and Cybernetics, International Journal of Electronic Commerce, ACM Transactions on the Web, Journal of Interactive Marketing, Jo: | of El ‘onic Commerce Research (2x), Electronic Commerce Research, Communications of the Association for Information Systems, Transactions on Computer-Human Interaction, Information Research, Information and Management Reviewer, Electronic Commerce Research, International Journal of Information Management, Journal of Information Science, Communication Research, International Journal of Internet Science, Journal of Organizational Computing and Electronic Commerce, Social Science Computer Review, Information Research, MIS Quarterly, Journal of Organizational Computing and Electronic Commerce, Library and Information Science, IEEE Transactions on Multimedia, Advances in HumanComputer Interaction (2x), Journal of Theoretical and Applied Electronic Commerce Research (3x), ACM Transactions on Computer-Human Interaction Reviewer, IEEE Transactions on Multimedia, Information Technology and People. Journal of Computer-Mediated Communication (2x), Sage Publishing, Electronic Commerce Research, International Journal of Electronic Commerce, Journal of Interactive Marketing (2x), ACM Transactions on the Web, ACM Transactions on Computer-Human Interaction Reviewer, International Journal of Information Management (2x), ACM Transactions on the Web, Social Science Computing Review, MIS Quarterly, International Journal of Human-Computer Studies, PLoS One, Information Research, Netherlands Organisation for Scientific Research, Computing Surveys, Information Sciences, Future Internet, International Information and Library Review, International Journal of Internet Science, Behaviour & Information Technology, Journal of Media Economics 2010 Reviewer, Internet Research Reviewer, The Computer Journal, ACM Transactions on the Web, International Journal of Electronic Commerce, Data & Knowledge. ineering Journal, ACM Transactions on Information Systems 76

Case 18-2868, Document 283, 08/09/2019, 2628241, Page478 of 883 Professional Service Ad hoc Reviewing 2008 2007 2006 2005 2005 2004 2003 2002 2001 1999 1998 Reviewer, Journal of the Academy of Marketing Science, ACM Transactions on the Web, ACM Transactions on Information Systems, Decision Support Systems, New Media & Society, IEEE Internet Computing, Journal of Service Science and Management, JEEE Transactions on Professional Communication, International Journal of Knowledge Management Studies Reviewer, Simulation Modelling Practice and Theory, ACM Transactions on Information Systems Reviewer, Journal of Information Science, ACM Transactions on Information Systems Reviewer, Journal of Medical Internet Research, ACM Transactions on Information Systems Reviewer, IEEE Systems, Man and Cybernetics Journal, Computer Networks Journal Reviewer, Information Retrieval, Information Processing & Management, Journal of Web Engineering, Journal of Library & Information Science Research Reviewer, IEEE Proceedings-Software, Information Processing & Management Reviewer, Journal of Informing Science, Information Processing & Management, The World Wide Web Journal Reviewer, International Journal of Human Computer Studies, Information Processing & Management Reviewer, Information Processing & Management Reviewer, Computer Science Education Journal, Information Processing & Management Professional Service Grant Reviewing 2015 2014 2013 2012 Reviewer, Qatar Research Program, Qatar Foundation Reviewer, grant panelist for National Science Foundation, CISE Research Infrastructure (CRI) program February 2014. Reviewer for grant proposal for Reviewer, American Association for the Advancement of Science (AAAS) Research Competitiveness Program Grant Proposal for funding through the Maine Technology Institute's Development Awards Reviewer, Army Research Lab Grant Proposal 77

Case 18-2868, Document 283, 08/09/2019, 2628241, Page479 of 883 Professional Service Grant Reviewing 2011 2011 2010 2010 2008 2007 2007 2004 Reviewer, National Science Foundation Grant Proposal Reviewer, American Association for the Advancement of Science (AAAS) Research Competitiveness Program Grant Proposal for funding through the Maine Technology Institute's Development Awards Reviewer, Standard Research Grants program of the Social Sciences and Humanities Research Council of Canada (SSHRC) Grant Proposal Reviewer for grant proposal for Reviewer, American Association for the Advancement of Science (AAAS) Research Competitiveness Program Grant Proposal for funding through the Maine Technology Institute's Development Awards Reviewer, Israel Science Foundation Grant Proposal Reviewer, Air Force Office of Scientific Research Grant Proposal Reviewer, Israel Science Foundation Grant Proposal Grant Reviewer, Arts and Humanities Research Board Grant Proposal, Whitefairs, Lewins Mead, Bristol, UK, BS1 2AE Professional Service Other 2016 2016 — 2015 2014 — 2012 2012 Special Issue on Computational Advertising, IEEE Intelligent Systems. Guest Editors: Yanwu Yang, Huazhong University of Science and Technology, China; Yinghui Yang, University of California, Davis, US; Bernard J. Jansen, Qatar Computing Research Institute, HBKU; Mounia Lalmas, Yahoo Labs, UK. 2007 Academic Panelist for The Google Online Marketing Challenge (http:/Awww.google.com/onlinechallenge/). Based on registrations from more than 100 countries and more than 11,000 student teams, the Challenge may be the largest, worldwide educational course ever done. External Examiner for Spanish PhD thesis (Universitat Pompeu Fabra Barcelona) 2013 Faculty Advisor for the Penn State Digital Marketing Association External Examiner for Australian PhD thesis (Queensland University of Technology) 2011 Member, Research Committee, Search Engine Marketing Professional Organization (SEMPO) 78

Case 18-2868, Document 283, 08/09/2019, 2628241, Page480 of 883 Professional Service Other 2011 — 2009 Chair of the American Society for Information Science and Technology (ASIST) Information Science Education Committee 2010 Reviewer, Cambridge University Press book proposal 2010 Reviewer, Cambridge University Press book proposal 2010 External Examiner for Australian PhD thesis (University of Sydney) 2009 — 2006 Chair of the American Society for Information Science and Technology (ASIST) Information Science Education Committee Dissertation Jury 2008 External Examiner for Australian PhD thesis (The University of New South Wales) 2008 External Examiner for Australian PhD thesis (The University of New South Wales) 2008 Guest Editor, International Journal of Electronic Business (IJEB). Special Issue on Sponsored Search 2007 External Examiner for Australian PhD thesis (Monash University) 2007 Guest Editor, with Andy Edmond, Kirstie Hawkey, Melanie Kellar, and Don Turnbull. Journal of Web Engineering. Special Issue on Logging Traces of Web Activity 2006 Guest Editor, Bulletin of the American Society for Information Science and Technology. Special Issue on Paid Search, January 2006 1995 -1994 President, Computer Science Graduate Students Association, Texas A&M University, College Station, Texas. Professional Service Conference Activities 2016 Chair, Program Committee, The Second International Workshop on Online Social Networks Technologies (OSNT-2016), 13th ACS/IEEE International Conference on Computer Systems and Applications AICCSA 2016. 29 November - 2 December. 2016 Chair, Program Committee, The Third International Workshop on Social Networks Analysis, Management and Security (SNAMS - 2016), The 4th International Conference on Future Internet of Things and Cloud (FiCloud-2016), Vienna, Austria. 22-24 August. 2016 Reviewer, Papers and Posters, 79th Annual Meeting of the American Society for Information Science and Technology (ASIST 2016). Copenhagen, Denmark. 14-18 October. 79

Case 18-2868, Document 283, 08/09/2019, 2628241, Page481 of 883 Professional Service Conference Activities 2015 2015 2015 2014 2014 2014 2013 2013 2013 2013 2013 2012 2011 2011 2011 Program Committee, 7" International Joint Conference on Knowledge Discovery, Knowledge Engineering and Knowledge Management, Lisbon, Portugal. 12-14 Nov. Meta-Reviewer, Papers and Posters, 78th Annual Meeting of the American Society for Information Science and Technology (ASIST 2015). St. Louis, Mo. 6-10 November. Reviewer, ACM CHI Conference on Human Factors in Computing Systems, Seoul, South Korea. 18-23 April. Reviewer, Papers and Posters, 77th Annual Meeting of the American Society for Information Science and Technology (ASIST 2014). Montreal, Canada. 31 October - 4 November. Program Committee: 3" International Information Systems for Crisis Response and Management Conference (ISCRAM 2014), State College, PA. May 2014. Reviewer, ACM CHI Conference on Human Factors in Computing Systems, Toronto, Canada. 26 April -— 1 May. Reviewer, Papers, 76th Annual Meeting of the American Society for Information Science and Technology (ASIST 2013). Montreal, Canada. 1-6 November. Reviewer, Posters, 76th Annual Meeting of the American Society for Information Science and Technology (ASIST 2013). Montreal, Canada. 1-6 November. Reviewer, 22™ International World Wide Web Conference (WWW 2013). 13"-17", May, Rio de Janeiro, Brazil. Program Committee: European Conference on Information Retrieval (ECIR 2013) Workshop on Group Membership and Search (GRUMPS), 24 March, Moscow, Russia Program Committee: Sixth ACM WSDM Conference on Web Search and Data Mining Workshop on Web Search Click Data, 4-8 February, Rome, Italy. Program Committee: Fourth Information Interaction in Context Conference (IIIX 2012), Nijmegen, the Netherlands, 21-24 August 2012. Session Track Chair, 74" Annual Meeting of the American Society for Information Science and Technology (ASIST 2011). 9-13 October. New Orleans, LA. Program Committee, iConference. Toronto, Canada, 7-10 February. Program Committee: 33 European Conference on Information Retrieval (ECIR 2011), Best Paper Committee, Dublin, Ireland, 19-21 April 2011 80

Case 18-2868, Document 283, 08/09/2019, 2628241, Page482 of 883 Professional Service Conference Activities 2011 2011 2011 2011 2010 2010 2010 2010 2009 2009 2009 2009 2009 2009 2008 Program Committee: 33 European Conference on Information Retrieval (ECIR 2011), Workshop on Information Retrieval Over Query Sessions, Dublin, Ireland, 19-21 April 2011. Program Committee: 12" ACM Conference on Electronic Commerce (EC11). San Jose, CA. 5-9 June. Program Committee: Conference on Multilingual and Multimodal Information Access Evaluation (CLEF 2011). Amsterdam, the Netherlands, 19-22 September 2011. Program Committee: 33 European Conference on Information Retrieval (ECIR 2011). Dublin, Ireland. 18-21 April. Program Committee, American Society for Information Science and Technology Annual Meeting 2010. Pittsburgh, PA. 22-27 October. Program Committee: Conference on Multilingual and Multimodal Information Access Evaluation (CLEF 2010). Padua, Italy, 20-23 September. Program Committee: LREC 2010 Workshop on Web Logs and Question Answering (WLQA2010). Malta, 22 May. Program Committee: 32% European Conference on Information Retrieval (ECIR 2010). Keynes, UK. 28-31 March. Program Committee: Web Information and Data Management. 19" International Conference on Information and Knowledge Management (CIKM 2009). Hong Kong. 6 November. Program Committee: Workshop on the Analysis of System Logs. 22" ACM Symposium on Operating Systems Principles. Big Sky, MT.14 October. Program Committee: Collaborative Information Behavior. GROUP 2000. Sanibel Island, Florida. 10 May. Program Committee: Qualitative and Quantitative Methods in Libraries International Conference (QQML2009). Chania, Crete, Greece, 26-29 May. Program Committee: 31% European Conference on Information Retrieval (ECIR 2009). Toulouse, France. 6-9 April. Reviewer, ACM Conference on Computer Human Interaction 2009 (CHI 2009), Boston, MA, 4 — 9 April. Reviewer, 18" Conference on Information and Knowledge Management (CIKM 2008). Napa Valley, California. 26-30 October. 81

Case 18-2868, Document 283, 08/09/2019, 2628241, Page483 of 883 Professional Service Conference Activities 2008 2008 2008 2008 2007 2007 2007 2007 2007 2007 2007 2007 2006 2006 2006 Program Committee: Workshop on Human-Computer Interaction and Information Retrieval (HCIR 2008). Redmond, Washington.23 October. Program Committee: 1° Information Interaction in Context Symposium (liiX 2008). London, United Kingdom. 14-17 October. Program Committee: 2008 Ad Auctions Workshop. ACM Conference on Electronic Commerce in Chicago, IL. 8-9 July. Reviewer, Southern Association for Information Systems Conference (SAIC 2008), Richmond, VA, USA 13-15 March. Program Committee, IEEE International Conference on Intelligence and Security Informatics 2007 (ISI 2007), New Brunswick, New Jersey. 23-24 May, 2007 Reviewer, Graphics Interface 2007, Montréal, Canada, 28 — 30 May 2007. Reviewer, American Society for Information Science and Technology Annual Meeting 2007. Milwaukee, Wisconsin. 18-25 October. Program Committee, 8" World Congress on the Management of eBusiness. Toronto, Canada. 11-13 July. Program Committee, WWW’'07 Workshop on Query Log Analysis: Social and Technological Challenges. World Wide Web 2007, Banff, Alberta, Canada. 8 May. Program Committee, WWW ’'07 Workshop on Sponsored Search. World Wide Web 2007, Banff, Alberta, Canada. 8 May. Program Committee, Chi’07 Workshop on Exploratory Search and HCI: Designing and Evaluating Interfaces to Support Exploratory Search Interaction. ACM CHI2005, Conference on Human Factors in Computing Systems (CHI'07), San Jose, CA. 29 April 2007. Program Committee, IEEE Intelligence and Security Informatics Conference (ISI 2007), New Brunswick, NJ. 23 — 24 May, 2007. Program Committee: 2006 Research Symposium of the Special Interest Group on Human-Computer Interaction. American Society for Information Science and Technology. Austin, Texas. 5 November 5, 2006 Reviewer, Hawaii International Conference on System Sciences 2007. Waikoloa, Big Island, Hawaii. 3-6 January, 2007. Program Committee: IEEE Information Technology: New Generations (ITNG) 2006, Las Vegas, NV. 16 -19 April 2007. 82

Case 18-2868, Document 283, 08/09/2019, 2628241, Page484 of 883 Professional Service Conference Activities 2006 Reviewer for SIGIR 2006 Workshop on Evaluating Exploratory Search Systems. The 29" Annual International ACM SIGIR Conference on Research & Development on Information Retrieval (SIGIR2006). 6-11 August. Seattle, Washington. 2006 Program Committee: 4" International Conference on Information Technology: New Generations, 16-19 April, 2007, Las Vegas, Nevada. 2006 Program Committee: 1* Information Interaction in Context Symposium (liiX symposium). Copenhagen, Denmark. 18-20 October 2006. 2006 Program Committee: IEEE Information Technology: New Generations (ITNG) 2006, Las Vegas, NV. 10 — 12 April 2006. 2006 Reviewer, The Fourth Annual Pre-ICIS Workshop on HCI Research in MIS, International Conference on Information Systems, 2005. 2006 Reviewer, Human Factors and Ergonomics Society 49" Annual Meeting, 2005. 2006 Program Committee: IEEE 6" International Conference on Information Technology, Coding and Computing. Las Vegas, Nevada. 5-7 April 2005. 2006 Program Committee: the 5" International Conference on Conceptions of Library and Information Science, Glasgow, Scotland, 6-9 June 2005. 2006-2002 Reviewer, ACM SIGIR International Conference on Information Retrieval. 2006 Session Track Co-chair, Web Searching Sessions (Three tracks), the IEEE 5" International Conference on Information Technology, Coding and Computing. Las Vegas, Nevada. 4-6 April 2005. 2005 Program Committee, IEEE 6" International Conference on Information Technology, Coding and Computing. Las Vegas, Nevada. 5-7 April, 2005. 2005 Program Committee, the 5" International Conference on Conceptions of Library and Information Science, Glasgow, Scotland, 6-9 June 2005. 2004 Session Track Co-chair, Web Searching Sessions (Three tracks), the IEEE 5" International Conference on Information Technology, Coding and Computing. Las Vegas, Nevada. 5-7 April, 2004. 2004 Reviewer, ACM CHI2005, Conference on Human Factors in Computing Systems 1998 Session Moderator, New Engineering Educators Conference, June 1998, Seattle, Washington. 1998 Co-organizer for ACM Computer Science Education Research Competition, February 1998, Atlanta, Georgia. 83

Keynote Keynote Keynote Case 18-2868, Document 283, 08/09/2019, 2628241, Page485 of 883 Professional Service Conference Activities 1998 Reviewer, New Engineering Educators Conference 1998 Reviewer, American Society for Engineering Education National Conference 1997 Session Moderator for American Society for Engineering Education National Conference, June 1997, Milwaukee, Wisconsin. Advisory Boards Current - 2012 CLAK Impressions http:/Awww.linkedin.com/company/clak-impressions Current - 2010 The Pennsylvania Technical Assistance Program (PennTAP), http://penntap.psu.edu/action-council/ Current - 2010 Innoblue, http://innoblue.org/ 2016 - 2007 Global Academic Panel, Google Online Marketing Challenge, http:/www.google.com/onlinechallenge/discover/judging-panel.html 2012 - 2010 Chief Marketing Officer (CMO Council) Advisory Board for research initiative, Localize to Optimize Sales Channel Effectiveness 2012 - 2010 Jabbit Board of Advisors, http://www _jabbit.com/ Invited Talks (Selected) Keynote, 2016 Sixth National Doctoral Forum of Information Science, 7-18 July 2016, Tianjin, China. http://jimjansen.blogspot.qa/2016/07/keynote-speaker-at-2016-sixth-national.html Keynote, The 7th International IEEE on Information and Communication Systems (ICICS 2016), 5-7 April, Irbid, Jordan. Keynote, The 10th International ACM Conference on Ubiquitous Information Management and Communication (IMCOM 2016), 4-6 January, Danang, Vietnam. http://jimjansen.blogspot.qa/2015/12/imcom-2016-keynote-transformed-role-of.html Presentation, Sungkyunkwan University (Sowan Campus), 23 April 2015, Seoul, South Korea. http://jimjansen.blogspot.com/2015/04/visit-to-department-of-interaction.html Presentation, National Research University Higher School of Economics, 10 March 2014, St. Petersburg, Russia http://jimjansen.blogspot.com/2014/03/presentation-at-national-research.html 84

Keynote Keynote Case 18-2868, Document 283, 08/09/2019, 2628241, Page486 of 883 Invited Talks (Selected) Presentation, Yandex, 11 March 2014, St. Petersburg Russia. http://jimjansen.blogspot.com/2014/03/visit-to-yandex-headquarters-in-st.html Presentation, Sungkyunkwan University (Sowan Campus), 20-21 June 2013, Seoul, South Korea. http://jimjansen.blogspot.com/2013/06/research-workshop-discussion-on-web.html Presentation, Library and Information Science Department and College of Information and Media, Duksung Women’s College, 19 June 2013, Seoul, South Korea. http://jimjansen.blogspot.com/2013/06/theoretical-constructs-of-searching-and.html Presentation, Library and Information Science Department, College of Liberal Arts, Sungkyunkwan University, 18 June 2013, Seoul, South Korea. http://jimjansen.blogspot.com/2013/06/keyword-advertising-research.html Presentation, Qatar Computer Research Institute, 24-29 April 2013, Doha, Qatar. http://jimjansen.blogspot.com/2013/04/research-presentation-to-folks-at-qatar.html Presentation, Department of Decision Sciences, College of Business and Public Administration, Old Dominion University, 14-15 April 2013, Norfolk, VA. http://jimjansen.blogspot.com/2013/04/keyword-advertising-presentation-to.html Presentation, Google Online Marketing Challenge Workshop, The University of Illinois at Urbana-Champaign, 11 March 2013. http://jimjansen.blogspot.com/2013/03/gomc-presentation-to-students-at.html Presentation, Casual Living Conference 2012, 22-24 February 2012, Sarasota, FL. http://accentsandfurnishings.com/conferences/casuallivingconference/2012/index.html Keynote, The Direct Marketing Association of Washington (DMAW) Professor Institute. 3-4 January 2012, Washington. DC. http:/\www.dmawef.org/Professors_Page/Professors_Page.html Presentation, Advance 2011: Rediscovering the Customer. 20-22 September 2011, San Diego, CA. http://www.idanalytics.com/advance2011/ Webinar, Web Analytics Webinar for the American Society for Information Science and Technology, 17 June 2011. http://asist.org/Conferences/webinars/201 1/web-analytics.html Keynote, Buying and Selling eContent 2011. 28 March 2011, Scottsdale, AR. http://www.buysell-econtent.com/201 1/Speakers/JimJansen.aspx Presentation, Evri (semantic news aggregation company). 10 February 2011, Seattle, WA http://jimjansen.blogspot.com/201 1/02/visit-to-evri-semantic-news-aggregation.html Presentation, IMPAQT (search engine marketing agency). 10 November 2010, Pittsburgh, PA. http://jimjansen.blogspot.com/2010/1 1/visit-to-search-engine-marketing.html 85

Keynote Case 18-2868, Document 283, 08/09/2019, 2628241, Page487 of 883 Invited Talks (Selected) Presentation, Yahoo! Research Lab. 9 November 2010, New York, New York. http://jimjansen.blogspot.com/2010/1 1/visit-to-yahoo-research-labs-new-york.html Presentation, School of Communication and Information, Rutgers University. 8 November 2010, New Brunswick, NJ. University-wide Presentation, Ryerson University, 18 October 2009, Toronto, Canada. Presentation, Query Log Analysis: From Research to Best Practice 2009/ 27-28 May. London, UK. Funded by European Union project on Evaluation, Best Practices and Collaboration for Multilingual Information Access. http://ir-shef.ac.uk/cloughie/qlaw2009/index.html Presentation, Query Log Analysis: From Research to Best Practice 2009/ 27-28 May. London, UK. Funded by European Union project on Evaluation, Best Practices and Collaboration for Multilingual Information Access. http://ir-shef.ac.uk/cloughie/qlaw2009/index.html Presentation, Google. 30 October 2008. Mountain View, CA. Presentation, IMPAQT (search engine marketing agency). 28 October 2008, Pittsburgh, PA. http://jimjansen.blogspot.com/2008/10/visit-to-sem-impaqt.html Presentation, Mahalo (a human power search engine). 6 July 2008, Los Angeles, CA. http://jimjansen.blogspot.com/2008/07/mahalo-human-power-search-engine.htm| Presentation, Pepperjam (search engine marketing agency). 24 June 2008, Wilkes-Barre, PA. http://jimjansen.blogspot.com/2008/06/visit-to-pepperjam.html Presentation, School of Communication and Information, Rutgers University. 2 September 2005, New Brunswick, NJ. Presentation, College of Information, University of North Texas, 15 June 1998. Denton, TX Membership in Professional Societies American Society for Information Science and Technology (ASIST) Armed Forces Communications and Electronics Association (AFCEA) Association for Computing Machinery (ACM) The Institute of Electrical and Electronics Engineers (IEEE) Societies: Computer Society 86

Case 18-2868, Document 283, 08/09/2019, 2628241, Page488 of 883 Professional Experience Numerous consulting projects and expert witnessing (class action suits, patent ligation, and civil ligation) US Army Officer (2002 — 1985): Held various command and staff positions of progressively increasing responsibility. Responsible for vision articulation, planning, directing, and day-today management of organizations ranging in size from 10 to over 200 personnel. Served in numerous locations in the United States, Europe, Central America, and the Far East as a communication officer. Responsible for the planning and installation of various types of communication systems including radio, telephone, computer and other digital networks. Served with the 8" U.S. Army Y2K Operational Evaluation Team validating critical information management systems. Responsible for the long term planning, developing, and budgeting of communication systems of all types for the U.S. Forces stationed on the Korean Peninsula. Responsible for a 22-person division that develops photographic, graphical, audio-visual and multimedia material for the U.S. Army War College. Security Clearance TS-SCI: Cleared for Top Secret information and granted access to Sensitive Compartmental Information based on a single scope background investigation by the Defense Security Service, Office of Personnel Management on 17 March 2011. 87

Case 18-2868, Document 283, 08/09/2019, 2628241, Page489 of 883 Appendix B Testimony Cases Year Deliverables Retained by Case 2016 Testimony Deposition Plaintiff ERIN ANDREWS, Plaintiff, vs MARRIOTT INTERNATIONAL, INC., a Delaware Corporation; WESTEND HOTEL PARTNERS, LLC dba NASHVILLE MARRIOTT AT VANDERBILT UNIVERSITY, a Delaware Limited Liability Company, and MICHAEL DAVID BARRETT, an individual, Defendants. CASE NO. 11C4831, which is pending in the Circuit Court for Davidson County Tennessee at Nashville. Law Firm: Greene Broillet & Wheeler LLP 2015 Deposition Plaintiff ENCORE MEDIA METRICS, LLC fka SPUR DIGITAL L.P., dba SPUR INTERACTIVE and STEVE LATHAM VS ADOMETRY, INC. fka CLICK FORENSICS, INC. Cause 2012-44351 / Court: 281. (The District Court of Travis County, Texas.) Law Firm: Watts & Guerra LLP and DiNovo Price Ellwanger & Hardy LLP 2014 Deposition Defendant M.B. AS NEXT FRIEND OF J.B., A MINOR Plaintiffs, V. CAMP STEWART FOR BOYS, INC., AMERICAN INSTITUTE FOR FOREIGN STUDY, INC. D/B/A CAMP AMERICA, AND SCOTT ASH JAMES ZIRUS Defendant. NO. 5:12-CV-1133 (Western District of Texas) Law Firm: Rymer, Moore, Jackson, & Echols PC 2014 Testimony, Deposition Defendant REAL LOCAL PAGE PARTNERS, LLC, Claimant, v. PAYMENT ALLIANCE INTERNATIONAL, INC., Respondent & PAYMENT ALLIANCE INTERNATIONAL, INC. Counter-Claimant, v. REAL LOCAL PAGE PARTNERS, LLC, Counter-Respondent. CASE NO. 32 147 Y 0021413. AMERICAN ARBITRATION ASSOCIATION, MIAMI, FLORIDA Law Firm: Kirkland & Ellis LLP 2013 Deposition Plaintiff CABLE WHOLESALE.COM, INC. v. SF CABLE, INC. Case No. CV 11-2966 EMC (Northern District of California) Law Firm: Law Offices of James G. Schwartz P.C. 88

Case 18-2868, Document 283, 08/09/2019, 2628241, Page490 of 883 Appendix C Documents Referenced Web Services Alexa www.alexa.com/ e Bing Search Engine https://www.bing.com/ e Compete https://www.compete.com/ e Google Keyword Tool https://adwords.google.com/KeywordPlanner © Google Search Engine www.google.com/ e Google Trends https://www.google.com/trends/ e Microsoft Bing Keyword Tool www.bing.com/toolbox/keywords e Million Short https://millionshort.com/ e =SimiliarWeb www.similarweb.com/ ¢ SpyFu www.spyfu.com/ e W3Snoop http://www.w3snoop.com/ Documents e Agarwal, D., Chen, B. C., and Wang, X. Multi-faceted ranking of news articles using post-read actions. In Proc. of CIKM, ACM (2012), 694-703. e Aikat, D. News on the web: usage trends of an on-line newspaper. Convergence: The International Journal of Research into New Media Technologies 4, 4 (Dec. 1998), 94110. e BBC News https://en.wikipedia.org/wiki/BBC_News e Castillo, C., El-Haddad, M., Pfeffer, J., & Stempeck, M. (2014, February). Characterizing the life cycle of online news stories using social media reactions. In Proceedings of the 17th ACM conference on Computer supported cooperative work & social computing (pp. 211-223). ACM. e Complaint, VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. CASE NO. 1:15-cv-07433 ¢ Daily Mirror https://en.wikipedia.org/wiki/Daily_Mirror e GIUFFRE001120 © GM _00068 (Gow E-Mail) e — http://digitalmeasurement.nielsen.com/files/metrics-guidelines.pdf e — http://www.ebizmba.com/articles/news-websites e — http://www.mirror.co.uk/news/uk-news/prince-andrews-pal-ghislaine-maxwell-508 1971 e — http://www.nydailynews.com/news/world/alleged-madame-accused-supplying-princeandrew-article-1.2065505 http://www.pewresearch. org/fact-tank/2014/02/03/6-new-facts-about-facebook/ https://www.google.com/advanced_search https://www.thesun.co.uk/archives/news/6754/prince-andrews-pal-ghislaine-groped-teengirls/ Mail Online https://en.wikipedia.org/wiki/Mail_Online Power Law https://en.wikipedia.org/wiki/Power_law Snowball sampling https://en.wikipedia.org/wiki/Snowball_sampling 89

Case 18-2868, Document 283, 08/09/2019, 2628241, Page491 of 883 Tatar, A., de Amorim, M. D., Fdida, S., & Antoniadis, P. (2014). A survey on predicting the popularity of web content. Journal of Internet Services and Applications, 5(1), 1. Teevan, J., Adar, E., Jones, R. and Potts, M. (2006). History repeats itself: repeat queries in Yahoo's logs. In Proceedings of the 29th annual international ACM SIGIR conference on Research and development in information retrieval (SIGIR '06). ACM, New York, NY, USA, 703-704. The Independent https://en.wikipedia.org/wiki/The_Independent The Times https://en.wikipedia.org/wiki/The_Times Triangulation (social science) http://en.wikipedia.org/wiki/Triangulation_%28social_science%29 www.theguardian.com/media/2016/mar/17/independent-mirror-express-and-star-suffer-s harp-fall-in-traffic 90

EXHIBIT 25 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page493 of 883 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VIRGINIA L. GIUFFRE. Plaintiff, 15-cv-07433-RWS v. GHISLAINE MAXWELL Defendants EXPERT REPORT OF PETER KENT OCTOBER 28", 2016 Expert Report of Peter Kent Virginia L. Giuffre v. Ghislaine Maxwell

Case 18-2868, Document 283, 08/09/2019, 2628241, Page494 of 883 Slave, Virginia Roberts Lies, Virginia Giuffre Lies, Virginia Roberts Giuffre Lies, Virginia Roberts Untrue, Virginia Giuffre Untrue, Virginia Roberts Giuffre Untrue, Virginia Roberts Liar, Virginia Giuffre Liar, Virginia Roberts Giuffre Liar, Virginia Roberts Ross Gow, Virginia Giuffre Ross Gow, Virginia Roberts Giuffre Ross Gow, Virginia Roberts Ross dishonest, Virginia Giuffre Ross dishonest, Virginia Roberts Giuffre dishonest, victims refuse silence sex slave 32. However, nowhere in his report does Mr. Anderson explain why these 26 search terms are important, beyond the fact that, he claims incorrectly, searching the major search engines with these phrases results in links to Web pages that contain allegedly defamatory material. However, this is true of literally thousands of different search phrases _ it’s a simple task to create search terms to match particular pages but he never explains why these particular 26 phrases are relevant. 33. As I explain below in detail, Mr. Anderson’s testimony is unreliable because it is not based on sufficient facts or data, nor is it the product of reliable principles and methods. Rather, it is seriously flawed in a number of ways. 1. Mr. Anderson’s Choice of Search Terms Is Arbitrary 34. Mr. Anderson, in his report, provides a list of 26 search terms (Page 7) that appear to have been chosen in an arbitrary manner; furthermore, Mr. Anderson does not explain how these search terms are relevant to this case. Most of the examples are rarely if ever searched upon, and return few, if any, relevant results (that is, links to pages that discuss or recount Defendant’s alleged defamatory statements). 35) Search terms are only relevant to this case if a searcher, wishing to find information about Plaintiff, would type the terms into a search engine. Mr. Anderson does not explain why such a person would type, for instance, the term victims refuse silence sex slave; in fact there seems no reason to believe that such a person would use this term. Why would someone wanting to research information about Plaintiff use the term virginia roberts lies, or virginia roberts ross gow? Mr. Anderson does not suggest any reason that somebody should use such terms. Indeed, these are terms unlikely to be used by anyone unfamiliar with this litigation or the fact that Defendant had denied Plaintiff's original allegations. These are not terms likely to be used by Mr. Anderson’s “casual searcher” (“I conducted an investigation to determine the Expert Report of Peter Kent Virginia L. Giuffre v. Ghislaine Maxwell

Case 18-2868, Document 283, 08/09/2019, 2628241, Page495 of 883 106. However, this 3-step process (create pages, place them on Web sites, create links to the pages) is not very efficient, regardless of the fact that it is common in the ORM business. One should keep in mind that the primary goal of any business is maximizing profits, not efficiency. The 3-step process may be inefficient, but it has the advantage of increasing the income of ORM firms; rather than merely creating links, they can also charge for the creation and placement of Web pages. There is, however, an alternative strategy that some ORM firms in fact do use, as I describe later in this report. 2. The Problems With Mr. Anderson’s Strategy 107. Mr. Anderson’s strategy is unnecessarily expensive and complicated, for a number of reasons: « Mr. Anderson exaggerates the number of Web pages (780) that must be pushed down in the search results e Placing new Web pages on quality Web sites will be very difficult, and unnecessary « Pushing the new Web pages up in the search results will be very difficult a) Mr. Anderson Exaggerates the Number of Web Pages (780) That Must Be Pushed Down In The Search Results 108. Mr. Anderson has stated that 780 Web pages must be pushed down in the search results; he takes his 26 search phrases, and multiplies by 30 results (in theory 10 results per search-result page, over three pages, in order to push the “offending” pages down to the fourth page, though in some cases, in particular on Google, there may actually be fewer results on the first page, perhaps 8 or 9.) This is wrong for various reasons. Most of the Search Terms Will be Used Infrequently If Ever 109. As noted earlier, most of Mr. Anderson’s 26 search terms are infrequently if ever employed by searchers. Why, for instance, would it be necessary to push down offending Web pages in the results that the search engines provide for the term victims refuse silence sex slave, when this term is likely never used (and furthermore, that the search results contain no Expert Report of Peter Kent Virginia L. Giuffre vy. Ghislaine Maxwell 33

EXHIBIT 26 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page497 of 883 From: <ross@acuityreputation.com> Date: 2 January 2015 at 20:38 Subject: Ghislaine Maxwell To: Rossacuity Gow <ross@acuityreputation.com> bec: martin.robinson@mailonline.co.uk, P.Peachey@independent.co.uk nick.sommerlad@mirror.co.uk, david.brown@thetimes.co.uk nick.alway@ bbc.co.uk, jo-anne.pugh@bbc.co.uk To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts - so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts that Alan Derschowitz is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. Sent from my BlackBerry® wireless device GM_00068

EXHIBIT 27 (Filed Under Seal)

Ma Y.23, 2010 CaS#48-2868, Document 283, 08/09/2019, 2628241, Page499 Of883 Page: 1 Document Name; untitled PANEL: 1234 Qa cD RO2 RO2 EAL EA1 FAL E01 Eol EO1 Eo1 RO3 E01 E01 E01 ENTRY DATE 101201 092001 081401 081600 062100 081699 081998 082097 082097 040797 082294 082393 082592 oD PF1=HELP 3=EXIT PAGE FULL...CONTINUE. WITHDRAWAL cD W26 wo2 W32 w47 w47 wo3 wo2 wol W22 wo2 DNE wo2 wol DATE 030702 101101 092001 081301 081500 081699 060999 061098 082097 061197 082294 061094 061193 AO7. ASSIGNMENT HISTORY Monday May 23, 2016 9:04 am stot: QJ) xoperrs, vircInia 1 Dro MVUAWVCADAVANNNZZ PP SY 02 02 02 ol 00 oa 99 98 98 o7 95 24 93 cL ol Ol Al Al Al o1 ol ol OL OL O1 Ol ol DS SCHL 3390 2331 2192 2192 2192 2331 0581 2331 2191 1691 1703 1901 1901 5=REFRESH 7=BKWD 8=FWD 9=NEXT SCHL; 3390 GR: DESC SURVIVORS ROYAL PALM HIG WLLNGTN HS ADL WLLNGTN HS ADL WLLNGTN HS ADL ROYAL PALM HIG FOREST HILL HI ROYAL PALM HIG WELLINGTON HIG CRESTWOOD MID ROYAL PINES SC LOXAHATCHEE EL LOXAHATCHEE EL PAGE 12=ESCAPE GR 10 10 30 30 30 10 09 09 og 08 06 05 a4 PRS TERML: I1B5 tf 4 YEAR: 16 10 ST; I E ABS UNX Y Bi = Ww Uys eee a 25 Y 33 y 5 ¥ 13 Y dae 8 Date: 5/23/2016 Time: 9:05:36 AM GM_00888

Case 18-2868, Document 283, 08/09/2019, 2628241, PageS00 of 883 TO - DISTRICT: 0000050 PALM BEACH SCHOOL DISTRICT SCHOOL; 3390 COURSE INFORMATION PILE; saTs123s SS Tes 2 To ‘ CURRENT DISTRICT; 50 PALM BEACH SCHOOL PAGE 3 CURRENT SCHOOL: 3390 SURVIVORS CHARTER SCHOOL DISTRICT: 50 SCHOOL: OSHL FOREST HTLL HIGH DISTRICT: 50 SCHOOL: 3390 NO COURSES ‘TAKEN YEAR: 1998-1999 GRADE LEVEL: 09 YEAR: 2000-2001 GRADE LEVEL: NA SUBJECT CRSHG AO CREDIT ‘'T coURSBH COURSE TITLE AREA FLAG RC N ATT. /BARN GPA QTY PTS GPA QTY PLS 1 0500500 PBRS,CAR,SCH DEV 1 EL B 2ZN0.50 0.50 DISTRICT-TeHM: 1.9286 5.00 CUM; 21,5429 27.00 1 0704320 FRENCH 2 FL BI CG %N 0.50 0.50 STATE-TERM: 1.4286 5,00 CUM: 1.5429 27.00 1 1001340 ENG 2 EN RJ A ZN 0.50 0.50 1 1200380 ALG 1-8 MA OR F ZN 0,50 0.00 2000-2001 NMWAL DAYS-PRESHNT- 0 ABSENT: 0 1 1900300 DRIVER ED CLASS EL. B ZN 0.50 0.50 SUMMER TERNS DAYS-PRESBNT: 0 ABSENT: 0 1 2000310 BIO 1 gsc RI A ZN 0.50 G.50 PROMOTION STATUS NOT APPLICABLE 2 2109320 WORLD HIST wa RJ C ZN O50 0.50 2 0500500 PERS,CAR,SCH DEV 1 EL BP ZW 0.50 0.00 DISTRICT: $0 SCHOOL: 3350 SURVIVORS CHARTER SCBOOL 2 0701320 FRENCH 1 FL RF F ZN 0.50 0.00 YBAR: 2001-2002 GRADE LEVEL; 10 2 0800300 BRAGTHI-LIF MGMT SKIM RJ P ZW 0.50 0.00 SUBJECT CRSEG AO CREDIT 2 1001340 ENG 2 EN RJ F 2% 0.50 0.00 T COURSE COURSH TITLE AREA FLAG RC BATT. /EARN 2 1200360 ALG 1-B MA sR F 2 0.50 0.00 1 0500530 PERS,CAR,.SCH DEV 4 EL Cc ZN 0.50 0.50 2 2000310 BIO 1 SC RT F ZU O0.50 0,00 1 1001440 BUS ENG I EN 9 B ZN O.50 0.50 2 2109310 WORLD HIST Wi KF ¥ ZN 0.50 0-00 1 1205370 CONSUMER MATH MA C CC #8 0.50 0,50 CREDIT, TERM: 7,00 3.00 1 8300310 WORKPLACE ESSENTIAL VO B 20,50 0.50 1 8302610 WORK EXP 1 vo F ZN 0.50 0.00 GPA QTY PIS OpA Ory Prs 3 8301650 WORK EXP-OJT vo F ZN 1,00 0.00 DISTRICT-TERM: 1.2857 3.00 CUM; 1.5713 22.00 CREDIT, TERM: 3.50 2.00 STATE-TERM: 1.2857 9.00 CUM: 1.5714 22,00 GPA QTY PTS GPA QTY PTs 1998-1999 ANNUAL DAYS-PRESENT: 155 ABSENT: 25 DISTRICT-TERM: 1.4286 5.00 CUM: 1.5429 27.00 SUWOIER TRRMS DAYS-PRESENT: © ABSENT: 0 STATE-TERM: 1.4286 5.00 CUM: 1.5429 27.00 ACADEMICALLY PROMOTED 2001-2002 ANNUAL DAYS-PRESENT: 69 ABSENT: 32 DISTRICT: 50 SCHOOL: 3390 NO COURSES TAEEN SUMMER TERMS DAYS -PRESENT: 0 ABSENT: 0 YEAR: 1999-2000 GRADS LEVEL: NA NOT ENROLLED IN DISTRICT K-12 AT END OF SCHOOL YEAR GPA QTY PTS GPA OTY PTS DISTRICT-TERM: 1.4286 5.00 CDM: 1.5429 27.00 STAPE-TERM: 1.4266 5.00 CUM: 1.5429 27.00 1999-2000 ANNUAL DAYS-PRESENT: 0 ABSENT: © SUMMER, TERKS DAYS-PREARNT: U ABSENT: 0 PROMOTION STATOS NOT APPLICABLE GM_00893

EXHIBIT 28 (Filed Under Seal)

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Case 18-2868, Document 283, 08/09/2019, 2628241, Page507 of 883 IMPORTANT MESSAGE | f M. OF. PHONE/ MOBILE. MESSAGE. 7 = ; 5 pul iat” at Ube ALT TELEPHONED PLEASE CALL TELEPHONED Pi E CALL CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILLIRALL AGAIN WANTS TO SEE YOU RUSH WANTS TO SEE YoU | ad { -BETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE 37>. / \ PHONE/ MOBILE ____ MESSAGE. [jis O.K. jor to stop by somethnite ey TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU | RUSH WANTS TO SEE YOU RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL | SPECIAL ATTENTION sA001450 GIUFFRE001421

Ow em wo ew we we re 4 Oo eww a. YG Gs a, Wa. Ware a! cree 108 (5 GQ. > @ @W. @ UG G. i Case 18-2868, Document 283, 08/09/2019, 2628241, Page508 of 883 IMPORTANT MESSAGE i 4h x ie Hipxsay pO o¢s AM —— time {5 — ; 1) PR IMPORTANT MESSAGE TELEPHONED CAME TO SEE YOu GAME TO SEE YOU WANTS TO SEE YOU RETURNED YOUR CALL MESSAGE Vas ic Cell bunt TELEPHONED CAME TG SRE You | WANTS TO SEE YOU | WANTS TO SEE You RUSH RETURNED YOUR CALL RETIRHED YOUR CAL a SPECIAL ATTENTION TELEPHONED CAME TO SEE YOU | PLEASE GALL WILL CALL AGAIN MESSAGE —___ ne SIGNED. SIGNED___ GIUFFRE00 1423

7A WT Wa WA AA 5 2 2 2 e se 2 we 2s a 2 @ 2 a > > 2 2 2 => a 2 ) O49 OWE HSE sored SRAM AAA @A ww Case 18-2868, Document 283, 08/09/2019, 2628241, Page509 of 883 IMPORTANT MESSAGE IMPORTANT MESSAGE TELEPHONED PLEASE CALL TELEPHONED | CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU | WANTS TO SEE YOU | RETURNED YOUR CALL MESSAGE —— SPECIAL ATTENTION MESSAGE. SIGNED__ FOR DATE “ae TELEPHONED IMPORTANT MESSAGE 1 3 Time = PLEASE CALL SIGNED. TELEPHONED oe MESSAGE DATE ofp 4 gos ]] PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL GALL AGAIN WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH ‘ [perdenen YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL | MESSAGE SPECIAL ATTENTION SIGNED _ _SIGNED___ GIUFFREO01426

ee et ee ne SRA SSSMDO9 SMO OOUUYVOUUDOOVODOOOODE 1 SCI18¢ 70001 IMOOODONDHOORVEAO Case 18-2868, Document 283, 08/09/2019, 2628241, Page510 of 883 | IMPORTANT MESSAGE OF_ PHONE/ MOBILE. TELEPHONED IMPORTANT MESSAGE PLEASE CALL MOBILE TELEPHONED PLEASE OALL CAME TO SEE YOU WILL CALL AGAIN CAME 70 SEE vou Jone cart acain WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH RETURNED YOUR GALL SPECIAL ATTENTION < ED, ivan RETURNED YOUR CALL MESSAGE SPEGIAL ATTENTION IMPORTANT MESSAGE — 5 FOR TELEPHONED SIGNED__. FOR SS DATE iz > fet OF. PHONE/ MOBILE. TELEPHONED 2/7 2485 IMPORTANT MESSAGE TIME /] PLEASE CALL CAME TO SEE YOU WANTS TO SEE YOU CAME TO SEE YOU ] WILL. CALL AGAIN WANTS TO SEE YOU RETURNED YOUR CALL MESSAGE RETURNED YOUR Cétt: MESSAGE ‘SPECIAL ATTENTION SA001477 cussicn icin. GIUFFRE001449

Case 18-2868, Document 283, 08/09/2019, 2628241, Page511 of 883 IMPORTANT MESSAGE IMPORTANT MESSAGE TELEPHONED PLEASE CALL TELEPHONED { PLEASE CALL | ' CAME TO SEE YOU | WILL CALL AGAIN CAME TO SEE YOU j WILL CALL AGAIN WANTS TO SEE YOU RUSH WANTS TO SEE YOU } RUSH L RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL MESSAGE = fete MESSAGE = — j SPECIAL ATTENTION STUCSUECB Clee t — ® ddd | IMPORTANT MESSAGE | nt ‘ Z iad pont = pete, > AM. = mis, ae oO PM. Ovo tmeZL Oe eM SD wD oe 7 > = wy PLEASE CALL TELEPHONED @ CAME TO SEE YOU WILL CALLAGAIN ‘CAME TO SEE YOU Tt) WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH cv) RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION wD = SAO0: a 1456 »~ ag wo SIGNED &, | GIUFFREO0 142

SEV OGOOCVVYV YU OOCG OEE UEY OO YVvO Uw S 2 2 » Ss » ys > % » » 5 EEN ‘ Case 18-2868, Document 283, 08/09/2019, 2628241, Page512 of 883 “eww tt of nmwKy [ IMPORTANT MESSAGE | MESSAGE IMPORTANT MESSAGE Fora f pag eed ome Ze AS fF aime. PLEASE CALL TELEPHONED | PLEASE CALL E {CAME TO SEE YOU | WILL. CALL AGAIN CAME TO SEE YOU WILL CALLAGAIN WANS TO SEE YOU [Rust [SPECIALATTENTION |_| WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE. SIGNED. IMPORTANT MESSAGE SIGNED. IMPORTANT MESSAGE ron ECOL, __ Tiel TELEPHONED PLEASE CALL PLEASE CALL CAME TO SEE YOU WiLL CALLAGAIN CAME TO SEE.YOU WILL CALL AGAIN RUSH MESSAGE Zit SPECIAL ATTENTION WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION SA001457 SIGNED_ SIGNED. GIUFFRE001428

Case 18-2868, Document 283, 08/09/2019, 2628241, Page513 of 883 IMPORTANT MESSAGE IMPORTANT MESSAGE ioe Lg? EPSIEL Pe AM. IR TIM J vr Fre € OF TELEPHONED ut TELEPHONED “| PLEASE CALL CAME TO SEE YOU CAME TO SEE YOU WILL CALLAGAIN WANTS TO SEE YOU i WANTS TO SEE YOU RUSH RETURNED YOUR CALL | RETURNED YOUR CALL SPECIAL ATTENTION ENON nto TIES SIGNED. IMPORTANT MESSAGE IMPORTANT MESSAGE a 7, 7 ron_ etic FT K LEIN atin: Lot AM a | pee e time tae OF, MOBILE. TELEPHONED i/ | PLEASE CALL a TELEPHONED .’ | PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN. WANTS TO SEE YOU fas WANTS TO SEE YOU RUSH RETURNED YOURCALL| || SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION SSE SSS FF Fw FS FFE OV FV HHH HK DOVDUIDIKKKDY 1 S$A001461 2 3 seat “a si@veD SIGNEN GIUFFRE001432

Case 18-2868, Document 283, 08/09/2019, 2628241, Page514 of 883 | IMPORTANT MESSAGE | | IMPORTANT MESSAGE | POR) be ron AR AH - aN alii; Abe pave fi ig ise PM. M PHONE/ MOBILE. TELEPHONED PLEASE CALL \ TELEPHONED CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WANTS TO SEE YOU RUSH a | WANTS TO SEE YOU RETURNED YOUR CALL ‘SPECIAL ATTENTION RETURNED YOUR CALL MESSAGE NCDowe SIGNED. IMPORTANT MESSAGE PAM PR MAR ERSTE: TELEPHONED | TELEPHONED | | PLEASE CALL CAME TO SEE YOU 4 { CAME TO SEE YOU | — [WILL CALLAGAIN WANTS TO SEE YOU | WANTS TO SEE YOU | _ RETURNED YOUR CALL SSFSOSCPFPSHSFTFCFCHGOFTHSCEFEFTVOIOUETKTOOVHUVVOVOODOVOVOVLY SIGNED ay ‘SIGNED. GIUFFRE00 1433

Case 18-2868, Document 283, 08/09/2019, 2628241, Page515 of 883 CEST [ IMPORTANT MESSAGE | IMPORTANT MESSAGE ron AR EPS TEED: . PHONE! MOBILE. TELEPHONED { { PLEASE CALL TELEPHONED __| PLEASE CAL CAME TO SEE YOU | ‘WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU | RUSH WANTS TO SEE YOU RUSH | RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIALATTENTION | MESSAGE -— fAles SIGNED. IMPORTANT MESSAGE ron MR: EPSTEIN DATE MAX PHONES MOBILE TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL CAME TO SEE YO "| WILE CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION 3 3 > > > > a > a 2 5 > 2 2 2 2 2 2 2 2 2 6 2 S e 2 2 4S a 2 2 BD: a 2 2 SD 2» » 2 GIUFFRE00 1435

Fe ye in wn, a a Hy PIPMNMOVD ESO IONMMOHOHOHOHHRUEEVYVUYLEHASEBELULDE 4) ) ia) ¢ seireé rat Case 18-2868, Document 283, 08/09/2019, 2628241, Page516 of 883 IMPORTANT MESSAGE TELEPHONED PLEASE CALL IMPORTANT MESSAGE @} PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU | WiLL CALL AGAIN WANTS TO SEE YOU RUSH WANTS TO SEE YOU | RUSH RETURNED YOUR CALL MESSAGE SPECIAL ATTENTION RETURNED YOUR CALL | SPECIAL ATTENTION OO cas ge TELEPHONED <| PLEASE. CALL MOBILE. TELEPHONED CAME TO SEE YOU | [wie CALL AGAIN CAME TO SEE YOU WANTS TO SEE YOU RETURNED YOUR CALL n 7 > Oey i rpst eel WANTS TO SEE YOU RETURNED YOUR CALL MESSAGE Xi SA001476 GIUFFRE00 1448

ee ee et ne uh SOG OS OPM O OOOOH UUVOOOUDOOODOOGOH SCI18¢ 70001 IMOOODONNDHOORVAO Case 18-2868, Document 283, 08/09/2019, 2628241, Page517 of 883 IMPORTANT MESSAGE OF__ PHONE/ MOBILE. TELEPHONED PLEASE CALL | IMPORTANT MESSAGE OF PHONES MOBILE, TELEPHONED CAME TO SEE YOU WILL CALL AGAIN WILL CALL AGAIN CAME TO SEE YOU WANTS TO SEE YOU RUSH WANTS TO SEE YOU | RUSH RETURNED YOUR GALL SPECIAL ATTENTION a ET, SPECIAL ATTENTION RETURNED YOUR CALL MESSAGE IMPORTANT MESSAGE — 5 FOR TELEPHONED SIGNED__. IMPORTANT MESSAGE FOR ee ap J AM 2/7 2445 M. DATE £7 Z2IGS TWME__ PM. iz > fet PHONES MOBILE. /] PLEASE CALL TELEPHONED CAME TO SEE YOU WANTS TO SEE YOU ] WILL. CALL AGAIN CAME TO SEE YOU WANTS TO SEE YOU RETURNED YOUR CALL MESSAGE RETURNED YOUR Cétt: ‘SPECIAL ATTENTION MESSAGE SA001477 cussicn Ou ek GIUFFRE001449

Case 18-2868, Document 283, 08/09/2019, 2628241, Page518 of 883 IMPORTANT MESSAGE IMPORTANT MESSAGE FOR Me. CFE trv one BY J OF TIME FIG ys uke Mark tpsfery OF. TELEPHONED CAME TO SEE YOU wessrce AS cel for WANTS TO SEE YOU RETURNED YOUR CALL MESSAGE. Cou Hew) poke FOR. FSSESSSODOSHHHKHDDdddDIdDOO_OOODE TELEPHONED CAME TO SEE MESSAGE. 30K) GAL. (2 lL» i» is is ie JAt Thes LOY | PLEASE CALL IMPORTANT MESSAGE tthe EFS Fe 014 or “A Ca jiM/son You | WILL CALLAGAIN WANTS TO SEE YOU RETURNED YOUR CALL OPEL ASE Te _/0¢ FEN | SPECIAL ATTENTION ae Atl Be qe, 15 B70 Mum ger ror = 1H Grrae SIGNED. OF. PHONE/ MOBILE. TELEPHONED PLEASE CALL ‘CAME TO SEE YOU | WILL CALL AGAIN WANTS TO SEE ov | { SPECIAL ATTENTION SA02828 SIGNED. GIUFFREO01452

Try = @ TETTCCCTTT YT 0d0000 ® BS: HHLHGEEEETS GST TT Case 18-2868, Document 283, 08/09/2019, 2628241, Page519 of 883 IMPORTANT MESSAGE ron eR ee , AM. we TIME Ue hy M. IMPORTANT MESSAGE JIS AZ. OF. PHONE/ MOBILE TELEPHONED ‘CAME TO SEE YOU WANTS TO SEE YOU WANTS TO SEE YOU | _ RETURNED YOUR CALL RETURNED YOUR CALL IMPORTANT MESSAGE FOR. ms re AM, PM. TELEPHONED PLEASE CALL SIGNED. IMPORTANT MESSAGE pon 22 EP Ae oy owe L027 OY aye FO GP nw LA DeBin CAME TO SEE YOU WILL CALL AGAIN: WANTS TO SEE YOU RUSH ‘CAME TO SEE YOU pat CALL AGAIN WANTS TO SFE You | RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE RETURNED YOUR CALL SPECIAL ATTENTION SAO02829 SIGNED. GIUFFRE001453

DHHHOSHHHHHHVVAT HDOOHOS pea pe as en, S5OO BESTS: lag % Sepcoresey Case 18-2868, Document 283, 08/09/2019, 2628241, Page520 of 883 IMPORTANT MESSAGE ron MS, MAXWELL ee ome DAJas 04 re 6:55 _ AN CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU at WANTS TO SEE YOU RUSH WANTS TO SEE YOU RETURNED YOUR CALL | SPECIAL ATTENTION RETURNED YOUR CALL Eh. MESSAGE. svoneo ware IMPORTANT MESSAGE Fon__2¢ qf n cuY. ee AM. es TE PM. PLEASE CALL ! TELEPHONED jw. CALL AGAIN j CAME TO SEE YOU | WILL CALL AGAIN RUSH ; WANTS TO SEE YOU | RUSH ! SPECIAL ATTENTION ? RETURNED YOUR CALL j, SPECIAL ATTENTION wessace LOOUIA Ye nel ofl Ye nave & Leeware” Come to Yalm Hach Yeelacy to abesy | \neve ane Inclo Seeas Aoi 4h0F£ writin Cisteune ise SA02830 SIGNED. GIUFFRE00 1454

poddudouOeeD: oe O00 6 SKHDODOHOOSE TeeOPGNaqqnTTTT| &8 55S Sb Ob, Case 18-2868, Document 283, 08/09/2019, 2628241, Page521 of 883 IMPORTANT MESSAGE ror_MK FPS TEN . = uy TIME AL Pu IMPORTANT MESSAGE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN TELEPHONED CAME TO SEE YOU | PLEASE CALL | WILL CALL AGAIN WANTS TO SEE YOU RUSH 4 WANTS TO SEE YOU RUSH RETURNED YOUR CALL | SPECIAL ATTENTION RETURNED YOUR CALL SPECIALATTENTION MESSAGE. d S MESSAGE A BEEP Conrinont Ooottintg Foy CoMPuréic LN CALAN: SIGNED. IMPORTANT MESSAGE oe FOR. a (GAT etre 4 PM. "BIO, OF. AN ME PHONE/ = ot Oe MOBILE. sa [rceasecan | WILL CALL AGAIN J PLEASE CALL |_| WILL CALL AGAIN WANTS TO SEE YOU RUSH | TELEPHONED CAME TO SEE YOU WANTS TO SEE YOU RETURNED YOUR CALL RETURNED YOUR CALL | SPECIAL ATTENTION SA02832 SIGNED. GIUFFRE00 1456

Dodd bd TESOSIT : 00000 bbobdoed: ot Boose b Case 18-2868, Document 283, 08/09/2019, 2628241, Page522 of 883 IMPORTANT MESSAGE ron LYK: EP STOP . Ar pate__ 47 TIME £160 BM: IMPORTANT MESSAGE FOR. L¢. les Fe 7/. ELW AM. te 2-29 pi. " PARR PHONEY MOBILE. TELEPHONED {PLEASE CALL CAME TO SEE YOU | WILL CALL AGAIN WANTS TO SEE YOU RETURNED YOUR CALL SPECIAL ATTENTION SIGNED. IMPORTANT MESSAGE Fon (= = DATE Spy M z i _ PHONE, ne. IMPORTANT MESSAGE <— j EL vey | PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU } RUSH RETURNED YOUR CALL| | SPECIALATTENTION |__| EA ry aA me@vcl A rte Lined Cah Tdop't low clon! SA02838 CLESTOUSE OTS: SIGNED. SIGNED. GIUFFRE00 1462

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Case 18-2868, Document 283, 08/09/2019, 2628241, Page524 of 883 TELEPHONED PLEASE CALL ; TELEPHONED | PLEASE CALL ‘CAME TO SEE YOU WILL CALL AGAIN 5 CAME TO SEE YOU WILL CALL AGAIN: WANTS TO SEE YOU RUSH i WANTS TO SEE om RUSH RETURNED YOUR CALL. SPECIAL ATTENTION i RETURNED YOUR CALL SPECIAL ATTENTION wiegssce 1€ Nos a teacher | + |mecsrce She called -f’ for ou _ to teach you | | ou pokd Life Por hom! to speak YUSSian | | her_€2 work. She { Sher ss 2x & yeors ode | | |_is araiccbfe tom. d Blade LSS0°25 Cte » | 4c? noon anal vee oh te ble Non - Fer uve Z foc eg iF welt a i134 TELEPHONED 4 | oP PLEASE CALL ' TELEPHONED CAME TO SEE YOU spUAGAI : CAME TO SEE YOU WANTS TO. BEE YOu i WANTS TO SEE YOU SPECIALATTENTION F RETURNED YOUR CALL MESSAGE. She hao I Card fa Navat on Fhe 2 2076 GIUFFRE001563

EXHIBIT 29 (Filed Under Seal)

EXHIBIT 30 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page527 of 883 gue U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 3340! (561) 820-8711 Facsimite: (S61) 820-8777 September 3, 2008 ViA COURIER Ms. Virginia Roberts c/o Asst Legal Attache Matthew Witt United States Embassy Sydney Australia Re: Jeffrey Epstein/Virginia Roberts: NOTIFICATION OF IDENTIFIED VICTIM Dear Ms. Roberts: By virtue of this letter, the United States Attorney’s Office for the Southern District of Florida provides you with the following notice because you are an identified victim of a federal offense. On June 30, 2008, Jeffrey Epstein (hereinafter referred to as “Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cl-009454AXXXMB and 2008-cf009381AXXXMB) and was sentenced to a term of twelve months’ imprisonmen: to be followed by an additional six months’ imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to cerlain conditions, including the following: ‘ TD An independent Special Master was assigned the task of selecting an attorney representative to represent the victims, including you, in connection with civil actions between the victims and Mr. Epstein. The GTUFFREO01203

Case 18-2868, Document 283, 08/09/2019, 2628241, Page528 of 883 MS. VIRGINIA ROBERTS et NOTIFICATION OP IDENTIFIED VICTIM SEPTEMBER 3, 2008 PAGE 2 OF 3 Special Master selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, P.A., ahighly-respected and experienced attorney. Youare not obligated to use Mr, Josefsberg as your civil attorney, but, as explained in greater detail below, Mr. Josefsberg’s services wil} be provided atno cost to you because Mr. Epstein is obligated to pay the costs and fees of the attorney-representative. Also, Mr. Epstein and his attorneys can only contact you via Mr. Tosefsberg, assuming that you would like Mr. Josefsberg to serve as your attorfiey. If you elect to file suit against Mr. Epstein pursuant to Title 18, United States Code, Section 2255, Mr. Epstein will not contest the jurisdiction ofthe United States District Court for the Southern District of Florida over his person and/or the subject matter, and Mr. Epstein waives his right to contest liability and also waives his right to contest damages up to an amount as agreed to between you and Mr. Epstein, so long as you elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any other claim for damages, whether pursuant to state, federal, or common law. Notwithstanding this waiver, Epstein’s agreement with the United * States, his waivers and failure to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability. As stated above, Mr. Epstein has agreed to pay the fees of the attorney representative selected by the independent third party. ‘This provision, however, shall not obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, if after consideration of potential settlements, you and Mr. Josefsberg elect to file a contested jawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other contested remedy, the obligation to pay the costs of the attorney representative, as opposed to any statutory or other obligations to pay reasonable attorneys fees and costs such as those contained in Section 2255, shall cease. Please contact either myself at ann.marie.c.villafana@usdoj.gov, or Justice Department Victim-Witness Specialist Twiler Srnith at Twiler. Smith@ic, fi.gov with a good telephone number and/or e-mail address, so that we may provide Mr. Josefsberg with a timely means of. communicating with you. If you would like to contact Mr. Josefsberg GTUFFREOO 1204

Case 18-2868, Document 283, 08/09/2019, 2628241, Page529 of 883 Ms. VIRGINIA ROBERTS NOTIFICATION OF IDENTIFIED VICTIM SEPTEMBER 3, 2008 PAGE 3 OF 3 directly, he can be reached at +1 305 358-2800. If you have already selected other counsel to represent you, or if you do so in the future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein’s attorney, Jack Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. In addition, there has been litigation between the United States and two other victims regarding the disclosure of the entire agreement between the United States andMr. Epstein. Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney to represent you, that attorney can review the Court’s order in the matter of Jnre Jane Does 1 and 2, United States District Court for the Southern District of Florida Court File No, 0880736-CIV-MARRA. Please understand that neither the U.S, Attorney’s Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation. Thank you for all of your assistance during the course of the federal and state investigations and please accept the heartfelt regards of myself and Special Agents Kuyrkendall, Slate:, and Richards for your health and well-being. Sincerely, R. Alexander Acosta United States Attorney A. Marie Villafafia Assistant United States Attorney ce: Robert Josefsberg, Esq. Jack Goldberger, Esq. GTUFFREO01205

EXHIBIT 31 (Filed Under Seal)

-1 of 12Case 18-2868, POGUE RES PERMA REET Page531 of Date of entry 07/05/2013 FD-302 (Rev. 5-8-10) VIRGINIA L. GIUFFRE, maiden name ROBERTS, date of birth Social Security Account Number United States Australian Permanent Resident, residence New South Wales, Australia, 2261 was interviewed at the United States Consulate in Sydney, Australia. GIUFFRE was advised of the identity of the interviewing agents and purpose of the interview. Present during the interview was Federal Bureau of Investigation Special agentT sd and via telephone, Assistant ee United States Attorney GIUFFRE provided the following information: GIUFFRE was born in Sacramento, California to parents date of birth be currently resides in date of birth p7c currently resides in GIUFFRE moved to Palm Beach County, Florida with her parents when she was four years old and returned to California at age 11. She returned to Florida at age 13 and was placed in a rehabilitation or foster care facility in West Palm Beach, Florida. GIUFFRE ran away from the rehabilitation facility when she was approximately 14 years old, and while living on the streets in Miami, Florida, she me b6 b7c was training GIUFFRE to be an escort igave GIUFFRE a life off of the streets which made her feel Investigationon 03/17/2011 at Sydney, Australia (In Person) Filey 31E-MM-108062 Date drafted 07/05/2013 b6 ——————— b7C by ‘This document contains neither recommendations nor conclusions of the FBI, It is the property of the FBI and is loaned to your agency; it and its contents are not to be distributed outside your agency. GIUFFRE001235

Case 18-2868, Document 283, 08/09/2019, 2628241, Page532 of 883 FD-302s (Rev. 05-08-10) 31E-MM-108062 Coninuationof FD-3020f Virginia L. Giuffre ,on 03/17/2011 page 2 Of 12 like she was locked into the relationship[__] gave GTUFFRE pharmaceutical drugs toward the end of their relationship. b6 bIC GIUFERE's relationship with[___Jended while she was at a private ranch near Ocala, Florida. GIUFFRE telephonically contacted a childhood friend, from a telephone at the ranch. GIUFFRE bé knew, from elementary school _and called him at the home telephone BIE of his parents GIUFFRE told she was sked her why she did not leave GIUFFRE's telephone conversation with| the recreational vehicle very lonely, an RV) GIUFFRE was did not pack staying in at the ranch strike her her belongings and told her she was going to live with another man. GIUFFRE bE felt that she was sent to ut did not know the bIC specifics of the arrangement. GIUFFRE engaged in sexual activity with who was described as a white male GIUFFRE stated GIUFFRE stayed with[ |aNU for approximately one or two weeks before the police located her and returned her to her parents. GIUFFRE was interviewed by a male detective. GIUFFRE’s parents were still married at the time and lived near[ Florida. GIUFFRE believed there was an FBI investigation related to She never saw[_—sddagaiin after In approximately June 1998 or 1999, GIUFFRE began working at Donald Trump's Mar-A-Lago Club in Palm Beach, Florida. GIUFFRE's father| sd was able to help her gain employment as a baby sitter and later as a locker room attendant at the club. GIUFFRE started studying for her GED and wanted to become a massage therapist. In August, GIUFFRE was reading an anatomy/massage book and was approached by [| _fand help her get her masseuse accreditatiomd ——“—si‘—sSCOY GIUFFRE consulted her father about the opportunity and at approximately 5:00 p.m. the same day, her father drove her to a residence af | be bic GTUFFREO01236

Case 18-2868, Document 283, 08/09/2019, 2628241, Page533 of 883 FD-302a (Rev. 05-08-10) 31E-MM-108062 Continvationof FD-302 of Virginia L. Giuffre on 03/17/2011 3 of 12 »Page [| riorida. [7 ]spoke with Grurre's father and told him it_was a wonderful opportunity for GIUFFRE. GIUFFRE met jalso known as GIUFFRE was led upstairs instructed GIUFFRE_to wash her hands prior to beginning the massage. The massage bega lemonstrated massage techniques to GIUFFRE, Diietea ene Genidve we ohé wavenee | _____ rasetilonea GIUFFRE about her past, including her time as a runaway. GIUFFRE was also asked if she took birth control. GIUFFRE was given instruction and began kissing At the conclusion __ instructed GIUFFRE to obtain two warm wash clothes. One wash cloth was used to clean second was describe: to help him relax. GIUFFRE and GIUFFRE then moved to the steam room and shower where GIUFFRE massaged with soap and a loofah in the shower. At the conclusion of the shower, GIUFPFRE went downstairs and Arrangements were made for GIUFFRE to return to the house the following day after work. GIUFFRE's cellular phone number was given t be b7c bé bi7c b6 bic be bic be b7c bé bic GTUFFREO01237

Case 18-2868, Document 283, 08/09/2019, 2628241, Page534 of 883 FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of FD-302 of Virginia L. Giuffre yn 03/17/2011 page 4 of 12 The same routine and pattern of massages and sexual activity between and GIUFFRE continued for between one and two weeks. At bE bic loffered GIUFFRE the option to quit her jeb at Mar-A-Lago and travel There was also discussion of GIUFFRE receiving massage training. GIUFFRE was to be paid $200.00 per day for travel and $200.00 per hour for massages. Early in her relationshi bb b7c and was introduced as| assistant. GIUFFRE soon_began traveling[—siFor the initial six months, GIUPFRE cece] ena the United States and Caribbean, ee including California, New York City, New Mexico, and various b ess bI7Cc Six to nine months after GIUFFRE began working for GIUFFRE was bE BTC at the time. GIUFFRE met the couple at_a condominium next to the and was a NU. Shortly thereafter, NU GIUFFRE cleaned She was paid cash In_ addition, paid GIUF GIUFFRE was 16 years old at the time GIUFFRE advisedT SS ~id troduced her to the drug Xanax. She explained that Xanax helped her escape from reality but allowed her to bE still function normally. Xanax helped her go forward with what she was an doing wit land others. Her habit went from two pills per day up to eight pills per day. GIUFFRE's second_client was an academic of some sort described as an older American male sent GIUFFRE from Miami International Airport tol b6 by commercial airline. GIUFFRE was picked up at the bIC airport by} nd then taken to the island by boat. GIUFFRE GIUFFREOO 1238.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page535 of 883 FD-302a (Rev, 05-08-10) 31B-MM-108062 Continuation of FD-302 of Virginia L. Giuffre on 93/17/2011 page 5 of 12 pointed out tha ee instructed GIUFFRE to entertain the : b7e client and wanted to ride jet skis and participate in other island activities| GIUFFRE spent two days_on the island with the client. GIUFFRE assumes the client also traveled| commercially. During the following several months, GIUFFRE traveled internationally Prior to her traveling abroad[__—sssisted GIUFFRE in getting her passport. GIUFFRE got passport photographs of herself and bo provided them t he vemaining paperwork was taken care of by bie IGIUFFRE traveled to Paris, France, the South of France, London, England, Africa, and Spain. While in Paris, GIUFFRE recalled staying at a hotel overlooking the Champs-Elysees. While IUFFRE traveled on the international times, GIUFFRE would contacted GIUFFRE through be b7c offered GIUFFRE a contract, GIUFFRE agreed to the contract for her story and was paid $140,000 for the story, $10,000 when the article was printed, and another $10,000 to be wired into GIUFFRE's account in May 2011. The contract prevented GIUFFRE from talking to_an other press for a specified ith detailed period. GIUFFRE informatio: advised that she b7¢ ————— bic GTUFFREO01239

Case 18-2868, Document 283, 08/09/2019, 2628241, Page536 of 883 FD-302a (Rev. 65-08-10) 31E-MM-108062 Continuation of FD-302 of Virginia L. Giuffre ,on 93/17/2011 6 of 12 . Page be bic At age 16, GIUFFRE be TUFERE believed she and Bee approximately the same age. bé bIc GIUFFRE would dress bE BTC GIUFFRE, though explained _— ‘ie GIUFFRE provided an b7C GIUFFRE described] An unknown individual GIUFFRE saw when she arrived at b6 b7C IUFFRE had GIUFFRE said that day was a low stage in her relationshibecause she could not believe! GIUFFRE never GIUFFREOO1240

Case 18-2868, Document 283, 08/09/2019, 2628241, Page537 of 883 FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of FD-3020f Virginia L. Giuffre on 03/17/2011 page 7 Of 12 saw GIUFFRE believed the girls may have been b6 GIUFFRE was not certain o GIUFFRE had a picture of herself she wanted to be b7c GIUFFRE described some of the unique interior areas of b6 b7C [which Grurrre referred to[ which was where GIUFFRE stayed. While in New York, GIUFFRE also stayed at_an apartment on 66th street IGIUFFRE was aware of additional b6 apartments in the same building. According to he bie apartment building on 66th street was owned by advised that she had a photograph of the interior of the 66th Street GIUFFRE advised that some of her photographs that were provided to her civil attorneys by her family were not returned. One of the missing photos depicted GIUFFRE wearing a pink dress while seated on a quad bike. = ved fensie that formerly lived in b6 b7Cc GIUFFREOO1241

Case 18-2868, Document 283, 08/09/2019, 2628241, Page538 of 883 FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of FD-302 of Virginia L. Giuffre ,0n 03/17/2011 pape 8 Of 12 LNU and GIUFFRE went shopping_to r_and purch clothing and sex be b7c bb bic GIUFFRE used a cellular telephone She believed it was a New York City number but could not recall the number. GIUFFRE and| GIUFFRE could only remember faces not their names. GIUFFRE but she did tr unsuccessfully to get GIUFFRE recalted but she could b6 not recall the wording. NU. bic GIUFFRE advised GIUFFRE traveled] ito a self-help conference at a hotel in New Orleans, Louisiana. The hotel was near the Hard Rock Café in New ae Orleans. GIUFFRE traveled the worl neluding the USVI, New York, Santa Fe, Palm Beach, France, Africa, Spain and the United Kingdom, GIUFFRE lled visiti Be recalled visiting BIE Alhambra Castle in Spain. IGIUFPRE eventually traveled to the United Kingdom and GTUFFREOO1242

Case 18-2868, Document 283, 08/09/2019, 2628241, Page539 of 883 FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of FD-302 of Virginia L. Giuffre (on 03/17/2011 page 9 of 12 while there[ __ approached GIUFFRE in a very excited manner and told her they had to go shopping to pick out a dress because GIUFFRE would be b6 dancing with] ] bic GIUFFRE and_____fwent shopping and purchased makeuy| clothing, and a Burberry bag. The items were purchased with GIUFFRE b6 instructed GIUFFRE to get ready. When GIUFFRE came down after getting ready, she was introduced to. IGIUFFRE traveled to CLUB TRAMP GIUFFRE tayed at CLUB TRAMP for an hour or hour anda half and drank a couple of cocktails before returning to GIUFFRE had not received any direction After returning tof requested to take a photograph of her IGIUFFRE advised that she still had the original photograph in her possession and would provide it to the interviewing agents. GIUFFRE proceeded with Approximately two months later, GIUFFRE met b6é b7c [CSR eco] —OCSC~—~SY Le SS GIUFFRE recalled joking about trading GIUFFRE in because she was getting too old. GTUFFREOO1243.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page540 of 883 FDD-302a (Rev, 05-08-10) 31E-MM-108062 Conimation of FD-302 of Virginia L. Giuffre con 03/17/2011 page 10_0f 32 GIUFFRE recalled meeting 7 2 5 b6 GIUFFRE was using Xanax heavily at the time, bic and her recollection was not clear. She remembered there were many models on the island that did not speak English along with a modeling perso. n who had an unknown accent. be bic id not have a problem with GIUFFRE using prescription drugs. was described by GIUFFRE as a bé b7c (TRUE NAME UNKNOWN)[____] a@ ranch employee a | but GIUFFRE ze could not recall his name. She did have a photograph of the ranch BAS employee. GIUFFRE met numerous famous people academics oliticians, and celebrities. be BIC GIUFFRE received many gitts|_ including jewelry, watches, pags, shoes, make up, clothing, and home furnishings. we b7C GIUFFRE left all of the items behind when she traveled to Tha receive massage training. In August 2002, GIUFFRE traveled by commercial airline to Bangkok, Thailand and began her massage training at International Training Massage sSchool(ITM) where she received, ification. She stayed at the Princess Hotel in Thailand| but never did. GIUFFRE met her future husband during her visit to Thailand. GIUFFRE contacted] Eelephontcally and = 4 im she had fallen in love with someone. GTUFFREOO 1244

Case 18-2868, Document 283, 08/09/2019, 2628241, Page541 of 883 FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of FD-302 o¢ Virginia L. Giuffre , On 03/17/2011 11 of 12 Page GIUFFRE had not heard from GIUFFRE received a istated he was an telephone call from| During that call FBI agent. He was trying to determine what she knew about| | She did not tel anything about her knowledge of She also received another telephone call from a person that indicated he was an FBI agent. She did not tell that individual anything either. She also received ¢ call from an attorney that was trying to determine if she had spoken with anyone or was willing to speak to anyone She explained that she was receiving telephone calls from people whom she did not know and that she was uncomfortable telling them anything over the telephone. an unknown attorne One or two weeks later, GIUFFRE was using a cellular telephone belonging to her husband. She ner her husband could recall the telephone number but advised that the carrier was OPTUS telephone company. GIUFFRE reviewed a series of photographs of individuals and identified the following: | (Ld Page 3, number 2f | page «, nuanor 3,[ Jao J Page 1, number 2, LJ Page 2, number 1, Page 2, number Page 4, number Page 4, number 8, GIUFFRE advised that the following were familiar to her, but she could not recall their names or her association to them: be bic b6 b7c b6 bic GIUFFREQO1245

Case 18-2868, Document 283, 08/09/2019, 2628241, Page542 of 883 FD~302a (Rev. 05-08-10) 3LE-MM-108062 ContinvationotFD-3o20r Virginia L, Giuffre yon 03/17/2011 page 12 of 12 Page 1, number 4 Page 2, numbers 7 and 8 Page 3, number 8 Page 4, number 1 Page 5, numbers 5 and 8 The images reviewed by GIUFFRE were placed in a 1A envelope of the case file. When questioned about United States Customs and Border (CBP) Patrol records Januar record was her return to the United States of her entries into the United States, GIUFFRE advised that_her 2001 record was the return from her London, England trip The April 2001 CBP b6 b7c GIUFFRE could not recall her travel from March and May 2001 CPB records. GIUFFRE advised that her United States Passport was turned over to the United States Consulate in Sydney, Australia. On March 18, 2011, writer, sa___ anal 6 traveled to GIUFFRE's residence where she provided 20 photographs and her b7c ITM massage school certification. FD-S97 Receipts for Property were executed for the items and a copy was provided to GIUFFRE. It is noted that the receipts were dated based on the United States Eastern Standard Time Zone date. The photographs, certification and original FD-597s were placed ina 1A envelopes of case file. GTUFFREOO1246

EXHIBIT 32 (Filed Under Seal)

GIUFFRE003192

EXHIBIT 33 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page547 of 883 atfe, Weissing, Edwards, Fistos & Lehrman, P.L. December 30,2014 New York Presbyterian Hospital Weill Cornwell Medical Center Medlical Records 525 East 68 Street New York, NY 10065 RE: Request for MEDICAL RECORDS and BILLING Our Client/Your Patient . i Date of Birth Dates Requested Our File Number - mber 31, 2000 To Whom It May Concern: This is # follow up to our original December 1, 2014 request for medical records (a copy of same is attached far your convenience). Attached, please find a copy of the Refused/Retuned Notice for your convenience. Pursuant to same, please be advised that we would like ALL records from August 9, 1983 present. If that is too general/broad, please limit the search to January 1, 1998 to December 31, 2000. Please contact us if the reproduction costs exceed $50.00. Please contact us if you have any questions or wish to discuss this matter further. We look forward to your prompt compliance with this request. Very truly yours, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. AD Amy W. Dishowitz, Paralegal — For Bradley J. Edwards, Esq. BJE: awd “Enclosures Pe JAN 0 6 2015 __ BY: ow. 425 North Andrews Avenue, Suite 2, Fort Lauderdale, Florida 33304 954.524.2820 office 954.524.2822 fax GIUFFRE003258 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page548 of 883 armer, fe, Weissing, Edwards, Fistos & Lehrman, P.L. December 30, 2014 New York Presbyterian Hospital Weill Comwell Medical Center Medical Records 525 Bast 68 Street New York, NY 10065 RE: Request for MEDICAL RECORDS and BLING: Our Clleat/Your Patient 8 poi Date of Birth 2 Dates Requested Our File Number To Whom It May Concern: ‘This is a follow up to our original Dec is attached for your convenience). Attached, pl convenience. Pursvant to same, please be advi we woulags ‘present. If that is too general/broad, please limit the search to Jt wuaty Please contact us if the reproduction casts exceed $50. Please contact us if you have any questions or wish: _forward to your prompt compliance with this request. Very truly yours, ett FARMER, JAFFE, WEISSING, EDWARDS, FISTOS ‘a RIRMAN, AD Amy W. Dishowitz, Paralegal For Bradley J. Bdwards, Esq. BJE: awd Enclosures La JAN 0 6 2015 5: Cepentetieres 425 Nortti Andrews Avenue, Suite 2, Fort Lauderdale, Florida 33304 954.524.2820 office 954,524,282 fax fax = = tne GIUFFRE003259 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page549 of 883 I 2-2 21221 c2r accor NEWYORK-PRESBYTERIAN HOSPITAL New York Weill Corel! Me “Ee nna Biacinia L. a jumania DOGS aa a liana: Cice CiElevetion Cimmabiization C) Dressing Ci Respiratory Precautions C1C-Collar LD Security Walch = tr 91-08-2015 21:15:54 GIUFFRE003260 CONFIDENTIAL

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Case 18-2868, Document 283, 08/09/2019, 2628241, Page551 of 883 | ema cacey NewYork-Prespyrertan Hosprrar, New York Weil! Cornell Medical Center HATTA A j = euerGency ores: Continnatior hen ® ke ee 7 | es ne Bed —. Lt, 65D sod fandltirntss 2IB+ U8. fed hi ~ Rem | ext pele Pack gene ae es “ fs ot 2 B 3 — 2 EO Ratan of symp tiie Wrerton pore ‘ears oe feasacs i Pang ander fT A*A4 , tatey re Coftraisong Beg EM wg F and A efiemomgyan | om ae May Page 3 01-08-2015 21:18:54 GIUFFREO03262 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page552 of 883 ae EMERGENCY DEFT RECORD NewYork-Pressyrertan HospirsL New York Weill Cornell Medical Center Weve EMERGENCY NOTES, Continustion cm 2LQ ree-@ TtP Ge sraassts ise ce se oa 01-06-2015 21:16:54 GIUFFRE003263 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page553 of 883 a - A re NewYork-Prespyrerian Hosprra New York Weill Corel! Medical Center & IBGE EMERGENCY NURSING FLOW SHEET EMERGENCY DEPARTMENT IC NO PLATE, PRINT NAME: SEX AND MEDICAL REUDRD NO. ALLERGIEE Vio muRSE wires: =a 2 gail J J mm ada Pied! 25 algal ii omaemaae eA Te # “heen dank gu ind d {laa 2. e “4 L Fea of Usa as Eerie OY =f] al, i —Ceohnsed drak. orivintin tad - . | 7 ag hy Be emo We cla ad ae fit de pate ae se - Games Cl thie Hoo cus Cas - Rha end Omer + a Page 5 1-96-2018 21.1654 GIUFFRE003264

Case 18-2868, Document 283, 08/09/2019, 2628241, Page554 of 883 >< =: EMBAGENCY DEFT RECORD eee” | eee, tira: a e EMERGENCY NOTES, Continuation EMERGENCY DEPARTMENT a 5 Ala Canter athe spe A Lepahs [é = ai 2 ee by DINGOT1 Page 6 01-08-2015 21-16:54 GIUFFRE003265 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page555 of 883 ae NewVYork-PRESBYTERIAN HOSPITAL ~~ New York Weill Cornell Medical Center AD : PROGHESS | NOTES 310 (a7) Paga + 01.06.2015 21:17:03 GIUFFRE003266 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page556 of 883 DocType: LAB REPORTS New York, N-¥.10021 Laboratery CLIENT INFORMATION: EMOND, SIEPHEN D MD ‘525 Bast 68th Street New York N¥_106219000 Client#: 00000 - a NBW YORK HOSPTTAL 07/09/2002 Recvd Date! 67/09/2001 Rpt Date: 07/19/2001 1911 ‘Reevd Time: 1911 0. Coll Date: Goll Time FINAL NAME _ABBORMAL CB | _DNITS 8.2 +2 K/ub 4.23 20 M/ob 7-16.0 gia AUTOMATED DIFFERENTIAL NEUT § 7 45,0-75.0 8 LYMPR & 50.0 4 9-12.0 4 6.0-5.0 4 0.4 0,0-2.0 a 6.8 H 2.1-4.9 ‘K/uL Q.71 Z K/ub 0.6 o K/uL 0.0 0.0-0,3 K/ub 0.0 0 K/ab Page 4 01-08-2015 29:17:11 GIUFFRE003267 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page557 of 883 | pect Ae reer Page 2 01-06-2015 21:17:11 GIUEFRE003268 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page558 of 883 [DocType: LAB REPORTS Parient Name: ROBERTS, VIRGINIA NY 2 07/10/2001 0438 07/09/2001 ose Page 3 01-06-2015 21:17:11 GIUFFRE003269 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page559 of 883 Joc Type: LAB REPORTS CLIENT INFORMATION: Potient Name: BMOND, STEPHEN D MD 525 East 68th Street New York Ny. Med Ri Date 109210000 Reatill ent#: Recvd Date: 97/09/2601 Coll pate: 07/10/2001 Coll Time: 1911 DRAWN DATE _REASON BASIC METABOL PANE] 07/08/01 Entry Ei ro de: ed by OINSOIT Pagad 04-06-2015 21:17:11 GIUFFRE003270 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page560 of 883 CE 25 ==: Hast 68th Street, New York, N.¥, 10071 Desmond Burke, M.D., Laboratory Director CLIENT INFORMATION: EMOND, STEPBEN D MD 25 East 68th Street New York NY 100210000 Client#: 00000 NEW YORK HOSPITAL 07/08/2001 Reevd Date: 07/09/2001 Rpt Date: 07/10/2001 1855 Recvd Time: 1973 Apt Time: 0438 FINAL TEST NAME ABNORMAL NORMAL REZERENCE IC_URINALYSIS COLGR APPEARANCE PROTE 30+ BLOOD NEGATIVE NEGATIVE LUCOSE NEGATIVE NEGATIVE TRACE* © GRAVITY NITRATE NEGATIVE NEGATIVE (LEUROCYTE SSTER [NEGATIVE NEGATIVE 0-2 0-2 o-2 NEGATIVE NEGATIVE errent) 7B (09/08/2000 TRIS URINE HAS BEEN EXAMINED FOR WBC, RSC, CASTS, CRYSTALS AND EPITHELIAL CELLS. ANY OF THESE ELEMENTS NOT REPORTED WAS NOT F ‘ed by DINGOTT Pages 01-06-2015 21:17:11 GIUFFREO03271 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page561 of 883 Page 6 91-06-2015 21:17:11 GIUFFRE003272 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page562 of 883 VIRGINIA L. t_Name: ROBERTS, 07/09/2001 1915 Recvd Date Recvd Time CHEMISTRY TININE SODIUM _BOTASSIUM CHLOR ID: coz 210 ANION GAP ACTD CALCIUM 34 °K BILIRUBIN DIR 1 SIND CHOLESTEROL _MAGHESIUM aS ALT (03/27/1999 CHOLESTEROL ‘ed by DINGOT1 New k, N.¥.10021 Labe y. actor CLIENT INFORMATION: EMOND, STEPHEN D MD 68th e N¥_100210: o0000 YORK HOSP 07/09/2001 1925 NORMAL 20 Page 7 CONFIDENTIAL 07/10/2001 0438 ITS 29-105 mg/dL mg/dL mg/aL 33-147 mmol /1. 0-45 of 0-45 01-08-2015 21:17:11 GIUFERE003273

Case 18-2868, Document 283, 08/09/2019, 2628241, Page563 of 883 DocType: LAB REPORTS, QUTPATTENT REPORT ‘ed by DINGO Page 8 91-06-2016 21:17:11 GIUFFRE003274 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page564 of 883 ory CLIENT INFORMATION: Patient Names: ROBERTS, VIRGINIA L SMOND, STEPHEN D MD East 68th Street New York NY 10021000 Client#: 00000 NEW YORK HOSPITAL iS 07/09/2001 5 07/05/2003 1925 07/10/2001 0438 Geil Coll _ABNORMAL 176 of ALKALINE PHOS 76 30-110 D/L CORONARY RIS! OL 30 < mg/dL DESIRABL 0 mg/d. BORDERLINE HIGH: 200-239 mg/sl. IGH! AQ mg/dL Pages 10S 2015 21474 GIUFFRE003275 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page565 of 883 ‘Type: LAB REPORTS Page 10° 01-06-2015 21:17:11 GIUFFREO03276 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page566 of 883 GLIENT INFORMATION: Patient Name: ROBERTS, VIRGINIA L. EMOND, STEPHEN D MO 525 East 68th Street ce c 00000 ~ YORK ROSPITAL 07/09/2001 Recvd Date: 07/08/2001 Apt Date: 07/10/2001 1934 Recvd Timer 1934 Rpt Time: 0438 FINAL = NORMAL BLOOD GRO! AND TYPE _ANTIBODY EN AND WORKUP PROCEDURE ABSC INT (07/05/2001 1934 NOTIMMZD CONFIDENTIAL ee ed by DINGO age 11 ov-os 2015 21317214 GIUFFRE003277

Case 18-2868, Document 283, 08/09/2019, 2628241, Page567 of 883 Page: 1 END OF CHART Page 12 01-06-2015 21:17:11 (GIUFERE003278 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page568 of 883 DocType: LAB RESORTS cast 6&th Street, New York, N. jasmond Burke, M.D., Laboratory 0 CLIENT INFORMATION: EMOND, STEPHEN D MD 525 Bast 68th Street New York Ny 10 Client#: 00000 Coll Date: Coll Tima; 0941 TEST _NAME CHLAMYDIA-GC CHLA SWAB SOURC _CHLA SWAB by DINGOT 07/09/2001 Recvd Dates NEW Y RK_SOSETTAL 07/10/2002 Recvd Timer 0941 Ret Dater 07/11 Rpt Time: 52 FINAL NORMAL UNITS SLAMYDTA BY AMPLIFICATION GERVIX NEGATIVE ATI CERVIX NEGATIVE NEGATIVE Page 13 D1-08-2015 21:17:11 GIUFFRE003279 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page569 of 883 joc Type: LAB REPORTS 525 Bast 68th Street, New York, N.¥-10021 M. Desmond Burke, M.D., Laboratory CLIENT INFORMATION ROBERTS, VIRGINIA L. BMOND, STEPHEN 0 MD 525 East 68th Street New Yor! Ry 400210000 Client#: oo00 ain WYORK-HOSP ITAL 07/09/2001 Recvd Date: 97/10/2001 07/11/2001 1929 Recvd Timer 0941 0452 REFERENCE ONITS TEST NAME ABNORMAL _GENTTAL : COLTURE-SCREEN GENITAL CULTURE OO ~~ COLLECTED: 07/09/01 1929 RECEIVED: 07/10/01 0941 TED: 07/10/01 0941 07/10/2001 LACTOSAC: MODERATE EPITHELIAL CELLS _MODE: _SEEN Paget END OF ‘ad by DINDOTT GIUFFRE003280 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page570 of 883 DocTypa: LAB REPORTS: 6Rth Street, New York, oo2i M. Desmond Burke, M.D., Laboratory Director CLIENT INFORMATION: EMOND, STEPHEN D MD 525 Hast 68th Street York N¥ 100210000 Client#:__00000 har, __NEW YORK HOSPITAL Date 07/09/2 Recvd Date: 07/10/2001 Rpt Dater 07/12/2001 Time: 192: Recvd Time: _0941 Ret Time: 0532 AME NORMAL REFERENCE _UNITS GENITAL | CULTDRE-SCREEN 7/09/01 1929 07/10/01 0941 07/10/01 0941 07/10/2002 2342 CONSISTENT WITH LACTOBACILLI 07/11/2001 2 MODERATE GRAM POSITIVE BACILLI CONSTSTENT WITH. “LACTOBRC: Bi FURTHER EVALUATION ed by DINGOT 01-06-2015 21:17:11 GIUFFRE003281 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page571 of 883 by DINGO Page 16 01-08-2015 21.1751 GIUFFRE003282 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page572 of 883 ee PAR REPORTS STEP! st 68th St. _NY 100210000 0000 HOSP Rpt Oate: 07/12/2001 Coll Date: 07/09/2001 Recvd Date: _07/10/2001 Soll Time: 1655 1102 Rpt Time: 0532 FINAL ~ TEST NAME _ABNORMAL NORMAL REFERENCE = _UNITS STONY 01 FINAL REPORT 07/11/2901 NO GROWTH (<1,000 CrU/ML) rd 01-08-2015 21:17:11 GIUFFRE003283 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page573 of 883 Doc Type: LAB REPORTS: 525 st 68th Street, oratory Director M. Desmond Burke, M.D.CLIENT INFORMATION: VIRGINIZ L_ EMOND, STEPHEN D MD 525 Bast 68th street New York Wy 100210000 Clieat#: 00009 NEW YORK HOSPTIAL 07/09/2003 Recvd Date: 07/10/2002 Rpt Date: 07/13/2001 1929 Reovd Time: 0941 Rpt Ti 0s 7 PARTIAL REFERENCE UNITS #1 01-4 STAINS & PREPS 07/10/2001 1 WITH LACTOBACILLI MOUERATE EPITHELIAL CELLS (ODERATE WSC SERN 07/21/2001 }ODERATE GRAM POSITIVE BACILLI CONSISTENT WITH COL’ HEL? FOR MODERATE GRAM POSITIV® BACILLI CONSISTENT WITH LACTOBACILLI G HBLD FOR FURTHER EVALUATION CULTURE BI ved by DINSOT 01-06-2015 21:17:11 GIUFFRE003284 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page574 of 883 2. si pao Page 18 proszorszu791 GIUFFRE003285 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page575 of 883 68th Street, New York, N.Y.10021 i Burke, + Laboratory Director SLIENT INFORMATION: Patient Name: ROBERTS, VIRGINIA L. EMOND, STEPHEN OD MD 525 East $8th Street New York 100210000 Client#: 00000 NEW YORK HOSPITAL Coll Date: 07/09/2001 Recvd Date 07/10/2001 Rpt Date: 07/14/2001 Coll Time: 1929 Recvd Time: 0942 Rpt Ti 04 FINAL JEST NAME ABNORMAL NORMAL REFERENCE UNITS COLLECTB GENITAL RECEIVED: SQURC! FREETEXT £0! 07/10/02 0941 & PREDS 97/10/2001 1342 MANY GRAM POSITIVE BACILLI CONSISTENT WITH LACTOBACILLI MODERATE EPITHELIAL CELLS “INARY REPORT 07/11/2081 1037 _MODERATE GRAM POSITIVE BACILLI CONSISTENT WITH TOBACILLI FURTHER EVA; ITIV CONSISTE! _MCDERATE GRAM OBA LLI LACTC ELD FOR FURTHER EVALUATION SULTORE BEING EB GRAM POSITIVE BACILLI CONSTSTRN> WIT Page 20 04-06-2015 21:17:11 CONFIDENTIAL GIUFFREO03286

Case 18-2868, Document 283, 08/09/2019, 2628241, Page576 of 883 DocType: LAB REPORTS LACTOBACILLI NO NI ‘a ee ‘ad by DINSOTt Page 21 01-06-2015 21:17:11 GIUFFRE003287 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page577 of 883 a. eee NewYork-PRESBYTERIAN HosprraL New York Weill Cornell Medical Center ee @ DIAGNOSTIC PROCEDURE ORDER FORM. 1) MDINP: teutenio, tants abe gertrpee be. tng. spprootae . Spyies Bie Rear aia 2) Wan Cien:_ Fartaoumto appropriate atten nese he flaring: to Pd, Tine, vet 9 Tent Armes (Gano Gamwanc prota cots re yma tare wi ba done, “VaR Giet: Wa re Dale ead Tare priest i ni ot Feo surat proede bx ping a ake a tc \ecky ore and etan on devant ins. 1% fyraw Rutea) Oo rot tov. Phare a i recut eam, Cvs yo copy to * WAGINIA L. CLINICAL DATA ID corgert Obie’, ; “Crresatechueyae ire * GJ Roapiratory Precautions o rasp nciiedy £2 1G Wiouncistin Precautions Giocal Htory.. UF Pregnancy Page 1 11-06-2015 211722 GIUFFRE003288 CONFIDENTIAL,

Case 18-2868, Document 283, 08/09/2019, 2628241, Page578 of 883 a arn Many af the Radiology examinations require that the patient be prepared for the procedure that js being ‘ordered, We have inolucdact a brief description of the most common procedures, HOWEVER, ail exams. gre Included In the Manual of Laboratory, X-Ray, and Special Procedures and are containad in the Ancillary Services section inthis roanual, The procedure in the manual contains a brief description, indications, cantramndications, pationt praps and special instructions, * Please call Pediatric Radiology x62554 for modified preps for peviatvic cases. NOTE: SEQUENCING of oxeyne is crftioal when ordering multiple exame. Barium studies generally should be done efter other dlagnostis procedures. Sse Manual for more complete Information or discuss with Radiologist so as not to delay patient care. Gl. Series Prep: N-P.O. from Midnight day before study, Suspend all medication except essential, ‘should be discontinued 24 hours before procedure. . Aftercare: mild laxative and fluids. Barium Enema Prep: Clear fluids 24 hours prior to study, 60 mi magnesium citrate by mouth at § PM day before study. 4 bleacody! tablets (Huicole) by mouth at 10 PM the night before exam, 4 bisacodyl suppasitary moming of exam. Nothing by mouth after midnight. LLP. (intravenous Pyelogram) Prep: 10 ounces of magnesium olirate at 6 PM evening before exam, Nothing by mouth after midnight. G.T. {Head & Body} Prep: Ciger fluids 4 hours prior to study. Contrast injection requires the patient be NPO tor et least 4 hours prlor to study. Pailents must be cooperative and abte fo hold theif breath for Body CT's. Aftercare: Patients recelving contrast should be hydrated, MRI CONTRAINDICATIONS: (}) Patients over 300 Ibs. @) Patlents with PACEMAKERS CANNOT BE DONE, &) Pailents wilh metal surgical clips and other prosthetic devices should consult wilh the Radiologist batore ordering MRt's. @) Claustrophobie and inability to remaln still are atso contraindication and sedation may bs required, SEE MANUAL FOR COMPLETE DETAILS. Sonograms PELVIC/OBSTETRICAL: Requires full bladder, Patient should crink water and maintain a full bladder, ABDOMINAL/AORTIC RENAL: Clear liquid diet for 24 hours prior fo exam. Nuclear Medicine - SPECIAL CONSIDERATIONS: 1. To con an. adage watt, Patient must be able to le quietly for up to one hour in supine acess he tient jap, and a shidios roquiting sedation, the patient must be fasiing for a of four hours prior to test. 3. Radloactive iodine is used for thyroid uptake and scanning. Do not schadule test if eny of the following druge or foods have been ingested within minimal tims limits indicated: lodine Compound {Lugol's Potassium todids, Kelp); 1-2 waeks ‘Seafood, Ovaltine, vitamin pills, Orande, Combid: 3-6 days Diodrast, Hypsque (.2., IVP end arteriograme): 1-2 weeks Priodax. Telepaque, etc. (Le. gallbleer cari} serige): 3-6 months Lpiodel (Le., bronchograms): at least Antishyrold cruge (Le., Fronnnart “par 7 days. If In preparation for urgent sadioiodina treatment, const Thyroid substance (i... located fora Th Thyroxine); 4 weaks Triiodathyronine (Cyiomel: 10-12 days. if special ciroumsiancas require evaluation. cenpita ths. above: Indications {contraindications) Nuclear Medicina physiclan consultation advised. 10.2015 21:17:22 fed by DINGO 1 Page 2 CONFIDENTIAL nee.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page579 of 883 ae... ORDERS NewYorx-PRespyrertan Hosprrat New York Weill Corneil Medical Center en e PHYSICIAN'S ORDERS EMERGENCY DEPARTMENT (01-06-2015 21:17:22, ad GIUFFREO03290 CONFIDENTIAL

EXHIBIT 34 (Filed Under Seal)

ak earn oa ae SEB BSCUMENE 285, UES LOT SBE AP, Bh gese1 of 883 From: Jenna Sent: Thur 2/17/2011 9:44:51 PM Importance: Normai Subject: RE: Received: Thur 2/17/2011 9:44:51 PM Not a problem but we have to continue __ rest of the interview at my house being thal the children are not feefing well, you have got th only document s pertaining to my case. Look forward to seeing you this afternoon . Jenna From: Sharon.Churcher@maitonsunday.co.uk Sent: Friday, 18 February 2011 7:25 AM To: Virginia Giuffre Hi there Have been up ali night writing. Won't have an opinion from our fawyer on how much can be published untii London wakes up. The lawyers wanted internal FBI documents but | think the Justice Dept etter is all you have from the feds??? Anyway can | give you a cail early afternoon? Maybe have a late lunch? Ss This e-mail and any attached files are intended for the named addressee only. It contains information, which may be confidential and legaily privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or use it, or disclose it to anyone ese. If you received it in error please notify the sender immediately and then dele! it from your system. Please be advised that the views and opinions expressed in this e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. We make every effort to keep our network free from viruses. However, you do need to check this e-mail and any attachments to it for viruses as we can take no responsibility for any computer vir which may be transferred by way of this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully carry out to prevent abuse of these facilities. Associated Newspapers Lid. Registered Office: Northctiffe House, 2 Derry St, Kensington, London, W8 5TT. Registered No 84121 England. CONFIDENTIAL GTUFFRE003678.

EXHIBIT 35 (Filed Under Seal)

Pear ert Te UR BSauMeNt oes UE BOL SUSE AP. Bhgesss of 883 From: Jenna Sent: Sun 2/13/2011 4:29:38 AM Importance: Normal Subject: RE: Agreements etc Received: Sun 2/13/2011 4:29:38 AM Hi Sharon, my address ii .:: me back for the directions from gosford and my hubby will lead the w: from there. -----Original Message----From: Sharon.Churcher@mailonsunday.co.uk Sent: Saturday, 12 February 2011 2:10 AM To: Virginia Giuffre Subject: Agreements etc Hi there, Thank you again for your email. We totally understand your concerns. Please don't worry about anything. Whatever happens, we are bound by confidentiality unless you consent to an article in a formal contract signed by you. Since | will be in the air by the time you wake up, can you email our Assistant Editor Sian James -- sian.,james@mailonsunday.co.uk -- your lawyer's information please? Sian will arrange to get him whatever assurances he requires. We really want to make this work and of course we want to protect you. We'll be really grateful if your lawyer will provide us his cell phone number as we'd like to sort this all out asap. Meaning we would like to talk to him Saturday EST. | will give you a call from Sydney. Fingers crossed we get over this last hurdle! Best regards, Sharon This e-mail and any attached files are intended for the named addressee only. It contains information, which may be confidential and legally privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or use it, or disclose it to anyone else. If you received it in error please notify the sender immediately and then delet it from your system. Please be advised that the views and opinions expressed in this e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. We make every effort to keep our network free from viruses. However, you do need to check this e-mail and any attachments to it for viruses as we can take no responsibility for any computer vir which may be transferred by way of this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully carry out to prevent abuse of these facilities. Associated Newspapers Ltd. Registered Office: Northcliffe House, 2 Derry St, Kensington, London, W8 5TT. Registered No 84121 England. CONFIDENTIAL GIUFFRE003690

EXHIBIT 36 (Filed Under Seal)

Pe ee er a te UR BSauMe Nt oes UE BOTe SUIE EP. Bh geses of 883 From: Jenna Sent: Fri 2/25/2011 10:12:25 PM Importance: Normal Subject: RE: Re: Received: Fri 2/25/2011 10:12:25 PM The flight logs didn't come through properly,could you please resend them? Thanks- Jenna -----Original Message----From: Sharon.Churcher@mailonsunday.co.uk Sent: Saturday, 26 February 2011 7:56 AM To: Virginia Giuffre Subject: Re: Can u look at the flight logs | just sent and see if any ring a bell re Virgin Is/Andrew orgy please? s x0 > ene aie sicae - ncn = pass esecnsns |Sharon Churcher Preeereecscon acace ies - = a soci os |25/02/2011 20:54 GMT Soa se spe eres prneetcehen et ia = pecs as one Hi shazza, 1am hoping it all goes well this a.m, please let me know when you know something. As far as other publications go, | am happy for your company to decide as long as | am not made out to be a vixen...you know my taste...he..he..! Talk to you soon buddy! =) Jenna -----Original Message----From: Sharon.Churcher@mailonsunday.co.uk Sent: Saturday, 26 February 2011 6:46 AM To: Virginia Giuffre So far it is all looking good. Waiting for a comment from Andrew. Will let you know as soon as we get it. Are there any publications to whom you do not want the piece syndicated? (You get 50 per cent of the proceeds). CONFIDENTIAL GIUFFRE003731

oe Case 18-2868, Document 283, 08/09/2019, 2628241, Page586 of 883 This e-mail and any attached files are intended for the named addressee only. It contains information, which may be confidential and legally privileged and also protected by copyright. Uniess you are the named addressee (or authorised to receive for the addressee) you may not copy or use it, or disclose it to anyone else. If you received it in error please notify the sender immediately and then delete it from your system. Please be advised that the views and opinions expressed in this e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. We make every effort to keep our network free from viruses. However, you do need to check this e-mail and any attachments to it for viruses as we can take no responsibility for any computer virus which may be transferred by way of this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully carry out to prevent abuse of these facilities. Associated Newspapers Ltd. Registered Office: Northctiffe House, 2 Derry St, Kensington, London, W8 5TT. Registered No 84121 Engtand. This email has been scanned by the MessageLabs Email Security System. For more information please visit htto-/Avww.messagelabs.com/email This e-mail and any attached files are intended for the named addressee only. It contains information, which may be confidential and legaily privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for ihe addressee) you may not copy or use it, or disclose it to anyone efse. If you received it in error please notify the sender immediately and then dele’ it from your system. Please be advised that the views and opinions expressed in this e-mail may not reftect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. We make every effort to keep our network free from viruses. However, you do need to check this e-mail and any attachments to it for viruses as we can take no responsibility for any computer vir which may be transferred by way of this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully carry out te prevent abuse of these facilities. Associated Newspapers Ltd. Registered Office: Northefiffe House, 2 Derry St, Kensington, London, W8 5TT. Registered No 84121 England CONFIDENTIAL, GTUFFRE003732

EXHIBIT 37 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page588 of 883 MENT OF STATE SPORT [_] REGISTRATION ‘ lefe|ssl | iii | | jot \ | l | | | | J a 4 4. PLACE OF BIRTH is aH eNTY We ae | GIUFFRE004721

EXHIBIT 38 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page590 of 883 ASE HISTORY/ASSESSMENT PLAN SINGLE (Not in a relationship} SINGLE (Is a relationship) - NAME, AGE Fiew long Description of partner DF VACTO RELATIONSHIP « NAME. AGE How long, Deserinéon of partner _ “ CHILDREN OF RELATIONSHIP: Wore * AGE; Mex, MARRIED: Name How tong OV 4 _ Description of spouse s S — Description of shared relationship: PREVIOUS MARRIAGES/SIGNIFICANT RELATIONSHIPS 1. NAME ___ HOW LONG Reason relationship Saished oe We, CHILDREN: ey REFERRAL saURCE Vevagks GIUFFRE005433 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page591 of 883 TAMILY HISTORY: MOTHER: AGE HEALTH MARITAL STATUS: MARRIED: SEPARATED: DIVO! New panter, Relationship with Mother: Self DESCRIPTION OF MOTHER. CARINGILOVING — NURTURING —-- POSITIVE -—— SUPPORTIVE. SENSITIVE DOMINANT NEGATIVE CONTROLLING —- MANIPULATIVE —- DEPENDENT --— SUBSTANCE ABUSE ENVIRONMENTAL. /GENERATIONAL FACTORS:——___——— DESCRIPTION OF RELATIONSHIP: \ {DISTANT ——NON EXISTENT —— CLOSE ¥ERY CLOSE — STRAINED - 57 $a e/a FATHER: © AGE—=-& HEALTH MARITAL STATUS: MARRIED — SEPARATED — DIVORCED — REMARRIED ——— NEW PARTNER PELATIONSSDP ¥ITH SELF —<$A wuqou IURING-—-POST) = SENSITIVE--—-DOMINANT CONTROLLING MANTPULATIVE—DEPENDENT-—SUBSTANCE ABUSE ————--- ENVIRONMENTALIGENERA TIONAL FACTORS: mem DESCAMTION OF RELATIONSHIP: CLOSE—VERY CLOSE-—STRAINED ~~ 3 wee DISTANT.—NON EXISTENT—- feseees STBLINGS — BIOLOGICAL/STES/BLENDED yy Sos Sh > Ae, QS RBROTHERS So a SISTERS Qo & b> Downs %> Bue hoge Single Marriedide facto/Separated/ Divocced/Children RELATIONSIMP: VERY CLOSE --—- CLOSE ----.--DISTANT——NON EXISTENTDESCRIPTION OF FAMILY RELATIONSHIP: VERY CLOSE CLOSE —-——-DISTANT-— GIUFFRE005434 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page592 of 883 CRILDROOD/ADOLESCENT HISTORY . Major ilinessen'opentions __ VU ab OS Savors = DESCRIPTION OF SELF ASA CHILD- BRIGHT.-—HASPY——-OUTGOING—LEADER— COMPLIANT —-LONFR UNHAPPY —HIGH ACHIEVER TROUBLED ———— DESCRIPTION OF SELF AS A TEENAGER: BRIGHT..--HAPPY—OUTGOING—LEADER— COMPLIANT—LONER-—--UNHAPPY----HIGH ACLILEVER-—-TROUBLED-———-— RELATIONSHIP WITH PLERS/) EACRERS EDUCATIONAL HISTORY Scheol leaving year HSC Tertiany studien University ( ) EME. 38 Company == Length of time MEDICAL & PSYCROLOGICAL HISTORY (ADULT) Significant ilnesses/operations/trentment “OW wi \.) vt Rares! Mi sexes PRESENT GENERAL HEALTH Cote ke MEDICATION — Substance abuse: Alechol fica Nicotine _ Other drug taking Nawiwods Vo bye hyd PREGNANCY HISTORY: Number of pregnancies J) A oe v Miscarriages % Tecininations Ses (Effecd reasonable! bad sti! affected by decision) ANXIETIES/CONCERNSFEARS GIUFFRE005435 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page593 of 883 PHOBIAS DESCRIPTION OF PRESENT PROBLEM __ TIME OF ONSET’/SYMPTOMS ___ SLEEP PATTERNS: —Good/falls asleco easily/ reasonable’pocr/dilliculty staying asleep! Awakens through aight! imable 19 wo tick t9 sleep AWAKENS FEBLING: Gooulitired/down/ Morning person Night person Awarenest of mental diserdes in family unit/origin SS eee ee MEMORY: Good/teascnable/peor— SUICIDAL THOUGHTS: Thoughts only/sericus/contemplation Attempts and manneintervention EPILEPSY - YES/NO RELAXATION/NTERESTS (Hobbies recreational interests) Walkingicooking/theatre/musicicinema/sportvbush walking/cealliwuedwork Shared with parmner Purpose menting xe We MOOS Nu (Ces. Rolewine. ec tAut ind /Con! Hal /Exsa /Exp/Resp.se!f'Ks.-non-j-c/w.dem.exp.(fgv unend J Siminished in Feclaiming if eee ees series . Acknowledged vaiidation—secognition - —ws. ~ not - if.) HYPNOSIS SUGGESTED -Explanation!description of Hypnosis!Pamphies ......... HYPNOTIC FORMAT; ,._.. Relaxation Fesponse/counting 1-20/Ideomotur/eye catelepsy/ HOW RECEPTIVE 42 2 34 8910 APPROPRIATE FOR FUTURE WORX ——-.—————— TRENTNENT PLAN / FOCUS: S wheuas = tans: WN ENN eCersh Ssiests wey At eA ies SES we asec SAO S gnc eatin Baggett Anes or eecht x \ GIUFFRE005436 CONFIDENTIAL

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Case 18-2868, Document 283, 08/09/2019, 2628241, Page595 of 883 GIUFFRE005438 CONFIDENTIAL

EXHIBIT 39 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page597 of 883 PALM BEACH “POLICE DEPARTMENT 7/25/06 . Incident Report 8:47:53 1-05-000368 Case No. . - 2 : DO NOT RELEASE SPECIAL NOTES. Occur From Dat Occur To Date 1/27/05 00900 Report Date Day Of Week . Thursday Common/Locatio: 358 EL BRILLO wy CLE os . PALM BEACH, FL RESIDENCE-SINGLE FAMILY DETECTIVE BUREAU Map Reference : SEXUAL BATTERY Report Officer : OPEN / ACTIVE Case Status Dt : TRYLCH, JEFFREY 3/14/05 OREGERO, LAURA 4/06/05 Location Type 2 Beat Assignment: Dept Class .. Case Status . Supervisory Dt. Eatry Date Names? .... 3: Property? . : Vehicles? . z Offenses? . .: Narrative? . .: Related Cases? : eeteevert VEHICLE INFORMATION # Case number . : 1-05-000368 Category... : State Veh Type : > ire ee ee ee Make 2... 2s 38 Model .. : Permit Number Model Name . . : EYL us, de F Color - Top . Color - Bottom : License # ‘ WEN) 3. ee pe Stolen value . Disposition .: Insured - KS Insured by . . Keys incar .: Vehicle locked Lein holder Date recovered : 0/00/00 Recovery value : Street number : BLE See coy, Fi tF Recovery code : NCIC number . : Be On Look Out?: SRKRREEWS BE RB OR REPORTING INFO Case Number . : 1-05-000368 Name. . i: Street Number : City . Birth Date/Age Employer? ..: Occupation Oper Lic No. . : Home Phone No. ;: RAGE it te le er TE Sex .... . : Female Height ... Oo Other Phone Nbr: Weight |. . seekerteneeexe SUS PECT/ARRESTEE case Number 1-05-000368 Street Number FL 334121460 fe : ROYAL PALM BEACH Dther Phone Nbr: sex. . + Female “inimum Weight 20 Minimum He ight Maximum Height city . 4. Birth Date Maximum Age = Employer? . t Occupation £ oper Lic No. i ee Home Phone No. : Race . .- 3 1/27/05 3/14/05 10 0000 1600 PAGAN, MICHELE 3/14/05 LIRR RE EEK ~ #1 tee RRRE RH White oO INFORMATION Prompt valid in: ROBSON, HALEY 18 White oO oO # 1 ** GIUFFRE005614 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page598 of 883 7/25/06 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 2 Case No. . Maximum Weight Aliases? .. Hair Color ~ Hair Style . Glasses Facial Hair Teeth . .. Hat .- s+ = Shirt «5+ % Shoes Body Marks #2 Body Marks #4 Arrest Case NoSee RREEERE EERE Case Number Street Number City o Birth Date . Employer? Oper Lic No. + 1-05-000368 0 Misc. IDF .. MO/Crime Spec? Hair Length Eye Color . Complexion . Budd Sa ki Speech... 2.28 Coat. 2. 2 ee & Pants . : Body Marks 1 é Body Marks #3 2 Status . . : Additional beR? : SUSPECT/ARRESTEE INFO 1-05-000368 Prompt valid in: : 358 EL BRILLO Wy :_ PALM BEACH, FL 000033480 pose ner Maximum age Occupation . Home Phone No. other Phone Nbr: 561/000-0000 Race Sex . : Female Minimum Height Minimum Weight zt Maximum Height Q Misc. ID# Maximum Weight : Aliases? .. Hair Color . Hair Style Glasses : Facial Hair Teeth ... Hat . Shirt shoes Body Marks #2" Body Marks #4 Arrest Case No.: RERKEERER RRR Case Number . Street Number CLS «2 ee Birth Date . Employer? Oper Lic No. 1-05-000368 + 358 EL BRILLO wy MO/Crime Spec? Hair Length Eye Color Complexion . Build .. Speech . Coat... Pants . Body Marks #1 Body Marks #3 Stakua.. s+, 2 : Additional UCR?: SUSPECT/ARRESTEE INFO Prompt valid in: : PALM BEACH, FL 000033480 =a Maximum Age Other Phone Nbr: Sex . 4 . Minimum Weight Maximum Weight Aliases? . Hair Color . . Hair Style : Male : 0 oO Occupation . . Home Phone No. Race . Minimum Height Maximum Height Misc. ID# ., MO/Crime Spec? Hair Length Eye Color : 0 (Continued) STILL SUSPECT RMATION- €2 +#* KELLEN, SARAH LYNNELLE 7 25 PERSONAL ASST/EPSTEIN 561/000-9000 White 0 0 STILL SUSPECT RMATIONEPSTEIN, JEFFREY #3 +e : 52 | : White Oo GIUFFRE005615 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page599 of 883 ‘Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 68:47:53 Incident Report Case No, - . . : 1-05-000368 (Continued) | Glasses . 8 Complexion . . : 1 Facial Hair . : Buligiy yc md Teeth, . - wis Bpeeeh.. <4 «3 | a a er | Ome 45 Tes WS asst Shirt .. . oF PATIGG ve, 8: iF ym S Shoes .. 3 Body Marks #1 : Body Marks #3: Status... . : STILL SUSPECT Additional UCR?: Body Marks #2. Body Marks #4 : Arrest Case No.: Shee kA YT Case Number. : Prompt valid in: Street Number : cTIM INFORMATION - #1 ##kteeeeeeHeeKeEEHne ~05-000368 City ... . Birth Date/age Employer? ..: Occupation . . Oper Lic No. .: Race... - : White Home Phone No, Sex - + + - s 2 WALGHE. sos 's) o58 Be On Look Out Victim Type . Residency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment Phys Last Name : Height . . - . Misc. ID# . . Other Phone Nb JUVENILE Residency Type File Charges . Victim Sobriet Injury Type 1 Hospital ID . Phys First Name: eekheeeeeeeeeek VICTIM INFORMATION - # 2 #4#keHbERHERHE EERE Case Number s 1-05- “000368 Prompt valid in: Street Number : CLEy a. <4 . + PALM BEACH, FL 000033480 Birth Date/Age : 2: Employer? ..: Occupation . . : Oper Lic No... : Home Phone No. : 561/000-0000 Race... . ., : White Sex...» » « ¥ Female Height ....: 0 Weight ....: 0 Mise. IDF. .: Be On Look Out?: Other Phone Nbr: 561/000-0000 ADULT Residency Type : Victim Type .: Residency Sts : File Charges . : Can Identify . : Victim Sobriety: Injury Extent : Injury Type 1 Injury Type 2 : Hospital Ip . Med Treatment : Phys First Name: Phys Last Name Fekeeeeteeeeee VICTIM INFORMATION - AHKKKEREKKEH ERE * cage thabek ene ans seoHaes Deeait. valid =a Street Number CAG 5. a) wh te : , FL 000033480 Birth Date/Age 3 16 Employer? .. GIUFFRE005616 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page600 of 883 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Case No... . 1-05-000368 Occupation. . Home Phone No, Bek va ew 561/000-0000 Female Weight... 0 Be On Look Out?: Victim Type JUVENILE Residency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment : Phys Last Name : kehehekeeeeeee VICTIM Case Number : 1-05-000368 Street Number : City iv. : Birth Date/Age En” Occupation . .: Home Phone No. ; 561/000-0000 Sex , .... . 3 Female Weight . . a £0 Be On Look Out?: Victim Type . : JUVENILE Residency Sts : Can Identify . Injury Extent : Injury Type 2 : Med Treatment : Phys Last Name : FRRKRASHREEEEA VICTIM Case Number . : 1-05-000368 Street Number =: CIEW ss 2 f Birth pate/Age : 18 Occupation. .: Home Phone No. : 561/000-0000 Sex ,.... + Female Weight ....:0 Be On Look Out?: ADULT Victim Type . Residency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment Phys Last Name : etethhkeeekeeee VICTIM Case Number . =: 1-05-000368 Prompt valid in: INFORMATION Oper Lic No. . Race... -: Height .. 2 44 Misc. ID# . .: Other Phone Nb Residency Type Pile Charges . : Victim Sobriet: Injury Type 1 Hospital ID Phys First Nam INPORMATION Prompt valid in: PALM BEACH, FL 000033480 Employer? .. Oper Lic No. . Race... + Height... i iva Misc. ID# .. Other Phone Nbr Residency Type File Charges Victim Sobriety: Injury Type 1 : Hospital ID .: Phys First Name: Prompt valid FL 000033480 Employer? ..: Oper Lic No. . =: Race . we a « Height. «+ + % Misc. IDE . Other Phone Nbr: Residency Type : File Charges . : victim Sobriety: Injury Type 1: Hospital ID .: Phys First Name: INFORMATION 561/000-0000 £ ’ keke REA AE EE RE White 0 561/000-0000 White 0 HERRERA EAA LEELA EY 561/000-0000 HOG RRR KRE RARE RRR EE GIUFFRE005617 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page601 of 883 PALM BEACH POLICE DEPARTMENT Page: Date: 7/25/06 Incident Report Tim 8:47:53 Case No. ... 1-05-000368 (Continued) Street Number Chey’ PALM BEACH, FL 000033480 Birth pate/Age 6 Employer? Occupation .. : Oper Lic No. Home Phone No. : 561/000-0000 Race... . + White i on ee : Female Height || 11:0 Weight a Misc. IDF ..: Be On Look out?: Other Phone Nbr; 561/000-0000 Victim Type . : JUVENILE Residency Type Residency sts : Pile Charges . Can Identify . Victim Sobriety: Injury Extent Injury Type 1: injury Type 2 Hospital ID Med Treatment Phys First Name: Phys Last Name KeaAREEEAREERE VICTIM INFORMATION - KAKEKAE MRE RE KRESS Case Number. 1-05-000368 —e_ = = Street Number : city .. :; PALM BEACH, FL 000033480 Birth Date/Age : a” Employer? Occupation. .: Oper Lic No. : Home Phone No. ; 561/000-0000 RAGE ye wor: os 3 mite Sex + sos « = + Female Height t Weight ©. 2 : 0 Misc. ID# .. Be On Look out?: Other Phone Nor: 561/000-0000 Victim Type Residency Type : Residency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment : Phys Last Name : Se RER REAR OY zaseé Number 3treet Number sity” eee. : JUVENILE cTiImMm -05-000368 File Charges Victim Sobriety: Injury Type 1 Hospital ID Phys First Name: INFORMATION - $.Q +4etteeneeeenneeeene Prompt valid in: FL 000033480 3eths pate/Age Employer? Jecupation . . Oper Lic No. : jome Phone No. 561/000-0000 Race. ... . : White FE a at ae, 1S Female Height ....:0 feight. » 6. 0 Misc. ID# ..;: je On Look out Other Phone Nbr: 561/000-0000 tictim Type JUVENILE. Residency Type : tesidency Sts tan Identify . njury Extent njury Type 2 ted Treatment hys Last Name KeeKAHAREAAEE VICTIM File Charges . : Victim Sobriety: Injury Type 1 Hospital ID Phys First Name: INFORMATION | # 9 #RHEKHEHHREHERRERERE GIUFFRE005618 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page602 of 883 PALM BEACH POLICE DEPARTMENT 8:47:53 Incident Report Program: CMS301L Case No. .. - : 1-05-000368 Case Number . : 1-05-000368 Prompt valid in: Street Number. : City . . + PALM BEACH, FL 000033480 Birth Date/Age : L7 Employer? ..: Occupation - z Oper Lic No. . : Home Phone No. : 561/000-0000 Race... : : White BOX wee >» : Female Height ....:0 Weight ....: 0 Misc. ID# .. Be On Look Out?: Other Phone Nor: 561/000-0000 Victim Type . : JUVENILE Residency Type : Residency Sts : Pile Charges. : Can Identify . : Victim Sobriety: Injury Extent : Injury Type 1 : Injury Type 2 : Hospital ID 3 Med Treatment : Phys First Name: Phys Last Name : keeEARESEREEARR VICTIM INFORMATION - # 10 *eeeRKKERERREAERR RE Case Number . : 1-05-000363 Prompt valid in: Street Number : Clty o> a PALM BEACH, FI 000033480 Birth Date/Age 17 Employer? .. : Occupation . . ¢: Oper Lic No. . : Home Phone No. : 561/000-0000 Race . . + + + White BO Sse se ce Female Height cseie oe 0 Weight .. .- oO Misc. IDF ..3: Be On Look out Other Phone Nb: 561/000-0000 Victim Type . : JUVENILE Residency Type File Charges . Victim Sobriety: Injury Type 1 Hospital ID . Phys First Nam Residency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment Phys Last Name RRKKAREREREERE VICTIM INFORMATI HLL RaRRR RRR REE EEE Case Number . : 1-05-000368 Prompt vali Street Number : city ee FL 000033480 Birth pate/Age Employer? ..: Occupation . . Oper Lic No. .: Home Phone No. : 561/000-0000 Race... . . : White Sex ... . » : Female Height -...:0 Weight ....:0 Misc. ID§ . .: Be On Look Out?: Other Phone Nbr: 561/000-0000 Victim Type . : ADULT Residency Type File Charges Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: Residency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment GIUFFRE005619 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page603 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 7 8:47:53 incident Report Program: CMS301L Case No. . . , :-1-05-000368 (Continued) Phys Last Name ; tkeeREKKHRKKEX Y TCT IM INFORMATI ON - LQ FEERKKHKEKEKENREREE Case Number . ; 1-05-000368 Prompt valid in: Street Number City + 5s PALM BEACH, FL 000033480 Birth pate/Age 18 Employer? ..i: Occupation . . Oper Lic No. .: Home Phone No, : 561/000-0000 Race... .. : White BGG ai yas ee Female Height ....:0 Weight ... 9 Misc. ID# ..: Be On Look Out? Other Phone Nbr: 561/000-0000 Victim Type - ADULT Residency Type Pile Charges . Victim Sobriety Injury Type 1 Hospital ID Phys First Name: IcTtiImM INPORMATION - #33 tivteeeeas | Residency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment Phys Last Name PERK RRR KERR Case Number . Street Number City: . PALM BEACH, FL 000033480 Birth Date/Age 16 Employer? z Occupation . . : Oper Lic No. | Home Phone No. : 561/000-0000 Race... 4s White Sex ..-.. . : Female Height: vy ico4 9 Weight... 3d Misc. ID# .. Be On Look Out?: Other Phone Nbr: 561/000-0000 Victim Type . JUVENILE Residency Type File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID .: Phys First Name: Residency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment Phys Last Name etekeERKKRREEAR VICTIM INFORMATION - 14 KAKKKERAESEEL SE REE Case Number . ;: 1-05-000368 Prompt valid in; Street Number city . « FL 000033480 Birth Date/Age a ee Employer? ..: Occupation . Oper Lic No. .: Home Phone No. 561/000-0000 Race... . . : White BOW. sete wi’ Female Height ....: 40 Weight... O Misc: ID# .. Be On Look out Other Phone Nor: 561/000-0000 Victim Type - : JUVENILE Residency Type : Residency Sts : File Charges Can Identify .: Victim Sobriety: Injury Extent : Injury Type 1 GIUFFRE005620 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page604 of 883 7 Date: 7/25/06 Time 7353 Case No. Injury Type tz Med Treatment Phys Last Name A dei Case Number Street Number Clty . Birth Date/Age Occupation. . Home Phone No. Bex .. Weight - . Be On Look Out?: Victim Type . Residency StsCan Identify . Injury Extent Injury Type 2 Med Treatment PALM BEACH POLICE DEPARTMENT Incident Report : 1-05-000368 Hospital ID . Phys First Name: VICTIM INFORMATION -# ERRERAKRR RE Ie EER : 1-05-000368 Prompt valid in: ee (Continued) : PALM BEACH, FL 000033480 > Employer? 3 Oper Lic No. : 561/000-0000 Race . o% : Female Height... a 3): 0 7 0 Misc. ID# . Other Phone Nbr: 561/000-0000 : ADULT Residency Type : File Charges Victim Sobriet Injury Type 1 Hospital ID Phys First Name: Phys Last Name : FARRER RR RRR Case Number Street Number ey i Birth Date/Age Occupation . Home Phone No. Sex v. Weight .... Be On Look Out?: Victim Type Residency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment INFORMATION Prompt valid i: WE C-T-I-M 1-05-000368 : PALM BEACH, FL 000033480 : 4 HAKKREREERER ERR EN EK 17 Employer? . z Oper Lic No. 561/000-0000 Race : White : Female Height . 0 0 Misc. ID# .. Other Phone Nbr: 561/000-0000 : JUVENILE Residency Type Pile Charges Victim Sobriety: Injury Type 1 Hospital ID Phys First Name: Phys Last Name : EKER RERKEERREE Case Number Street Number city Birth Date/Age : Occupation . Home Phone No. Sex . Weight . Be On Look Gute: Victim Type Residency Sts VIcTIM 1-05-000368 CH, FL 000033480 INFORMATION - LT HKHKHEEKKHAEEHHRERERK Prompt valid in 16 Employer? ..: : Oper Lic No. . : : 561/000-0000 Race . . : White + Female Height . . 20. o Misc. ID# . Other Phone Nbr: 561/000-0000 : JUVENILE Residency Type : File Charges GIUFFRE005621 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page605 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page Incident Report Program: CMS301L | Case No. . - . : 1-05-000368 (Continued) Can Identify . : Victim Sobriety: Injury Extent ; Injury Type 1 : Injury Type 2 : Hospital ID . : Med Treatment : Phys First Name: Phys Last Name tkxaxeeee OTHER PERSON INFORMA — FOO I AAO Case Number . 1-05-000368 Last Name . . aaa aes Street Number City. . WEST PALM BEACH, FL 33411 Birth Date/Age 14 Employer? Occupation . . ; STUDENT Oper Lic No. Home Phone No. Race». sw White BOL 6 aes Pemat Height}... 5 20 Weight .... 0 Person Type .- OTHER PERSON Other Phone Nbr: teteeeeee OTHER PERSON INFORMATION - # 2 +kteteene Case Number . ;: 1-05-000368 Last Name . . : MARCINKOVA, NADA Street Number : 358 EL BRILLO WY City .. : he FL 000033480 : Birth Date/Age . 19 Employer? ..: A Occupation . . : Oper Lic No. . ay | Home Phone No. : Race... i: . : White Bex i... . 2 Female Height . ... : 510 Weight ... : 0 Person Type . : OTHER PERSON Other Phone Nbr: | eeeeERERE OTHER PERSON INFORMATION -— # 3 ##ttkaKKE Case Number . : 1-05-000363 Last Name Street Number : } | City ~ : ROYAL PALM BEACH, FL 33411 Birth pate/Age 35 Employer? ..: | Occupation Oper Lic No. . | Home Phone No. Race... . . : White | Se Ss, . + Female Heigne ava e FO oO Person Type . : OTHER PERSON Weight... = Other Phone Nbr: eeekKeEee OTHER PERSON INFORMA HeKKKHHRE faba misbar’ |. _—— Street Number City mv Birth Date/Age 37 Employer? ..: Occupation. . Oper Lic No. . : Home Phone No. : Race... ww. : White Bae ee ts Sots Height ....:0 Weight .. 7 0 Person Type . : OTHER PERSON Other Phone “wor: kekeNeHEe O THER PERSON INFORMATION - # 5 teuneenee Case Number . : 1-05-000368 Last Name ..: GIUFFRE005622 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page606 of 883 Date 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 10 Time: 8:47:53 Incident Report Program: CMS301L pew malty om adann eae sh eet epi recs ae ya deena arose a da deae gota date ne denaces { Case No. . . . : 1-05-000368 (Continued) Street Number : City... : Birth Date/Age : 0/00/0000 O Employer? . Occupation . . : FAMILY THERAPIST Oper Lic No. Home Phone No. : 561/000-0000 Race. ...., +: White Sex... . 3 : Female FeLgEt s i-.s- « 0 Weight... : 0 Person Type . : OTHER PERSON Other Phone Nbr: 561/000-0000 | ***EMPLOYER INFORMATION*** i Case Number . 1-05-000368 | Employer Name PBC DIVISON OF YOUTH AFFAIRS j Address 4200 N AUSTRALIAN AV i City/State/Zip WEST PALM BEACH, FL 33407 Phone Number . : 561/840-4540 seteeten® O THE R PERSON INFORMATION - # 6 *#ttaekee Case Number . :_1-05-000368 Last Name .. : Street Number : city. : WELLINGTON, FL 33414 Birth Date/Age : ER © Employer? ..: Occupation . : STUDENT Oper Lic No. : Home Phone No. : Race... . . : White Bex... ao 4/1 Male Height ....:0 Weight . . : 0 Person Type . : OTHER PERSON j Other Phone Nbr: | ***EMPLOYER INFORMATION*** | Case Number . : 1-05-000368 Employer Name : SUMMIT CHRISTIAN SCHOOL Address .. : 4900 SUMMIT BV City/State/Zip : WEST PALM BEACH, FL 33415 ! Phone Number . : j SteeRAKER OT HER PERSON INFORMATION ~- # 7 xkeenxene | Case Number . 1-05-000368 Last Name ..: Street Number city’. . 5 Birth pate/Age : 0/00/0000 0 Employer? . 3 Occupation . . : Oper Lic No. . : Home Phone No. : iy Race =. .: .: White BBR: Wr iy ce cap se) § MAD Height .. ..:0 Weight ....:0 Person Type . : OTHER PERSON Other Phone Nbr: seeeertee O TH ER PERSON INFORMA = pee S STS Case Wunber . : 1-05-000368 —— «| Street Number Cley Fs Birth Date/Age Employer? | Occupation . Oper Lic No, Home Phone No. ; i Race y 2 os. Sex ,.. . . + Female Height ....:0 GIUFFRE005623 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page607 of 883 PALM BEACH POLICE DEPARTMENT Page: gab Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) | Weight ...-.:0 Person Type . : OTHER PERSON Other Phone Nbr: ttetesexek O THER PERSON INFORMA — +i Ree! Case Number . : 1-05-000368 Last Name . : { Street Number =: j City. icra. } Birth Date/Age : 16 Employer? = Occupation . .: Oper Lic No. Sawa Home Phone No. : 561/000-0000 Race... . . : White Sex .. .:. « 1 Female Reight .. . 2.4.0 Weight Person Type . : OTHER PERSON a aso, ge ete Other Phone Nbr: 561/000-0000 HL RHRRATHREEARR ER REE EE REE ES SRKPEAE RR REE REE RRERRE NARRATIVE Original Report LO Reported By: PAGAN, MICHELE D. 9/20/05 Entered By.: OREGERO, LAURA D. 9/20/05 On 03/14/2005, I received a call from = id not wish to i identify herself (later identified as . She sta | that her fourteen year old step daughter (later identified as MNNM):.s Possibly may have been molested in Palm Beach by a wealthy i Man. According _ she learned of the possible molestation } by a third party. “5 tained that she had received a call from the mother of her stepdaughter's friend, The mother claimed to have overheard a conversation between her daughter and a male friend; they were talking about i. The conversation was about how had met with a 4 = id man and had sex with him and was paid for it. I advised that I would like to meet with her to obtain a more detailed statement and facts. stated she did not know what to do and had to discuss the matter with her husband. At this point id not provide me with a call back number or any other information. She stated that she would contact me once she had spoken with her husband and (fs mother. On 03/14/2005 received a call from Mr. & a comet They stated it was all right to s daughter a cell phone i GN. er mother had been made aware of the case. They agreed to meet me at the police department later this date. on 03/14/2005, Mr. iS --companied by his wife [ER i came to the Palm Beach Police Department where they advised i me that they believed their fourteen year old daughter may have had some type of sexual relationship with an older male who resided in Palm Beach. Neither knew the suspect's name or address. Both stated that their daughter did not talk to them about the incident, nor would she admit to it. HR ienti fica his daughter as w/f, DOB resides with her biol ne: at | GIUFFRE005624 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page608 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 7:53 Incident Report Case No... 1-05-000368 inued) her sister Gs des with vw - Both = are currently attending school, wnica is an involuntary admitte facility. ee at the facility during the week and comes home on the weekend. ccording to =a she was admitted to the school because of disciplinary problems that recently escalated. The facility also coordinates with the families to provide one on one as well as family counseling. nceording to Mrs. MMM, che believes the incident occurred on y, - A friend of [BBB's, named Haley: picked Her up at their v= and left. They believe Haley initiated the relationship with the older gentleman, though they do not_ have any proof. Haley lives close by with her mother. further explained that Ges es mm mm :. by | a boy iin °° (goes to| plays baseball). Mrs. continued that on Sunday, Haley picked up MM, and drove to Palm Beach where they met the man. Supposedly, the man has a lot of money and often has young girls come over to his house. Haley offers these girls a way to make fast cash. The man starts with a If he likes them, he keeps them around and does more. The ave any information on Haley other than she lives On the last house on right side (north side). Mrs. talked of a_conversation that she had with tne mother of a former friend of found it strange that they were oo tonger friends until she received the call_from her mother telling her of the conversation she overheard between id a boy named Mrs. told me of an incident that occurred on 00s. Igot into a fight at school . x Assistant Principal, found ovér $300.00 :a1 ; purses Ya different explanations for the large sum of money. Initially the school administration thought it was drug related but then dismissed the claim. Since that day, MMdid not return to school; she ran away Thursday, 02/10th or Friday 02/11 and returned to her mother’s house later that night after midnight. It eee = x call on hat she learne was the girl that got into the fight with The fight was instigated when MM accused Mor being a prostitute. who has legal joint custody of his daughter J gned the affidavit of prosecution indicating he wr to prosecute against the inappropriate sexual behavior with his fourteen-year-old daughter. Mr. t st he had no objections with our agency speaking his dai ter: jabout the incident. Mr. =n stated that s mother § aware o. gations and also was willing to cooperate. According to Mrs. she does not believe her daughter had any additional contact with the suspect as she was with GIUFFRE005625 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page609 of 883 PALM BEACH POLICE DEPARTMENT Page: 13 Incident Report Program: CMS301L (Continued) Case No. . . . : 1+05-000368 her mother and then placed into ii rovided me the information I coetor ed the School Board Police who West Palm Beach, Florida. Checking the there was no school board records for disciplinary record found. I was advised if no disciplinary action was taken for a fight, such as an expulsion or detention, the incident may not have been recorded. This was at the discretion of the individual school security and principal. 03/15/2005, I called the Palm Beach County Sheriff's Office and left a message for PBSP Sgt. Chris Keen, Child Abuse Unit. on 03/ 2005, IT went ot, is white female Also present was joke with therapist. During an audiotaped intervj about the allegations that were made. initially denied i bad happened, only admitting to going with Haley (later ed as Haley Robson) to Palm Beach to pick up money Robson was identified Haley Robson as the cousin of her former She ultimately admitted to knowing that Robson She boyfriend worked for a wealthy man and possibly did sexual favors for him, also admitted that Robson had offered her an opportunity to make money MM enti ice Robson's boss as a white male named "Jeff" who alin’ Beach (later positively identified as Jeffrey Epstein) . nn that she was first approached by Robson to go with a : house. According to ££'s house, when they were at she was not su ctly what was going on with Robson but | agreed to go with her, boyfriend) gry when he heard Robson inviting to accompany. believed it was to pick up money the man owed Robson. stated Robson told her that she would pick her up at her house on Sunday. According wai of the exact dates but knew it was a Sunday. aw Robson along with an unkn; ly Hispanic female, old her to picked her up at her father's house o1 It was later confirmed by father that they were going shopping. hat Robson picked his daughter up. According to Mr, 'Robsondrove: a@spick, up-truck Robson ae GE 22 onc with the unknown female to Palm Beach. on occurred between Robson and the way there, a conversa’ hereby Robson told MEBBMMbhat if Jeff asked her age, she should say she was eighteen. ecalled that deff's house was on a dead.end street. All ree girls walked up a drivewa ast what appeared to be a small sunndjeneucity room, In fact, a a male approaching them asking what they wanted. opson stated they were there to see Jeff. The male allowed them to continue walking up to the house. GIUFFRE005626 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page610 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 14 Time: 8:47:53 Incident Report Program: CMS301L Case No... . : 1-05-000368 (Continued) stated the man told them that Epstein was not there but was expected back, He allowed them to enter the house, via the kitchen, He offered them something to drink while they waited inside. Shortly after, Epstein man, described as white with. blond hair entered + en. jelieved the woman was Epstein! Stant. mie: that the woman did not seem friendly and respons ort and direct. Epstein introduced himself a: Jeff. iot_ the impression that Epstein and Robson's rrien knew each other. z lescrihed Epstein as being approximately forty-five; years old," a"Iong “face; and bushy eyebrows, with graying hair. Robson and Epstein left the kitchen leaving MMM and robson's friend alone in the kitchen. They returned a short time They all spoke briefly in the kitchen. While speaking to me, became upset and started to cry. stated the woman instructed her to follow her upstairs, which she did. According to the woman led her to a room that had a massage table in it. ‘Tne woman started to fix up the room, putting the covers on the table and taking lotions out. She then told — Epstein would be up ina second. left the room, and soon after a, walked in and told to _take o: er clothes. As was telling me what had happened, she looked away from_me,-and with a pointed finger, repeatedly pressed it into her thigh. ed he was stern when he told her to take off her clothes. said she did not. know what to do as she was the only one there. shirt leaving her bra in, dressed in a towe ier ti take ort everything. eee she removed her pants leavin her thong panties on. Epstein then instructed her to give him a Massage pointing t6 a specifi jon for her to use. Epstein laid on the table, face down. As © give Epstein the massage, he told her to get to K, Stated she straddled herself stein's back. S_were touching Epstein § Dare buttocks. iving Epstein the massage, fhe turned around, and wacked of later explained that wacking off was masturbating) . tated she was di y Epstein's actions but did not say anything. According <> i Epstein told her that she "had a really hot body." Epstein excuse himself and went to the bathroom where sne be. asturbated again. Epstein returned to the room and told hat he was done and gave her three hundred dollars. They went back down stairs where they met Robson. Epstein said good-bye and they left Robson asked how. did it go and asked what did she ee 3. When old Robson that Epstein asked for a massage, Robson stated "I know." eel they then went shopping. stated Robson also got paid, but that she did not know why since she was confident that Robson did not do anything. described Zpstein's house as a two story pink house with a Ca ac Escalade parked in the drivewa: There were gates leading into the property. From the kitchen, ecalled walking up a flight of stairs, lined with photographs, to a room. Upon entering GIUFFRE005627 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page611 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 15 Date: i 7:53 Incident Report Program: CMS301L Tim Case No. .. . : 1-05-000368 Continued) the room there was a large bathroom to the right. recalled a hot pink and ms sofa in the room. There was a door on each side of the sofa. recalled there being a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. a === =< Epstein did not change in front of her but did take Ort his Lowel, exposing himself «<a icc Epstein being hairy especially on his che in also had a hairline that d_to his buttocks. admitted to seeing his penis. I i ig circumcised meant and she stated then said that she thought Epstein was on steroids @ was a "really built guy and his wee wee was very tiny." would explain that when she stated "wee wee” she meant penis. stated Epstein exposed himself when he took his towel off, placing it on the floor as he laid down on the table. GR 254 Epstein was specific in his i to her on how to massage, telling her to go clockwise, etc, recalled that Epstein got up from the table and went to the Datnroom where she heard him making, what she believed to be sexual type of noises. (moaning) He then returned to the room where he again laid down on the table. Epstein then turned over and instructed Ail: > massage his boobs. As she did this, Epstein continued to make moaning noises. resumed massaging his chest area. [EBBBBMMMkes now standing on the ground. Epstein turned to his side, and with the towe ie ground started to rub his penis in an up and down motion. stated Epstein held on to the xr back as she massaged his chest, back and shoulder ores: hemi = 2257.3 Epstein ejaculating because he had to use the towel to wipe himself as he got off the table. MBBBBBNMMMatso recalled Epstein having a noticeable freckle on his chest. Epstein then left the room and a... dressed. She went back downstairs where she met Haley and the unknown white female. admitted to getting paid three liars in cash from ED Before they left, Epstein asked to leave her phone number. As they were leaving the ho asked MBM what had happened and how much she was paid. a: Haley seemed upset or jealous when she told her thi received three hundred dollars. Haley stated received only two hundred dollars that day. stated that she believed Haley was paid two hundred dollars for bringing her. Robson told that if they do this every Saturday, they could be rich; agreed. They then went shoppi fh she is not sure where. Possibly at Td Maxx or Marshall's. stated she never saw Robson again as she got into a fight at school. She had not spoken with Robson either as her mother took away her cell phone. I asked if she was aware of any video equipment while she was in the room. She stated no. GIUFFRE005628 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page612 of 883 PALM BEACH POLICE DEPARTMENT Incident Report Page 16 Program: CMS301L 1-05-000368 (Continued) stated she was afraid that Robson would retaliate against her or her family if she ever went to the police regarding the incident. stated that her father's vehicle was recently vandalized. admitted to tellin what had happened with Epstein. According to became angry t, punching a hole in the wall. guessed that it was ho told about the incident, and now there were rumors in school about and what she did with Epstein. I then talked to (I 222°" ii lying. We talked about the a color sweater she was wearing. lenied having sexual intercourse with Epstein. She denied touching his penis. ss again admitted to observing Epstein masturbate. Ma ....: to cooperating with the police department in placing a phone call to Robson in a controlled setting jib Ms. = and advised her of the families' as well !'s willingness to cooperate with this investigation. Copies of this interview were placed into evidence. i made contact with MM nother of I advised her briefly of my investigation. She was aware of the incident and stated that she overheard a portion of ion that her daughter was having with a boy named stated that it was her opinion that both girls liked recalled hearing her daughter calling a whore. admitted that she did not listen to the_entire conversation but did confront her daughter about it later told her mother that something to the effect that (BBMMMnad slept with an older man for money. el © would not object to me speaking with her daughter. It was s belief that everyone in the school may have oe this because of the fight that her daughter and had gotten into. I reminded MMM that this was an ongoing investigation and requested she not discuss the fact that I had contacted her. She agreed. On 03/16/2005, PBSO Sgt. Chris Keen left a message that he was returning my call. I spoke with Keen and discussed the case with him and inquired if he had any open allegations or cases, where the suspect resided in Palm Beach. Keen stated he was unaware of any. Keen offered any assistance if needed. Keen stated it was his experience that due to the age of the parties involved, it would be difficult to interview them and expect the investigation to remain confidential. Because of the time delay, there was no need for the victim to be taken to a medical facility for a physical for the purpose of obtaining evidence. There was also no need to take her to CPT as she was already in a juvenile facility, with an assigned therapist, in which coordinating a day and time to obtain a statement could be made. On 03/17/2005, I queried Jeffery Epstein on the internet and obtained GIUFFRE005629 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page613 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 17 8:4 3 Incident Report Program: CMS301L Case No, . - : 1-05-000368 (Continued) a ae of Epstein to be used in a photo line up. I met with lat which time she viewed the photo line up. She recognized Epstein and pointed to him (Position #5), ae the photo line up under Epstein's picture. This signe ne up was placed into evidence. On 03/18/2005, I met with HE - . her —,:: the purpose of placing a controlled call to Haley Robson. spoke with Robson and asked if she could arrange another meeting wi eff. Robson stated that she would have to call him and make the arrangements. A copy of this conversation was placed into evidence. 03/19/2005, Is with and and was advised that left the state to visit with her aunt and uncle. is scheduled to return to Florida on 03/27/2005 03/21/2005, I coordinated with PB BSF Unit and OCVAN to initiate surveillance on 358 El Brillo. 03/21/2005, Coordinated with Det. Lee regarding trash pulls from 358 Bl Brillo. On this same date T called ie ©. schedule an appointment to speak with .| She stated the school guidance counselor was reluctant to have police presence at the school, TI assured her that I would respond to the school in civilian clothes and an unmarked vehicle. HR 221d me back vised that I did not need to make an appointment to see iyed a return phone call from | tk would be attending the family therapy sessions with i I received messages from aa I conducted a computer query on Epstein. The results of this query indicated the most recent driver's license on file for Epstein was for the state of Florida, which had expired. A cross reference of Epstein s residence, 358 El Brillo, Palm Beach, revealed the following affiliated names: Nada Marcinkova, w/f, dob Mark L. Epstein, w/m dob & Ghislaine N. Maxwell, uk/f, dob MM. A computer query for both returned no history. on 03/23/2005, I spoke with [MMMM <1) phone wk Si requested_that she not discuss the incident with anyone including her daughter as I did not want the investigation compromised. I was have not been getting along due told at this time, that and to the fact that MMMMMMBpas decided to continue living with her father. On 03/29/2005, I placed telephone calls to both the =: residences requesting to speak with them regarding the GIUFFRE005630 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page614 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Case No. . » + 1-05-000368 I received return phone calls from Mrs. and advised them that I would be contacting s family therapist to coordinate a time to meet with was at the request of: both Mand mrs. classroom and therapy schedule be disrupted as little as po wv, also updated them to the investigation thus far. Both stated they had no objection to my meeting with | In speaking with Ms. wees she identified the cell phone number of as being the phone assigned | = Ms. nad no objections and provided consent to giving it to the police department for the use of placing controlled phone calls from it. tated the phone had been taken away from as part of her punishment for not doing well in school. According to aN. MMMsea to be an excellent student, but in the past two months Nas become irritable, verbally abusive to the family and has run away. tated her daug ecent behavior is the opposite o normally is. stated they are going through family therapy sessions with the school but none of this had come up. Arrangements were made for Det. Captain Gudger to retrieve the cell phone from lat her place of employment. I called Ky and requested to speak with Ms. Upon speaking with Ms. she advised me that she was in the middle of therapy sessions and would call me back once the sessions were completed. Ms. 9MMMstated the sessions should be concluded by 7:00 PM. At approximately 8:00PM I had called Ms. at which time I left a message on her voice mail requesting a return phone call. I spoke with Ms. and advised her that I did not meet with her daughter and tha’ would again attempt to coordinate a | time with the counselor so as not to disrupt school s ae: no objections. apt’, after speaking with Ms. = received a call from Ms. I explained the situation requested a ti © meet with MMMM reviewed QIK schedule and advised that would be available after 3:00PM. T_reminded ee er conversa! . w. a Robson, During this time initiated a conversation with me which she admitted that she was not telling me everything that ed during the time she was alone with Epstein. According — while she and Epstein were alone ‘on the secon stein used a purple vibrator to massage her vaginal area, stated there | was ni ion as the vibrator was on top oO: er underwear. I £ Epstein ever asked her age and she stated he had. stated she told_him she was eighteen. When Epstein asked in, MBM cesponded she was in the what school she was i. grade at Wellington. During the course of this incident, stated Epstein told her that Haley had worked for him for years. We then continue: ith t controlled call to Robson. At approximately 3, from her cell phone, made a call to Robson s home, Robson was not home, Hl’: told GIUFFRE005631 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page615 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 7:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) that Haley rking a double and could be reached on her cell phone, W/F, Haley Robson is employed at The Olive Garden Restaurant, located on Forest Hills Blvd in Wellington. bson. During the conversation between Haley Robson and Robson asked QM what happened, stating that she had heard rumors that was going to press charges. Robson asked if they, meaning s, knew about Jeffery. Robson claimed t' F !s father had found out about Jeffrey. told Robson that parents) did not know anything about Epstein. Robson told that Epstein needed someone to work tomorrow and asked if she was le. Robson stated she would call Epstein and then call back. During the course of these conversations with iy she would at times appear to be articulate and well spoken. She would then | start to act in an immature manne: oking around, not paying attention, drawing on a paper. would offer me a high five whenever she claimed to have told me the truth in the details of the afternoon at Epstein's house. would sit in the chair, with her knees propped up to her chest as she admitted that she did not tell me the all the details of her encounter with Epstein-during our aa As a means of positive reinforcement I would high five On 03/31/2005, subpoeni -Mobile Wireless j and Cingular Wireless, (Robson and phone numbers) were drafted. On 04/01/2005, I met with members of PB BSF Unit for the purpose of conducting surveillance on 358 El Brillo. Cross-reference supplement. On 04/01/2005, I met with Det. Krauel of the Palm Beach Police Department who provided me a copy of the concealed weapons permit for Mr. Epstein. It revealed Epstein had a valid permit. There was no current photo attached to the renewal notice. On this same date I queried various different web sites for a possible identification of the purple item retrieved from the trash pull from 358 El Brillo. The item was similar in description as the one described by eq and used by Epstein. I made contact with Spicygear.com and spoke with the owner John. I emailed a photograph of the item for his opinion. He identified the items as a Jelly Anal Wand of some sort. The item is easily available at sex shops in South Florida. 04/06/2005, I conducted business queries into Epstein utilizing the internet. I located articles relating to financial reports. There was no local history. On 04/01/2005 - 04/03/2005, with the assistance of BSF, there was GIUFFRE005632 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page616 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Case No. 05-000368 (Continued) continued surveillance on the property. On 04/04/2005, I obtained a copy of ic. Messages, dated 03/31 and 04/01 from Haley Robson to A female identifying herself as Haley states that she cou. pick up to take her to Epstein's house for an eleven o clock appointment. A copy of this was placed into evidence. On 04/05/2005, a trash pull was conducted at 358 81 Brillo by Det. Lee and me. There were several messages written on various forms of papers. There was a message from Haley, indicatin The following was additional information obtained from ‘etrieved i llen from 358 El Bril i 2 Dav. Friday 5:30PM a@ message receipt dated = 1:05— She is looking to speak to you .; 5 On 04/06/2005, I f£ =) a requests to SA Mighdolls office for in, Robson and hone records. Phone numbers & on 04/06/2005, 1 callie ST and spoke with Principa He confirmed that they had a student by the name of He requested a written request prior to releasing any additional information. On this same_date I faxed a requ; For student and parent information on =i : mS sed that due to this being an open investigation he was not to discuss the matter with anyone. On 04/08/2005, I receive following information: w/m DOB i i Parents name; Det. Lee provided me with trash obtained from 358 El Brillo for 04/06 04/07/05. The following information was retrieved: Jet Aviation pubicietnien coarse: indicating a departure date of 04/05/2005 at 4:00 PM with an arrival in New York City of 6:15PM. Flight crew captain David Rodgers, co-captain, Larry Visoski, flight engineer Larry Morrison, Call sign N908JE; a note stating Bye J. thank you hand written notes & messages 11-Glenn, 12:30 chicken, 3 September B & J, Big Screen x8, work day @ y_after school?; left message for , , Hox: 4-9 Monday and Tuesday, leaves school @ ‘ here tomorrow @ 10:30 Am; Mrs. Business i | There was no trash for 04/08/05. 2/0 eived the results of a subpoena request from Bellsouth for | The results only provided subscriber information. I contacted Alice Grant Investigative Subpoena Compliance Center who stated the request was not complete and the results would be mt to GIUFFRE005633 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page617 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Pag 21 Time: 8:47:53 Incident Report Program: CMS301L Case No. .. . : 1-05-000368 (Continued) me as soon as the query was finished. Cross-referencing the names aaa eae well as phone numbers, which were obt. rom message notes via trash pulls, I identified the before mentioned individuals as being ac jeone at 358 El Brillo. ha L BL ¢ MMM D0: Boe are bot ove the legal age of consent. On 05/03/2005, I_spoke with land updated her on the investigation. tated thal was doing well in the school. Her contact with the outside is Limited as they do not have access to the phones. comes home on the weekends and she is not allowed to go anywhere alone. On 05/11/2005, I made arrangements to meet with On Thursday, 05/12/05, I spoke with regarding the case. They will be moving to GA in July 2 ey be very busy over the next few weeks but would be available via phone. Will coordinate a date to meet to discuss the matter further. During this week I conducted surveillance at Epstein s residence and at the airport, but there was nothing to indicate that Epstein was in town. Due to conflicting appointments, rescheduled until 06/02/2005, to meet with Ms. I also spoke with [I 2 updated her to the investigation, On 06/02/2005, I met with| HE. 2=: that she could be reached at she is a. to provide me with her new contact information. I also received a message ——, Attempted call back but the line was busy. June 14, 2005, I received information that Epstein's plane was at Jet Aviation. I spoke with Det. Lee regarding surveillance. I called the Olive Garden and asked for Haley Robson. I was advised she was not working today. This would indicate that Robson was still employed there. On 07/07/2005, I faxed subpoena requests to SA Mighdolls office for i s phi (Phone numbers id . The original s © billing information. On 07/20/2005, conducted a trash-pull arranged by Ofc. Lee. Inside there were misc. papers with phone numbers and names. There were GIUFFRE005634 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page618 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT 8:47:53 Incident Report Case No. . . . : 1-05-000368 (Continued) misc. female hygiene products in the trash. Based on a prior Auto Track report done on 358 El Brillo, a possible subject residing at the residence is Nada Marcinkova. Marcinkova fit the description provided by officers who had conducted surveillance in the area of a female seen entering and leaving the residence. On 07/21/05, I received the Duces Tecum dated 07/18/05, which was clerked by ASO On 07/26/2005, I received the results of Bell South Subpoena. On 08/04/05, I received DHL Express from T mobile with the results of the query. I spoke with me: confirmed that ma... still living out of state hat all was going we. I left a message cox [ at On 08/08/2005, I received the results of Cingular cell phone subpoena. During the week of 09/08/2005, I checked 358 El Brillo and the Palm Beach International Airport but there was no direct indication that Epstein was in town. On 03/08/2005, I reviewed the case notes of this file, as the case will be turned over to Det. Recarey. On 09/11/2005, while on patrol, I conducted a check at Epstein's residence and found that it still had the hurricane shutters on. On a drive by the Palm Beach International Airport later that afternoon, I did not observe Epstein's plane. On 03/14/2005, I conducted a check at the Palm Beach International Airport. but did not see Epstein s plane. On 09/15/2005, I spoke wit i keep her updated and_t. find out if there was any change of address or phone I was told no. I left a message for ie -in order to provide her with Detective Kecarey 58 information. HHRKRERKE RARER RR REAAARE RE AEREN A RRATIVE BD RAKHI A AREA ERE RARER RE REE EE NA Reported By: RECAREY, JOSEPH 9/21/05 Entered By.: ALTOMARO, NICKIE A. 9/21/05 On September 19, 2005, I met with Officer Pagan and received the information pertaining to this case. Members of the Burglary Strike Force had previously been conducting surveillance on both Epstein and Robson. Officer Munyan was assigned to monitor the Epstein home and Sgt Sorge and Officer Minot were assigned to monitor Robson. Both teams provided a surveillance log that will be placed into the GIUFFRE005635 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page619 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 23 8:47:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) attachment file. Det. Dawson was assigned to relieve Officer Munyan at 4:00 pm; he informed me that at approximately 8:00 pm, Epstein had left for the airport and his private jet was sitting on the tarmac. Epstein's. private vehicle drove to the jet and unloaded packages into the jet. It appeared that Epstein left the county at this time. Surveillance will continue to determine when Epstein will return. Inv Continues, HR KARHERAREAAEARERAAEREREAER NA RRA T LV Bo # 3 ttkktRRAR KHER EERE NA Reported By: PARKINSON, GREGORY A. 9/23/05 Entered By.: ALTOMARO, NICKIE A. 9/23/05 On Friday, September 23, 2005 at approximately 1:45 p.m., I began to copy a tape micro cassette, under case number 05-368 and property number 05-243, tape number 1. I placed the tape in the telex copy-et, series 2 machine and began to go through the copying process. Approximately 1/2 through the tape, the tape wrapped around the spindle and became locked and stretched the tape. I examined it and determined that it was in the best interest to leave it as it is asa prior copy had been made and turned over to Sergeant Frick. I immediately took the tape to Sergeant Frick and allowed him to examine it and then obtained the copy from him and Detective Recarey and brought the copy of the tape down and made a copy for him based on that. The tape was placed back in the original container and is retained in the evidence bag under the previously mentioned property number of 05-243. It is not advisable to attempt to copy this tape as further damage could result to the recorded material and there is an existing copy anyway. RARKARE KH ERAARARAARHARAEHARE NARRATIVE BA RRRHKEEAR EAR REA RERHEREEE NA Reported By: PARKINSON, GREGORY A. 9/26/05 Entered By.: ALTOMARO, NICKIE A, 9/26/05 On 3-24-05 at 11:00 pm, a copy of tape 2 (case number 05-294) had been made for Det. Pagan by Bvidence Specialist Annette Badger. The copy was turned over to Detective Recarey. On Friday, 09-23-05 at approimately 2:15 pm, I was in the process of reproducing audio tapes (micro and standard) to standard size when it was discovered, in the test review process, that tape number 2 was blank. I notified Sgt, Frick and Det. Recarey. I was informed that they had a prior copy and I could use it to make a master tape. I did so and when reviewing and signing the evidence sheet, I noticed Evidence Specialist Badger had written "#2 is blank." I ebtained that copy from Det. Recarey and made a new copy on a standard size tape. The new copy was placed in the evidence bag under GIUFFRE005636 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page620 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 24 8:47:53 Incident Report Program: CMS301L Case No, . .. : 1-05-000368 (Continued) property number 05-294 with the blank tape. RERERKERRARR AR RAKAAAKEREAHAEE NARRATIVE FD RFRHREREREREER ER RARER RRR R EE NA Reported By: RECAREY, JOSEPH 3/26/05 Entered By.: ALTOMARO, NICKIE A, 9/28/05 Copies of the tapes that were submitted into evidence were requested. Additionally, trash pulls were started on September 21, 2005. Sgt. Szarszewski made telephone contact with Tony Higgins, Supervisor of the Sanitation Department, and requested that trash be collected at the Epstein House located at 358 El Brillo in Palm Beach. Sgt Szarszewski met with Sanitation worker, Jeff Williams and observed him enter the property at 358 El Brillo. Shortly thereafter, Williams exited the property and placed the three white trash bags in the empty well in the rear of the truck. Williams then drove away where he met with Sgt. Szarszewski who removed the bags from the well and placed them into one large black trash bag. The bag was returned to the Police Station where I, was waiting for him. Upon his arrival, we inspected the bags where several notes and papers were found. These notes contai es ai «: with times. Additionally, there was a note from and to Jeffrey Epstein on a notepad, which stated,"For a good time call and " Also, there was another telephone numbe he note iso found was a written note, which stated, can not come at 7 p.m. tomorrow because of soccer. These items were written on notepads that contain Jeffrey Epstein on the bottom of the notes. These items were Placed into evidence for future follow up. I requested subpoenas for subscribe: ti @ telephone numbers listed the and The cellular telephones and aaa © oth assigned to Cingular Cellular Service. Other notes were found within the trash on Jeffrey Epstein_pad, pape: contained telephone numbers. One note had es with e written on it. This cellular number_is ass © Cingular Cellular Service. Another sheet had written HE «ich is assigned to Bell South Telecommunications. The subpoenas were picked up and submitted to Cingular and Bell South Telecommunication for subscriber information. On September 22, 2005, I was informed by Sgt. Szarszewski that there would be no trash pick up as it was recycle pick up day. A request for copies of the micro and standard size cassettes were requested from crime scene to familiarize myself with the interviews conducted. On September 23, 2005, the tapes were received and I began to become familiar with the interviews that were conducted. Det, Krauel had met with Town of Palm Beach Sanitation worker, Jeff Williams and observed him enter the property of 358 Hl Brillo. Shortly thereafter, Williams exited the property and placed the three white trash bags in the empty well in the rear of the truck. Williams then drove away where he met with Det. Krauel who removed the bags from the well and placed them into one large black trash bag. The bag was returned to the Police Station where I was waiting for him. Upon his arrival, we inspected GIUFFRE005637 CONFIDENTIAL | | |

Case 18-2868, Document 283, 08/09/2019, 2628241, Page621 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Case No. .. . : 1-05-000368 (Continued) the bags where several notes and papers were found. The notes will be inspected for future use. The items collected were placed into evidence. It became evident that some of the recordings were recorded with background noise and some interference. The calls most affected were the control phone calls from the victim to the suspect Haley Robson. I obtained the graphic equalizer and discovered that the calls are able to be legible with the use of the equalizer by lowering the background noise and increasing voice gain. I also learned that a tape was broken during the coping of the tape. I returned the copy of the tape marked Property Number 05-243 to have it recopied to have an eriginal in evidence and a working copy with the file. Upon researching the file, it was discovered that the suspect, Haley Robson's cellular ca aed incorrectly. The suspect el one number was and the original request was for as I requested the information through Cingular Cellular Service from February 2005 through the present. The purpose was to have a record of Robson making calls to victim, Jeffrey Epstein and the frequency of calls. The request was submitted to the State Attorney's Office. Investigation Continues.... HAKHAKA AA RAR HER EES AEREERE NARRATIVE $6 RFRA REEAR EER ER ERE REE NA Reported By: KRAUEL, CURTIS D. 10/06/05 Entered By.: ALTOMARO, NICKIE A. 10/06/05 On or about September 23, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. Williams had been previously notified to assist in trash pulls at the residence of Jeffrey Epstein, 358 El Brillo, Palm Beach, Plorida. I observed Williams enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the back of an empty sanitation truck. I then followed Williams to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There Was a total of 4 white im color plastic bags and each contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about September 26, 2005 at approximately 0900 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jessie Jones. Jones had been previously notified to assist in trash pulls at the residence of Jeffrey Epstein, 358 El Brillo, Palm Beach, Florida. I observed Jones enter the driveway of 358 El Brillo, where no trash was located within the receptacles. I left the area without incident GIUFFRE005638 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page622 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 26 Incident Report Program: CMS301L Case No. . .. : 1+05-000368 (Continued) } and notified Det. Recarey to that affect. ! On or about September 27, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jesse { Jones, TI observed Jones enter the driveway of 358 El Brillo and I remove one plastic bag of trash and place it in the back of an empty i sanitation truck. > | I then followed Jones to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 1 white in color plastic bag which contained correspondence | for 358 El Brillo. All documents of evidentiary value were removed ' and turned over to Det. Recarey for follow-up. On or about Monday October 3, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker deff Williams. I observed Williams enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the back of an empty sanitation truck. I then followed Williams to a predetermined location and seized the trash from the truck, The trash was transported to the Palm Beach f Police Department where I began sifting through its contents. There } was a total of 7 white in color plastic bags with a red tie and 1 i black in color bag which contained 2 white in color plastic bags with a red tie, Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. Inside of one of the white in color bags, I located a broken piece of a hard plastic or clear acrylic stick, which was shaped with small ridges. This | device is commonly used as a sexual toy which is inserted into the vagina or anus for stimulation. This item, along with all documents | of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about Tuesday October 4, 2005 at approximately 0928 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. I observed Williams enter the driveway of 358.El Brillo and remove several plastic bags of trash and place the contents into the side well of the sanitation truck. This side of the truck is separate from the rear of the truck and does not come into contact with other trash. I then followed Williams to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 2 white in color plastic bags which were tied at the top. Each of the bags contained documentation and correspondence for 358 B1 Brillo and Jeffrey Epstein. All documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about Wednesday October 5, 2005 at approximately 0928 hours, I GIUFFRE005639 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page623 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 27 Time: 68:47:53 Incident Report Program: CMS301L Case No. . - . : 1-05-000368 (Continued) responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. I observed Williams enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the bed of the sanitation truck. I then followed Williams to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents, with the assistance of Det. Recarey. There were a total of 2 bags, one of which was white in color and tied in a knot at the top, and the other was a black in color bag, which contained two white in color trash bags along with loose debris. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. FeekeeEAAARA EAA AR SEE ES EEEH N A RRA TIVE BO] BERR HERA RHR EER RR RRR RRR ERE NA Reported By: RECAREY, JOSEPH 10/07/05 Entered By.: ALTOMARO, NICKIE A. 10/07/05 I met with Det. Kravel and requested further assistance to maintain trash collections at Epstein's residence at 358 El Brillo Road. on October 3, 2005, at approximately 10:30 am, I was contacted by Sgt. Frick to respond to the’ Palm Beach Police Station. Det. Krauel had observed Jeff Epstein riding his bicycle on South County Road. Upon my arrival, I met wit 0 advised, as Epstein was currently in Town; we interview as to her involvement with Epstein and the girls that are brought to his house. As we were to interview n the county, (outside of our jurisdiction), I contacted the ate torney s Office Investigation Division, and made contact with Assistant Supervisor Investigator Carlos Ortiz. I requested assistance to interview jas the interview may occur in the county. Supervisor Ortiz assigned Investigator Mike Waites to assist us at the location and interview of Det. Dicks had responded to the address of a: viewed her vehicle parked in the driveway, [MMs venicie a red Plymouth Neon was parked in the driveway of =a n Loxahatchee. gt Frick and I responded to 120th Ave an awaited the arrival of Investigator Mike Waites. Upon his arrival, he was briefed that should she wish to be interviewed within her home he would be needed. However, should §MMsree to return to the police station for further questioning, he would not be need . Frick and I knocked on the door and met with s told that’ we were investigati aoclaim involving Jeffrey Epstein of El Brillo in Palm Beach. a. asked if she wanted to accompany us back to the police station for further questioning. She was also told that at the conclusion of the interview she would be returned home. She agreed and wished to change her clothes prior to accompanying us back to the police station. At the conclusion of her changing clothes, she advised she was ready to go. I thanked Inv. Waites and advised she was going to voluntarily return to the police station. GIUFFRE005640 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page624 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT 6:47:53 Incident Report Case No. .. . : 1-05-000368 (Continued) Upon 7. entry in the unmarked Detective vehicle, I placed a tape recorder within the vehicle to record any conversations within the vehicle. During the ride back to the police station, dvised she is attending Palm Beach Community College at the Palm Beach Gardens Campus and is majoring in journalism. Upon our arrival at the police station, was broug} he Pi Bi interview room in the Detective Bureau. I explained to that <I appreciated her willingness to assist us and informed her that should she desire to leave at any time she may do so. I further lained the interview room door is only closed for priva tated she understood. During the taped swo: i iew, as asked how she came in contact with Epstein {en back when she turned 17 years of age she was approache a Iriend lin the Canopy Beach Resort in Rivera Beach. a: asked ir sme wanted to make money. She was told she would have to provide a massage and should make $200.00. thought about the offer_and agreed to meet with Jeffrey. Unknown last name) and (Unknown last name) picked her up and she was taken to Epstein's house. Upon her arrival at the house, she was introduced to Epstein in the’ kitchen of the house. She was also.introduced to a white female known to her as Sara. She was led upstairs to the main bedroom known to her as Jeff Epstein s bedroom. Sara arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed. Sara then left the room and informed her Jeff would be in a minute. Jeff entered the bedroom wearing only a towt lay on the table onto his stomach d massage oil foe mig 3 rub on him. During the noscace, miami S 2255° He tried to touch me and I stopped him. I asked how he tried to touch her. He } grabbed her buttocks and she felt uncomfortable. [RP so Epstein has a vibrator, which is large and white in color. told Epstein, I'll massage you but I don't want to be touchea stated she performed ‘3: maked. At the conclusion of the massage, Epstein paid $200.00 for the massage. He explained, I know you re not comfortable, but I'll uu if you bring some girls, He told her the younger the better. stated she once tried to bring 23-vear-old female and Epstein stated that the female was too old was asked how many girls she brought in total to Epstein, eq six that she can remember. tated she brought and the Victim in this case. I asked hich one was the youngest. (RBBBMMBRdvised the victim was the youngest. stated every girl she brought knew what to expect when they arrived. They were told they would provide a massage, possibly naked, and some touching. I asked her if the victim was aware. She stated every girl she brought knew what to expect. She explained she knew the victim wanted to make money. She approached the victim and explained about going to work for Jeff, The GIUFFRE005641 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page625 of 883 Date 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 29 Time: 8:47 Incident Report Program: CMS301L Case No. . , . : 1-05-000368 (Continued) victim agreed and arrangements were made to bring the vic Epstein'’s house on a we ated that she and (later identified as picked up the victim at the victim s house. They traveled to Epstein's House and entered through the kitchen door. They met with the house chef and Epstein s assistant Sara. The victim was introduced to Epstein while they were in the kitchen area. Sara led the victim upstairs and Epstein went upstairs. When_the massage was over, the victim returned to the kitchen area. tated she was paid $200.00 for bring the victim to Epstein's. stated the victim _told her she was paid $300.00 for the massage. Back in the vehicle, QMMMfasked the victim what happened. The victim told her about the massage and then they went shopping. Ra sated the victim was the last person she brought to Epstein. She ther stated that she had changed her cellular number to avoid being contacted by Sara. She continued that when Epstein tant that he is traveling to Palm Beach, Sara announces to would contact © arrange girls for PE Sarah, later identified as Sarah Kellen Date of Birth had told ae: Jeff likes to have his fun with the girls. Ms ated that once her parents discovered that she was visiting a. they disapproved of the encounters with him and she stopped. ee S2- stated that Sara still tries to call the house ae leaves messages. With ee assistance of we were abl. identif: f587, i988. me: DOB DOB Sgt Frick entered the room and tl that based on her own statements, she had implicated herself with bringing underage girls to Epstein's house. = aware of what she had stated and wished to assist further in hopes to receive a lesser charge. provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she ovided possible addresses and areas in which they lived. As s being taken home in the vehicle, a tape recorder was placed nm the vehicle to record any ations within the vehicle. During the drive back to her home, ade the comment I m like a Heidi Pliess, (Hollywood Madam who sent girls to clients for sexual favors in California). [Eves dropped off at her house without incident. Sgt Frick and I went to atchee, Florida in an a speak with . We met with Mrs. ees Mother) at t locor. We explained the ongoing investigation and felt that may have additional information as we had information that she had worked for Jeff. Mrs. (itt coduced us to her husband and 2 niin” hi We sat in the dinning room and met with am 588. As she was under the age of eighteen, Mrs. was advised we would be speaking with her. She expressed, if her daug! she wanted to assist. As we interviewed she denied having any inappropriate encounters with Jeff (Epstein), She stated she had gone to Jeff s GIUFFRE005642 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page626 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 30 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) House with Haley Robson approximately eight months ago and sat in the kitchen with the house chef but nothing happened. As the parents were present during the interview, we felt that was withholding information from us, She made several comments as to she has put the entire incident behind her. I left my direct telephone number and advised should she wish to speak with me again to telephone me. Sgt Frick and I thanked Mrs. a her time and left the area. She stated she would ask her again after s to what happened ad my telephone at Epstein s house. I informed her that number and hopefully she would call. Sgt Frick and I then attempted contact with al a. Loxahatchee. We met with who stated was her daughter. [was at the wellington Mal. =_ not home. We explained the ongoing investigation and felt the may have additional information as we had information that she had worked for Jeff. We left our phone numbers and asked her to telephone me upon her daughter's return. We then left the area. On October 4, 2005, at app: i 705 am, Sgt Frick had retrieved a voice mail message from rel She stated she had spoken with her daughter and ation as to what occurred at Jeff s house. I contacted who stated her daughter was in the shower at the moment and would be traveling back to Orlando to attend College. I informed her I would be en route to her home in co Det. Dawson and I drove to the home and met wi and During a sworn taped statement, stated she was taken to the house by Haley Robson. She was to. she could make money working ‘=: She was told she would have to provide a massage to Jeff. stated upon her arrival to the house she was brought to the kitchen area by Robson. They met with the house chef and Haley stayed in the kitchen. She was introduced to Sara, Jeff's assistant and was brought upstairs to the Mater bedroom. Sara prepared the room and massage table for a massage. Epstein entered the room and she provided a massage. i stated she kept her clothes on during the massage. She stated sometime during the massage Epstein grabbed her buttocks and pulled her close to him. said she was wierded out by the incident involving Jeff. At the conclusion_of the massage, she was paid $200.00 for the massage. I asked QMMMJif she has any formal training in massages to which she replied no. I asked her if Robson received any monies for taking her to perform the sm WM stated Robson also received money for taking hi a. stated she went with Robson and another girl, to Je: s house once. stated she waited in the kitchen with Robson, while Mas taken upstairs by Sara. stated she only did the massage once, as she was wierded out by tne whole experience. At the conclusion of the interview and the tape was stopped, I was informed that Sara had attempted to reach ii 3 cell phone. A voice mail message on October 4, 2005 at 10:55 am, revealed a female voice who identified herself as Sara who requested her to call her back reference the GIUFFRE005643 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page627 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page 31 Time: 2:47:53 Incident Report Program: CMS301L Case No, .» » ? 1-05-000368 (Continued) police questioning. This voice mail message was recorded onto a micro cassette rovided the incoming telephone number as stated she j ntly co) 6 ox the police investigation because had calle er to te. Sq about how she just received a rental car from Jefi Epstein had called her to tell her that she was given Silver Nissan Sentra, to utilize to visit family and visit Jeff. WMMMMMJ2sked ber what was going on att use that the police would be asking questions. MMMMNS:atca mel: called Jeff and Sara and asked what was going on reference @ ongoing police investigation. According to Sara has since then been trying to contact her to ask about the police questions. _ I instructe ot to contact Sara and do not provide any more information to las she would notify Jeff Epstein and Sara what was transpiring. Investigation Continues... FRRKEAAEREHEAERASENERSEREVER ND RRATIVE FE Q FAHERREREARAE RARER ARERR NA Reported By: LEE, LA'MONT 10/07/05 Entered By.: ALTOMARO, NICKIE A. 10/07/05 On March 30, 2005, I was asked by Sgt. Daniel Szarszewski to begin conducting surveillance and trash pulls reference Detective Pagan conducting a criminal investigation involving Jeffrey Epstein. I was advised that Epstein was possibly engaging in sexual contact with young females. On March 30, 2005, I made contact with Town of Palm Beach Sanitation Office Supervisor Tony Higgins and requested trash pulls for 358 El Brillo Way to begin on March 31, 2005. On March 31, 2005 at 9:20 a.m., I responded to the area of 358 El Brillo Way and met with Town of Palm Beach sanitation employee, Jeffrey Williams. I observed Williams enter the driveway of 358 El Brillo Way, collect the trash bags from Epstein's property and place the contents into an empty sanitation truck. I followed Williams to a nearby area, were he turned over seventeen white plastic trash bags, which were collected from Epstein's property. 4 I took the trash bags to the sanitation department were I sifted through its contents. I collected mail correspondence from Armani Exchange addressed to Nada Marcinkova, Jeffrey BE. Epstein notepaper with an important me xr addressed to J.B dated 03/29/05 at 5 p.m. reference U.S Airways boarding pass copy for passenger, Janusz Banasiak, Montgomery County, Maryland Health Department food service ID for Janusz Banasiak and Ghislaine Maxwell notepaper with names and phone numbers. Photocopies of the trash collected were attached with the supplement. Detective Pagan was advised of the contents that were collected for evidentiary value. GIUFFRE005644 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page628 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Case No. . - . : 1-05-000368 (Continued) On March 31, 2005, Sgt. Daniel Szarszewski requested that I set up a surveillance vehicle on El Brillo Way and conduct video surveillance of the front exterior of Epstein's residence. At 3:00 p.m., I set up a surveillance vehicle equipped with a video monitoring device. The surveillance vehicle was parked on El Brillo Way approximately fifty feet east of Epstein's driveway. The purpose of the video surveillance was to gather investigative intelligence by monitoring and recording all vehicle and pedestrian traffic entering and leaving Epstein's property. The video surveillance tapes were changed daily with a new Maxell T-160 VHS tape. Video surveillance was established for Epstein s from March 31, 2005 through April 05, 2005. On April 05, 2005, video surveillance was concluded. I reviewed the video tapes and advised Detective Pagan the surveillance videos yielded no evidentiary value, On April 01, 2005 at 9:30 a.m., I responded to the area of 358 El Brillo Way to meet with Town of Palm Beach sanitation employee, Jessie Jones. While parked in the area of 358 El Brillo Way waiting to collect Epstein s trash, I observed a white female, who I recognized as Nada Marcinkova from her Florida driver's license photograph. I made no contact with Marcinkova. While parked in the area, I also observed Epstein s GMC Yukon truck leave the property as well as other vehicles arrive and park across the street from the property. The occupants of these vehicles appeared to be housekeepers, maintenance men, and gardeners. At 9:38 a.m., I met with Town of Palm Beach sanitation employee, Jessie Jones. I observed Jones enter the driveway of 358 El Brillo Way and collect the trash from Epstein s property. I followed Jessie to a predetermined area at which time I collected the trash bags from the sanitation truck, I transported the trash bags to the sanitation department, where I sifted through its contents. I collected mail correspondences addressed to Jeffrey Epstein, automotive records and personal documents for Janusz Banasiak and Beata Banasiak as well as Jeffrey Epste japer with the names and appointment times for id No last names or other personal information was written on the notepaper. While sifting through Epstein s trash, I also collected a three-inch purple finger size object, which had a broken end. The object appeared to be a broke piece from a sexual toy similar to a (Cyclone Vibrator) possibly used for rectal gratification. The sexual object was photographed for Detective Pagan, packaged in a biohazard evidence bag (possible body fluids) and secured as investigative evidence. All items collected from Epstein s trash were turned over to Detective Pagan for evidentiary purposes. On April 05, 2005 at 9:18 a.m., I met with Town of Palm Beach sanitation employee, Jessie Jones. I observed Jones enter the driveway of 358 El Brillo Way and collect the trash from Epstein s property. TI followed Jessie to a predetermined area at which time I GIUFFRE005645 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page629 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: Tim 8:47:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) collected the trash bags from the sanitation truck. I. transported the trash bags to the sanitation department, where I sifted through its contents. I collected mail correspondences addressed to Jeffrey Epstein as well as notepaper (Important Message) with names and telephone numbers. The following are items collected from Epstein s trash. aADeT blank piece of white black paper black paper David The following items were documented for Detective Pagan s investigation for evidentiary purposes. MSN Hotmail On April 96, 08, 11, 12, 13, 15, 2005, at approximately 9:30 a.m, I met with Town of Palm Beach sanitation employees. I observed the employee enter the driveway of 358 El Brillo Way and collect the trash from Epstein's property. I followed the employee to a predetermined area at which time I collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. All of the documents collected from Epstein's trash during my assistance were turned over to Detective Pagan for evidentiary | purposes. On June 14, 2005, Detective Michelle Pagan contacted me and advised that the airplane belonging to Jeffrey Epstein of 358 El Brillo Way was parked at the Palm Beach International Airport. i Detective Pagan requested that I begin trash pulls for the purpose of gathering evidence and intelligence. I made contact with Town of Palm Beach Sanitation Office Supervisor Tony Higgins and requested trash pulls for 358 El Brillo Way to begin om June 15, 2005. On dune 15, 2005, I met with a sanitation employee. I observed the employee enter the driveway of 358 El Brillo Way and collect the trash from Epstein s property. I followed the employee to a predetermined area at which time. I collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents, The trash yielded negative results and no evidence was collected. No further trash was collected throughout the week due to the fact that Epstein s security gates remained closed throughout the week; therefore, the sanitation employees were unable to gain access onto the property for collection of the trash. GIUFFRE005646 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page630 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Incident Report Casé No. . . . : 1-05-000368 (Continued) All evidence and intelligence gathered by this officer has been turned over to the detective bureau and no further action has been taken by this officer. End of supplement. FRaREAK KAR AA KAR RAREAE RAKE]. NARRATIVE HQ KREKEREERARREE SERRE EEE NA Reported By: RECAREY, JOSEPH 10/07/05 Entered By.: ALTOMARO, NICKIE A. 10/10/05 On October 4, 2005, T made telephone contact EE who had left several messages on voice mail. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She further advised she did not-want to speak of this incident in front of her mot. t approximately 15:48 pm, I made telephone contact with Jat During a taped recorded statement, stated the following: Approximately a year ago, when she was sixteen years of age, Robson took her to Jeff's house twice. The first time she went, Haley Robson drove to the house. They entered through the kitchen area where she was introduced to Sara and Jeff. She was taken upstairs to a bedroom by Sara who set the room up with a massage bed and brought cut the oils to use. Jeff then entered the ve ing a towel. He lay on the table and picked out a lotion <r ill rub on hil At one point during the massage, he tried to remove her shirt ‘hid she became very upset and discontinued the massage. Both nd Jeffrey had a verbal disagreement at which time she left without being paid. She met with on who was sitting in the kitchen and told , advised she received no money for that day. jalso Said that Haley Robson had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the more you do the more you are paid. Several weeks later, MD advised she agreed to be taken a second time by Haley Robson. Once they arrived at the residence, Haley sat in the kitchen and Sara took her upstairs to the master bedroom again. Sara set the room up with a massage bed and brought out the oils to use. Jeff then entered the ro we ing a towel. He lay on the table and picked out a lotion for a, . rub on him. At_one point during the massage, he tried to touch her buttocks. | EE === wearing tight jeans and had a tight belt on Jeff was @ to touch her buttocks. Jeff then rolled ck during the massage; he attempted to touch her breasts. hen became upset again and told him she didn't want to be touched. discontinued the Massage and was paid $200.00. then went downstairs where Haley Robson was waiting for her. She told Robson she w leave. [RRBBBBMMMkaic she never ret e. stated she 1s aware that her friend, was e house and had a problem with Jeff. She provided a telephone number GIUFFRE005647 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page631 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 35 } Time: 9:47:53 Incident Report Program: CMS301L met erste Oo is Les ape eens een menaone conan ncaheneeesasuenccnnsasaneqecnane = | Case No. 1-05-000368 (Continued) for [MMM «The interview was concluded and the micro cassettes were turn in as evidence. On Octob researched the incoming telephone had left la message. The telephone number, was assigned to ATT/Cingular Cellular service. I prepared a subpoena request and faxed the request to the State Attorney s Office. | Information requested was subscriber information as well as all incoming and outgoing calls for the months of September and October 2005, I later researched nd discovered she resides in Royal Palm Beach. Det. Dawson and I Beach and met with j t her residence} in Royal Palm Beach, j greed to speak with us in the kitchen area. During a sworn tape | stated the following: On or about November 2004, she was approached by Haley Robson and asked if she wanted to make money, She agreed and was told she would provide a massage to wealthy man in Palm Beach, Robson picked her up and drove her to a house in Palm Beach. She was brought into the kite: house. she further stated that a =: went with them. They were brought into the kitchen where she was introduced to Jeff and other females. stated she was introduced to a helper of Jeff; the female was described as white | female (unknown name), with blond hair. She stated that the assistant | was familiar with Robson. The. assist up the massage table and put out lotions to be used. She cold ill == would available in a minute. Jeff entered the room wearing only a towel. Jeff lay on the massage table and picked a lotion to rub on his thighs and back. MN cute stated that during the massage Jeff asked her = her clothes. She complied and removed her pants and blouse. my didn't remember if she had removed her bra but feels that she did. was certain that she stayed in her thong underwear. continued the massage and at one point she straddled him to massage his back, which touched his buttocks with hers. as instructed to return_to the ground at which time Jeff turne O have his chest rubbed. it was at this time she is sure he was masturbating. id not want to look at his penis area because she was €, Jeff removed a large white vibrator and turned it on. tated he began rubbing the vibrator over her thong underwear on her vaginal area. Shortly thereafter, Jeff ejaculated and removed himself from the table. He walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her direct view. When I asked how old she was when this occurred, she stated she had just turned seventeen. At the conclusion of the shower, | was paid either $350.00 or $400.00. She stated she wasn't sure, ss it was close to $400.00. At the conclusion of the interview, istated she never returned to provide a massage for Jeff. She advised she was ashamed and uncomfortable with the situation. GIUFFRE005648 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page632 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 36 1:47:53 Incident Report Program: CMS3011L Case No. . . . : 1-05-000368 : Continued Det. Dawson and I then left the area and responded to the| (MM igh School where Robson and all the above-mentioned girls na attended. I met with School Police Officer, Off Williams. I ined I was looking for a previo o attended xy High School. I inquired about I further explained that I was working a case in which most of the girls I have interviewed are either witnesses or victims and felt that = be e one. as well. Officer liams researched his previous st’ cords and found aaa She attended the same year and graduated in the s as the other girls. I was provided the last known address of At approximate: : nm and I met with her recisence, Alimama’. “2:,."2aa5 sesetet only seventeen years of age, I had notified her mother, Mrs. =a that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I the possibility o£ her being either a witness or victim. Mrs. dvised she wanted| O cooperate and consented to the interview. During a sworn taped statenent , stated the following: at the age of sixteen, during the mont September 2004, she was approached by Haley Robson for a chance to make money. § friends with the friends of Robson and knew the same people. had been previously told by her fri what Robson did for Jerr. Robson called a person known to as Sara and scheduled the appointment. Robson picke up and drove her to Palm Beach to a street called Brillo Way. rove to the end of the street and entered a large driveway They entered the kitchen area of the house and met with Jeff. fas introduced to Jeff. Robson led ME} steics to the main bedroom area and set up the room with a massage le and set out the oils. Robson dimmed the lights and turned on soft music, Robson exited the room and Jeff entered the room wearing only a towel. Jeff picked oils and instructed her to rub his'legs, under h ocks, back and chest area. Jeff asked her to get comfortable. vised she did not remove her clothes. She was wearing tight Jeans and a cropped tank top exposin: elly area. During the massage, Jeff removed his towel. As rubbed his chest area, Jeff attempted to reach down her pants hh the and a tight belt. vised Jeff began to masturbate as she rubbed his chest. loaned as she rubbed his chest. She observed he was continuing to © and attempted to reach up her tank top and touch her bressce. fill 274 back and Jeff stopped. However, he kept masturbating unti © climaxed,. ed himself with the towel he was previously wearing. I asked if she knew the difference between circumcised and not ¢j ised. She explained she knew and advised Jeff was circumcised. a paid $200.00 for the massage and left the area. She met witn Ropson who was waiting in the kitchen area and left the house. HE chen explained she never provided anot: eff. She did however, go to the house with Robson and as they buttocks area, a unable to due to the tightness of the jeans GIUFFRE005649 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page633 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 8:47:53 Incident Report Program: CMS301 Case No. . . . + 1-05-000368 (Continued) took another friend of Robson's. sed she was present when rent to work for Jeff. She advised she iat er and sat in the kitchen area wi it for Misc: that while they waited ot chet prepared lunch for them, as it was almost lunchtime. was finished with the massage, they left the area. I asked if Robson a: what would be expected of her when she provided a massage. stated yes, Robson told her that a massage would be expected possibly naked and possibly some touching involved. has no formal training in providing massages. Mae...- about a third and last time she went to Jeff's house. Robson drove another girl, who is friend, to Jeff's house. (§MBBMsctated she knew that Robson hi € money providing girls for Jeff and she wanted to do the s x jon took them in the kitchen a: ¢ house and introduced to Sara. Robson and Sara cook gm 2°25. to the main bedroom. advised she doesn t know wi appened as did not spe: out what happened in the room. eceived $100 Robson for going with her to Jeff s house and ee as unable to remember Ms telephone number. The interview was concluded and we left the area. Investigation Continues... Phe REAR EAERE EERE RAE REERERE NARRATIVE HOLD FARRER RAR Ra a Rae NA Reported By: RECAREY, JOSEPH 10/03/05 Entered By.: ALTOMARO, NICKIE A. 10/10/05 On October 6, 2005, Det. Dawson and I went to Lynn University located in Boca Raton. We met with Dean of Students, Paul Turner. I explained to Mr. Turner that we were investigating a crime within the Town of Palm Beach and felt that a student, =a may have information. Turner confirmed that is a student and currently on the soccer team for Lynn University, he was in computer class at the time of our arrival. Turner sent a security guard to locate in class ‘ia < her to the office. .Mr. Turner allowed us to interview jin an empty conference room. At 11:45 am I met wi iT oc explained to her why we there to interview her. She advised she was aware of the ongoing i tigation. MBBBMMMstated she had previously spoken with hho told her she was interviewed by detectives. During a sworn taped statement || ed she knew that Haley Robson worked for Jeff in Palm Beach. advised she has been there many times for massages. d her if she had fo aining in providing Massages, mcs she did not. vised she was told what was expected of her by providing massages and would have to remove clothing but if she fel ortable just to say so and Jeff would stop pushing the issue. began providing massages and advised she kept her clothes on. She considered Jeff a pervert who kept GIUFFRE005650 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page634 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:4 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) pushing to go further and further. xplained she would keep telling him she had a boyfriend and t would not be right to her boyfriend. It wasn t until recently §MJadmitted to removing her and staying in her thong underwear to provide a massage. xplained Jeff wanted to be rubbed on his back and recently he began turning over to have her rub his chest as he mastu; He would try to touch her breasts as she rubbed his chest. tated, Jeff would try to get away with more and more on each massage. micinally, Robson drove her to the house for the original massage. left Sara her cell phone number and every time Jeff would come into town, Sara would call her for an appointment. Each time she went, Sara would meet her at the kitchen doo; She would bring her upstairs and prepare the massage table. fbi. «35-5 deff would ask her questions about herself. He knew shy soccer player and would be attending Lynn University. I asked f£ he knew her real | age MBM stated Jeff didn t care. The most recent massage she ' provided was on October 1, 2005. During the massage she asked Jeff if she could borrow one of his vehicles to visit her family and boyfriend in Orlando. Jeff had told she could borrow one of his vehicles but later stated he would rent her a car, She continued with the massage as Jt bed her buttocks and caressed the buttocks cheeks. I aoe a? she was wearing undergarments to which she replied her thong underwear. Once he tried t wich her breasts she would pull away from him an ld stop. a: ed if he ever used a vibrator on her. lwas aware of the vibrator but advised she never -would allow him to use the vibrator on her. She described the vibrator as a large white vibrator with a huge head on the tip of the vibrator, She stated he kept the vibrator in a closet near the massage table. (MRcvised she had been doing the massage for \ approximately two years, which meant she would have started doing massages for Jeff at the age of sixteen. MM 2223 she was contacted by Sara on October 3, 2005. Sara had informed her that Jeff had rented her a new Nissan Sentra and she should come by the house t it up. Sara informed he would have the car for a month. tated Jeff knew her car was not working properly and had missed appointments in the past because of her car being inoperable. xplained the car is currently parked next to field. I asked he: ook any one to the | house. ii ined she ‘ii a friend of hers who { has returned to Orlando to attend Llege. asked she ever allowed another female in the room. dvised no one was brought into the | room with her. At the conclusion of the interview, Det. Dawson and I | went to the Gym area and located the Silver Nissan Sentra bearing Florida tag X98-APM. The vehicle is registered to Dollar rent a car out of the Palm Beach International Airport. tact was made with aaa) the victim's mother, at I explained to her that I was following up on this case and provided a complete update on the case. Investigation Continues. GIUFFRE005651 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page635 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 39 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) RHHKEARKRAR RRR AAERR ARERR NARRATIVE BOLL ARKH R RAKE RRR REE REE EN ES NA Reported By: RECAREY, JOSEPH 10/21/05 Entered By.: ALTOMARO, NICKIE A. 10/21/05 On October 1 oximately 2:30 p.m., I made telephone contact with During a taped conversation, a told of an ongoing investigatio: ich I felt she had information pertaining to Jeffrey Epstein, wa ns she met Ep) i just sixteen years of age. She was approached al tend who also had previously gone to Epstein's house Massages. dv: as working at the Wellington Mall when she was approached. told her that she would have to provide sage to Epstein and she would have to perform this massage naked. | ened about the offer and stated she could make $200.00 for mutes of work. She agreed to perform the massage and mnie: the appointment for her that same day. HE cen was a weekend as she only worked at the mall on the weekends. took her to the house where she was introduced to Sara, J assistant, Sara took her upstairs to a master bedroom. explained that as she was walking up the stairs she observed several on of naked women along the walls and tables of the house. further explained that she was brought into the bedroom -where ara prepared the room by setting up the massage table and provided the oils for her to rub on Epstein. Epstein entered the room and introduce iaaiiaiag * Epstein lay on the table and told her to get comfortable. jould ember if he was naked or if he entered the room with a towel. tated she provided thé massage wearing only her panties. She continued rubbing his legs, thighs and fect MM Svisec he turned over onto his back. She continued to rub his legs wi the oils. Epstein touched her breasts and began to masturbate. TI ai if she knew what circumcised and un-circumcised meant. tated circumcised the penis has no foreskin and_the hea penis is oe said Epstein is circumcised. §Mbegan to cry on the telephone an stated she had been to his house hundreds of times over a two-year period. miss to have made thousands of dollars during her visits. jstated she could not remember how many times exactly she went to Epstein's heme but said it was a lot. became more upset; erying hysterically and stated she was paid and instructed to have sex with Epstein's assistant, Nada Marcinkova by Epstein. Epstein continued to watch them have sex and masturbated himself as they had sex with each other. She further stated that things escalated further and further. Epstein used toys such as vibrators, rubber penises and strap-on penises on aces teene ly, See cetes he performed oral sex on her numerous times, She claimed he (Epstein) put his fingers inside her vagina while he masturbated in an attempt to make her climax. could not continue and wanted some time to regain her composure. I explained tollllco take her time. After taking several minutes to regain her composure I GIUFFRE005652 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page636 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 40 8:47:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) explained that I would travel to meet with her in person as I felt she had additional information to provide t with Sgt. Frick and explained the importance to meet vite iS person. Sgt. Frick agreed and made arraignments for Det. Dawson and I to meet with in Jacksonville, Florida. 005, at 4:10 p.m_. Det. Dawson and I met wit a her re -.- in Jacksonville, Florida. ted to have present for support. I explained to her that I did not em as long as she wanted (BEEP resent during the int tated she wanted her present. I explained that as S present she was not allowed to comment or_ask any questions during the interview. She was only there to comfort jhould the interview upset her. During a sworn taped statement , Mp 1ainea how everything began. She said she was brought through the kitchen area where she met Sara for t tt time. She was led to the master bedroom, Epstein s room ‘ee es that as she was walking up the stairs she observed several photographs of naked women along the walls and tables of the house. Mm coches explained that she was brought into the bedroom, where Sara prepared the room by setting up the massage table and provided the oils for her to rub on Epstein. xplained she remembered the steam room area, which contained two large showers. stein entered the room from the steam room area and introduced 1f. Epstein lay on the table and told her to get comfortable. emoved her skirt and kept her shirt on. She could not remember if ne was naked or if he entered th: with a towel. Epstein then instructed her to remove her shirt. joved her shirt and remembered she was not wearing a bra. tated she provided the massage wearing = panties. She continued rubbing his legs, thighs and feet, dvised he turned over onto his back. She continued to rub his legs with the oils. Epstein touched her breasts and began to masturbate. Epstein ejaculate meant the massage was over. At the conclusion of the massage 00.00. They walk ether downstairs where Sara and/ ere waiting. ‘is: eceived an unknown amount of money for taking her to Epstein. Epstein instructed to leave her cellular telephone number so that he could contact her when he is in town. HM. oeinca that she continued to go to Epstein s house and became @ regular at the house. She could not provide an exact number but claimed she had been their hundreds of times. She claimed sexual activities did not occur every time she was th There were times she went to dinners and parties with Epstein. xplained that things began to escalate more than the massage. The encounters included bringing in his assistant, Nada Marcinkova. xplained Epstein had purchased her from her family in Yugoslavia. Epstein bragged he, her inte the United States to be his Yugoslavian sex slave. dvised he was naked in the bedroom, she entered and removed her clothing. Marcinkova d the room from the steam room area already naked. He instructe: to perform oral sex on GIUFFRE005653 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page637 of 883 Date: 2/35/08 PALM BEACH POLICE DEPARTMENT Page: 41 Time: 8:4 Incident Report Program: CMS301L Case No... . : 368 (Continued) Marcinkova . efused to perform that act. Epstein offered her an additional 0 for her to perform oral sex on Marcinkova for i i greed to perform the oral sex for the additional ained that Epstein would masturbate while he watched them perform sexual acts. Things continued to escalate by purchasing sex toys. MEBMMMtated she had massagers, vibrators and strap on rubber penises used on her. Each time somet! w was introduced additional i were produced and offered <a allow the acts to happen. as adamant that she performs all these acts but there was an understanding Epstein that no vaginal penetration would occur with his penis. explained that Epstein's penis was deformed. [§Mxolained that his penis was oval shaped. She claimed when Epstein's penis was erect, it was thick toward the bottom but was thin and small toward the head portion. She called it egg-shaped. H- otinued that a encounters with Marcinkova, Epstein and her became a ritual. ould arrive at the house iia. herself upstairs, where Marcinkova and Epstein were waitd ould remove her clothing and join them on the bed. Mlle inkova and she would begin by kissing and touching each other. explained sex toys were brought into the bed by either Epstein or Marcinkova and they would begin using the toys on each other. Epstein would perform oral sex person depending who was on top during the intercourse. ee revealed they were in a missionary position. MMB <<< one day, HS .2: unable to state and exact date when 8 incident occurred), she came to the house after Sara had informed her that Epstein had arrived, She arrived at the house and went upstairs to the master bedroom. (§MRdvised she immediately removed her clothing, as Nada Marcinkova and Epstein were already naked in the bedroom. lained that Nada Marcinkova and she had a sexual encounter to include kissing, touching and oral sex, remembered that she climaxed and was removing her self from the massage table. jasked for a sheet of paper and drew the massage table in the masts: feo" and where Epstein, Marcinkova and she were. Epstein turned jon to her = on the massage bed and inserted his penis into ina. stated Epstein began to pump his penis in her vagina. Ailf=cane upset over this. She said her head was being held against the bed forcibly, as he continued to pump inside her. She screamed no, and Epstein stopped. She told him that she did not want to have his penis inside of her. Epstein apologized for his actions and subsequently paid her a thousand d for that visit. Additionally, shortly thereafter, Epstein a 2005 Doge Neon, blue in color for her personal use. dvised there were times that she was so sore when she left jadvised she was ripped, torn, in her vagina Epstei: se area. dvised she had difficulty walking to the car after leaving the house because she was so sore, Mes that other GIUFFRE005654 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page638 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 42 8:47:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) ; than that one time, when Epstein inserted his penis inside her vagina, i there was no other penile intercourse. ; provided names of girls that she knew of that have gone to tein's house. ME ovicea the name as. feels she still = be {ise to the house to massage Epstein. According to is still sucking his dick." When asked if she had been recently contacted by anyone of the house, wised she received an email from Sara, from ! et, which is her email account. The email was just a he Ow are you doing type of email. There had bee: ther contact from the house. The interview was concluded and left the area. The tapes and drawing were submitted into evidence. Investigation continues.. Sette ee cede eKREREEHEREEA EAE NARRATIVE #12 t#tttttaktateaneesencesnee NA Reported By: RECAREY, JOSEPH 11/01/05 |! Entered By.: ALTOMARO, NICKIE A. 11/07/05 On October 12, 2005, Det. Dawson and I traveled to the Orlando area and made telephone contact with greed to meet with us as we were in the Orlando are ovided directions to her apartment. Det. Dawson and I met with who stated, during a aped statement that nothing happened between her and Epstein. [ nervous during the interview. I assured her had spoken with other people who advised differently. she only went a couple of times and provided a massage was brought to the Epstein house in March of 2005. ie. vor, IE == no formal training in providing ccs: Mosc she provided a massage, fully for $200.00. As I sensed hesitancy in her answers, I asked £ she had been contacted by anyone from the house. Stated she was interviewed already by an investigator for Epstein. He met with her on October 8, 2005, at a Roadhouse in Orlando. He identified himself as Paul an mit the police investigation his telephone one lala additional contact. | rovided no additional inrormation, as it appeared her We left the area and returned to Palm responses were almost scripted. Beach Police Department. Based on the information acquired during the interviews, a search warrant was prepared for entry at the Epstein home. Om October 18, 2005, I met with Judge Laura Johnson who reviewed the warrant request. She found there was sufficient probable cause and signed the warrant request. On October 20, 2005, at approximately 9:36 am, members of the Palm Beach Police Investigations Unit executed the search warrant at 358 El Brillo in Palm Beach. Members of the Investigations Unit included Capt Gudger, Sgt Frick, Det. Dicks, Det. Dawson, Det. Melnichok, Det. Sandman, Det. Krauel, the crime scene unit and myself. GIUFFRE005655 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page639 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT i 8:47:53 Incident Report Case No. . . . : 1-05-000368 (Continued) As we entered onto the property, we encountered the house manager, Janusz Banasiak who was in the guest portion of the house. The guesthouse section had open doors and no forced ent: was made. TI mad w: Banasiak, Date of ot Fl DL and informed him of the search warrant for the premises, The members of the Police Department entered the residence and announced we had a search warrant. A safety search was done and members exited the home. I read the search warrant to Banasiak as Mgr Parkinson videotaped the search warrant execution. Several interior edon the property. I spoke with Mark Zeff, of lew York. Mr. Zeff stated he is the designer for Mr. Epstein's homes. He advised he was contacted in March of 2005 to do a complete overhaul on the house. He advised he was on the phone with Mr. Epstein when officers announced the search warrant, Mr. Epstein was then made aware of the search warrant. Mr. Zeff advised, his contact with Epstein is strictly business and he has never witnessed Epstein with any girls except for his assistants, Sara or Nada. I then interviewed Daniel Estes, of jin New York. Mr. Estes stated he has worked for Zeff for seven years. He advised he personally worked on the New York and Palm Beach home for Mr, | Epstein. He has previously met with Sara and Adrianna, Epstein's assistants in New York and in Florida. Estes stated they travel with { Epstein everywhere he goes. i I interviewed Zara Bailey of De Jersey. Bailey stated she just arrive rom Scotland an S worked with Zeff for only one month. She stated she has never met Epstein and has not ) seen him. The interview was then concluded. | I then spoke with Douglas Schoettle a York City. Schoettle stated he has been Epstein's Architect for seven years. He further stated he deals with Epstein's assistants and Speaks with Epstein on the phone. Schoettle stated he mainly speaks with Sara Kellen, Epstein s main assistant, who travels with Epstein. Schoettle stated he only has contact.with Epstein when his services are needed. At approximately 10:30 am, I was informed that the videotaping was concluded. i entered the residence and located two covert (hidden) cameras. The first camera was a covert wall clock in the garage area. I traced the wire behind the clock and removed the RCA wire and unplugged the camera. The other covert camera was located within a desk clock beside Epstein's desk, I traced the wire behind the clock and unplugged the RCA wire. I could not locate another camera. I then began with the search of the residence for the specified evidence. My search consisted of the second floor. Det. Krauel and I began in the master bedroom area where several items were located. They were GIUFFRE005656 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page640 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: a4 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) marked to be retrieved by the evidence custodian. In the master desk with Epstein's notepad: stein we located a high transcript from High School a Also in the room, /armoire where Ocated a bottle of peach flavored Joy Jelly (Sexual Lubricant). Additionally, there were several photographs of young naked teenage girls within the closet, which was consistent with what the witnesses said. The massage table was also located within the master bedroom. Video tapes were located beside the television, which were also collected. An itemized list of the property and locations was prepared on the property receipts. At approximately 2:55 pm, the house was secured; ‘the exit of the residence was videotaped. Upon our exit of the property, I encountered Atty. Guy Fronstein who advised he was . representing Mr. Epstein. He provided a business card and provided his assistance with the investigation. Due to Hurricane Wilma, which struck South Florida causing massive power outages, the courthouse was closed due to the lack of power, I was previously told that the Chief Judge had extended the filing deadlines due to the hurricane and the Courthouse being closed. On October 27, and 28, 2005 the courthouse was closed and I could not file the search warrant and inventory at the clerk's office. on October 31, 2005, I responded to the courthouse and filed the Paperwork along with an order to seal, signed by Judge Johnson, to deny any release of any paperwork on this case. INV CONTINUES. . RRRRKERRRAREA AREA ARRRAEAEEAAN AD RRA TIVE § 13 tttteesekeeeeeeeeea re eeeen NA Reported By: PARKINSON, GREGORY A. 10/20/05 Entered By.: ALTOMARO, NICKIE A. 11/07/05 On October 20, 2005, at approximately 8:30 a.m., Thursday morning, I was advised by Captain Gudger that a search warrant would be executed and that I was to assemble the Crime Scene Investigative Team and stand by the south side of the building ready to go. I designated Evidence Specialist Annette Badger to handle the inventory return, the documentation of the property receipts and the collection and bagging of the evidence at the scene. I further instructed CSI Kim Pavlik, ID # 8807, to accompany us and perform the role of photographing the scene and the items that may be taken into custody by the affiant, Detective Joseph Recarey, ID # 7915. My responsibility was to go through from the reading of the warrant to the final exit from the residence and perform a video recording of the reading of the warrant, the initial walk through of the residence showing the current condition and then finally a walk through of the residence at the time of the police exit. We started out towards the residence, which was located at 358 Bl Brillo and arrived at approximately 9:33 a.m. The search was conducted, items were collected by Evidence Specialists Badger, GIUFFRE005657 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page641 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Incident Report Case No. . . . : 1-05-000368 (Continued) photographed by CSI Pavlik and then videotaped by myself. The search was concluded at approximately 3:05 p.m. whereupon Detective Recarey and I were the last two officers in the house. Upon securing the residence we met with the gentleman who identified himself to Detective Recarey as the lawyer for the defendant and he was informed that the residence was secured and that copies of the inventory return had been left on the first floor table of the personal assistant's office. Detective Recarey and I returned to Police Headquarters and secured for the day. EWKERARRKRRRRRR REA ERE EAAKKOR NARRATIVE HOLA FARRAR RRR REE RR EE NA Reported By: DAWSON, MICHAEL C. 11/07/05 Entered By.: ALTOMARO, NICKIE A. 11/07/05 On October 20, 2005, I assisted Defective Recarey in the execution of a search warrant at 358 El Brillo Way, Palm Beach, Florida, 33480. Upon the announcement of the search warrant, immediate contact was made with three white males who came out of the house or surrounding structures. Those males were identified as Janusz Banasiak, Daniel Estes, and Mark Zeff. As other members of the police department cleared the home, I kept watch over these three males. Once the house was cleared, those males were turned over to Detective Recarey. Detective Dicks and I were assigned to assist in the search of the main house, the cabana and the servant's quarters. We started in the garage. All areas of the garage were searched to include four vehicles. These vehicles were three black Mercedes Benz cars registered to Jeffrey Epstein. The fourth vehicle was a Harley Davidson motorcycle, green in color, registered to Jeffrey Epstein. Nothing was recovered from the garage. A towel closet and pantry located off the kitchen were searched and yielded negative results. The kitchen was searched and taken into evidence was a phone message book that was located near a house phone. North of the kitchen was an office room which contained a computer. The room had a closet that contained a locked gun locker. The combination was entered by Banasiak in the presence of Sgt. Frick and the safe was opened. Items were taken from the room. See the completed property receipt for a detailed list. A green bathroom located on the first floor was searched and nothing was taken. A closet located just west of the green bathroom was searched. Two Massage tables were located in the closet along with a photo of a mide GIUFFRE005658 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page642 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 46 t 8:47:53 Incident Report Program: CMS301L Case No. . + + 1-05-000368 (Continued) female from the waist up. See the property receipt for details, I searched two bedrooms and their adjoining bathrooms, which were located on the second floor on the East side of the house. In the Northeast bedroom closet I found adult sex toys called Twin Torpedoes. Soap made in the shape of a penis and vagina were also found in these upstair bedrooms. See the property receipt for details. I searched the pool cabana located on the South side of the pool. Photos were taken from the wall. See the property receipt for details. I assisted in the search of Banasiak's living quarters. Numerous CD s along with a message book was seized. See the property receipt for details. Kkkkhkhhetkekeekereeeeeeteee NARRATIVE OLS RARER RRR eR ee NA Reported By: RECAREY, JOSEPH 11/08/05 | Entered By.: ALTOMARO, NICKIE A. 11/08/05 On November 1, 2005, I was contacted by Atty. Gus Fronstin, who advised he was willing to assist with the investigation. Atty. Fronstin advised he would try to have his client, Jeffrey Epstein available to be interviewed. I explained I would be interested in conducting an interview with his client as well as other employees that are employed within the house. Atty. Fronstin advised he would return my call once he received confirmation on the interviews, On November 6, 2005, I attempted contact with a her residence. I left a business card for her to r . Upon returni he lice department, I had received a telephone call from I returned her call at ae: spoke | with he made arrangements to resp tion to provide an interview. At approximately 3:30 pm, she arrived at the Palm Beach Police Station with her boyfriend. Her boyfriend was allowed to sit in the lobby area while Ms. was interviewed. I took Ms i-; the Detective Bureau Interview room. I closed the door for privacy and explained to her that I appreciated her coming to the police station for the interview. During the sworn taped statement, she advised she was at Jeffrey Epstein s house o! roximately two months ago, she was approached by a girl, | who was dating her roommate, to make some quick money. vised she was in need to make some quick cash to make the rent that She agreed to go to the house. She had been told by ls the massage would have to be done in her underwear. She advised Move with her and brought her into the house. The walked into the kitchen area and took the stairs upstairs. rae) further stated she was brought into a master bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroom. Epstein entered the room wearing only a towel and GIUFFRE005659 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page643 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Case No. . . . : 1-05-000368 (Continued introduced himself as Jeff. GM e.cvisec she recalled she a removed their clothing down to their panties, Epstein lay on his stoma id they provided a massage on his legs and feet area, I asked £ she had any formal massage training and she replied no. advised she was tople. the panties she wore were the boy shorts iace panties. She and continued the massage until the last ten minutes of the massage, Epstein, told JMMJto leave the room so that MMjcould finish the massage. jot dressed and Epstein turned over onto his back. Epstein then removed the towel, which had been around his waist. Epstein laid there naked and requested that MMrub his chest area. stated hii: this, Epstein, began masturbating as she rubbed his chest. tated he pulled down her boy short panties and he ~ produced a large white vibrator with a large head. She stated it was within a drawer in his master bathroom. He rubbed the vibrator on her vagina area. HE visea he never penetrated her vagina with the vibrator. er vagina with the vibrator as he continued to masturbate. tated she was very uncomfortable during the incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he had He continue on previously and went into the shower area jot dressed and met with gn the kitchen area stein came into the kitchen = provided 200.00 for bringin: land paid $200.00 to for providing the massage. — told to leave her t hone mumber with Sarah, his assistant for future contact. ee her cellular telephone number for future contact. BBBMwas asked if she was recently contacted about this investigation by anyone from the Epstein organization. She replied she was called but it was for work. She stated she was called by Sarah for her to return to work for Epstein. iii ° the term used by Sarah to provide the massage in underwear. advised she declined, as she was not comfortable in providing that type of work. The interview was concluded and the videotape was placed into evidence. Investigation Continues. . FEA RAR RH ERERAERAAHRREREREERA NA RRA TIVE #§ 16 *ekKREEN ERE ARERR EER ERE NA Reported By: RECAREY, JOSEPH 11/10/05 Entered By.: ALTOMARO, NICKIE A. 11/10/05 On November 7, 2005, I made telephone contact with fe advised she would be able to meet with me at her home. Det. Sandman he to her home in Royal Palm B jade contact with a During a sworn taped ceavenent, lglligle® S55 she met Jeffrey Epstein through Haley Robson. Robson would approach females who wished to work for him. stated she was asked to work for him but declined. explain that work means give massages. She was asked a Ormal training in providing massages to which s she said no. aid she accompanied Robson and other females GIUFFRE005660 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page644 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Pag! 48 8:47:53 Incident Report Program: CMS301L Case No. . .+. : 1-05-000368 mag ed) who were taken to Epstein s house to provide massages. further stated she had been to the house approximately 4 or 5 times in the past year. She accompanied Robson with ME = yess ols icc Bach time the girls were taken over, they were previously to. ey" would have to provide a massage, possibly naked. It was also told that should Epstein require them to do anything extra were not comfortable just to tell him and he would stop. stated Robson received $200.00 for each girl she brought! massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, the victim, as she sta fifteen years old at the most; she looked really young. urther stated each time she went to the house, she sat in the kitchen and waited with Robson until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked her if there was anything that caught her attention within the home. stated there were a lot of naked girls in photographs throughout the house. The interview was concluded and the tape was turned into evidence. Investigation Continues.. SERERAAER AREER EA RAEREREEE NARRATIVE £17 *tttttekintardaeeneeecakan NA Reported By: RECAREY, JOSEPH 11/10/05 Entered By.: ALTOMARO, NICKIE A. 11/10/05 Det. Dawson and I attempted contact with lin Royal Palm Beach. I left my business card at her front door Ms returned my cail and arranged a meeting with me at the Palm Beac. Police Department for November 8, 2005. At approximately 2:00pm, jarrived at the Palm Beach Police Department. She was brought into the interview room and the door was closed for privacy. She was told that I appreciated her coming to the police station for questioning regarding an on going investigation. She was told that I was investigating a crime involving Jeffrey Epstein and knew, based on the investigation, that she had, rs with him in the past. During a sworn taped seasenen, lll sé=c3 she had met Epstein approximately two years ago. She was xst introduced to Epstein by Haley Robson. Robson approached her about working for Epstein and Providing a massage to him for $200.00. The arrangements were made and as Robson cow. day the arrangements were made, een A 2-5 School and was familiar with Epstein. % recalled she was brought there and entered through the back kitchen door. She had met with an assistant Sarah and another assistant Adrianna. Sarah brought her upstairs as she observed several photographs of naked females throughout the house. stated stein came in the room, wearing only a towel, and laid on the table. ee he picked out the oils he wanted h d requested she remove her clothing to provide the massage Stated that on the first massage she provided she did not remove her GIUFFRE005661 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page645 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT 8:47:53 Incident Report Program: CMS301L Case No. . . +1-05-000368 (Continued) clothing. MM < 2 << she had returned eel: after that, Each time she returned more things happened. stated that the same thing would happen. Epstein would walk into the master bedroom/bathroom area wearing only a towel. He would masturbate as she provided a massage. EE 2-2 she was unsure if he climaxed as he masturbated under the towel. Additionally she never looked blow his waist. She claimed that Epstein would convince her to remove her clothes. © She eventually removed her clothes and- stayed in her thong panties. On occasion, Epstein would use a massager/vibrator, which she described as white in color with a larg her. Every time she provided a massage he would masturbi jadded she has no formal training in providing a waRFages st. brought two females during h Ss stated she brought a girl named High School. received $20 brought. Additionally, was given $200.00 for taking her in the very beginning. The interview was concluded and the tape was placed into evidence. Investigation continues... Fede RARE REE ERROR! NARRATIVE # 18 tttttttkiraedawetaketeeete NA Reported By: RECAREY, JOSEPH 11/13/05 Entered By.: ALTOMARO, NICKIE A. 11/14/05 mber 8, 2005, I made telephone contact vi w/F, aa: | at her residence. MEE -<socndea to the police station for an interview reference an ongoing investigation. At approximately 2:30 pm, she arrived at the Palm Beach Police Station and was brought into the interview room for the interview. The door was closed for privacy and she was told that I apprec jer cooperation in this case. During a sworn taped statencnt, lll sca ce3 she had met Jeffrey Epstein approximatel ne year ago She was approached by a subject known to her as za ..3 asked her if she wanted to make money provi Epstein. [—BBMMMJhad heard that several girls from High School were doing thi. making money. She agreed and was taken to the house b had introduced her to Sarah and Epstein and brought her Upstairs toa master bedroom and Master bathroom where a massage table was prepared and the proper oils we’ out. QBJleft the room and waited downstairs for tated Epstein entered the room wearing a @ she provided a massage wearing only her thong panties. dvised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed; once that occurred the massage was over. She felt the whole situation was weird but she a she was paid $200.00 for prov the massage. She also stated received $200.00 for bring Epstein. tated she had gone a total of 15 times to his residence to =e a massage and things had escalated from just providing a GIUFFRE005662 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page646 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page 50 8:47:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) massage. Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breast with his hands as she provided the massage. stated on one occasion, he offered extra monies to have vaginal i course. She stated this all occurred on the massage table. emia =: =: Epstein penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax. Epstein SS eS from her vagina and climaxed onto the massage table eceived $350.00°for her massa I_asked her if she had any formal training in providing massages AMM cased she did not. GE one inved to state on one other occasion, Epstein introduced his ant, Nada, into the massage. Nada was brought into room with aa provide a massage. Epstein had them kiss and fondle each other around the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, Epstein introduced the large white vibrator/massager during the massage. Epstein stroked the vibrator/massager on| vagina as she provided the massage. tated the last time she spoke with anyone at was with Sarah during the weekend of October 2 or 3, 2005. stated she had brought two people to the Epstein house. ‘She p the names of id (unknown las jould noted a een previously identified as| and had been previously interviewed. The interview was concluded and the videotape was placed into evidence via the locker system. On November 9, 2005, Sgt Frick and I traveled to =z: Boynton Beach, Florida in hopes to interview Juan Alessi, the xmex houseman of Epstein's home. As no one was home, a busi; eft for him to return my call. We then traveled to jin Miami in hopes to interview Alfredo Rodriguez, a rormer house man of Epstein. We did not locate them at home. I left a business card for him to return my call. We then traveled to Lynn University and met with tudents, Mr. Turner. We requested to speak with iy as re interviewed, as she still was in ession of the rental car that Epstein had acquired for her. stated that Sarah, Epstein's assistant, had called her on her cellular telephone and informed her that rental was extended for her. Sarah stated she had paid a additional $625.00 for her to keep the rental an extra month. was asked if she had any additi mtact with either Epstein or anyone from his organization tated she did not, other than the telephone informing her that she could keep the car for an extra month. did not provide any additional information. On November 10, 2005, at approximately 9:47 am, Alfredo Rodriguez had telephoned reference my business card found on his door. Rodriguez Stated he had worked with Epstein for approximately six months after GIUFFRE005663 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page647 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page 51 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . +: 1-05-000368 (Continued) the previous houseman left. Rodriguez stated that it was his responsibility to keep the identity of the masseuses private. Mr. Epstein had a massage in the morning and one in the afternoon. Mr. Rodriguez stated he would rather speak about this in private. He advised he would come to the police station to speak with me. Rodriguez stated he would return my call on Monday, November 14, 2005. I then made telephone contact with Juan Alessi. He advised he found my card on his door and wanted to know what I needed to speak with him about. I explained to Alessi that I was conducting an investigation on his former employer, Mr. Epstein. Alessi stated he would returm my call shortly as he was in the middle of a project at his home. 1 received a telephone call from Attorney Donald Morrell from Mr. Morrell stated he represented Mr. Alessi and did not want me speaking with his client. I then made telephone contact with the State Attorney s Office and confirmed that subpoenas would be issued to the former employees to assist in the investigation. I then made telephone contact with Attorney Guy Fronstin, attorney for Mr, Epstein. I explained to Mr. Fronstin that I would like to speak with Mr, Epstein. He stated Mr. Epstein is not in residence in Florida at this time and would check with him to ascertain if he could be here by Wednesday November 16, 2005 for an interview. Mr. Fronstin stated he would return my call should Mr. Epstein decide to come in to the police station for an interview. Investigation continues. AEARARAEAAREAKERAERKRAERELRE NARRATIVE LD FARARERHRHER RR REEH ERE ERLE NA Reported By: RECAREY, JOSEPH 11/15/05 Entered By.: ALTOMARO, NICKIE A. 11/16/05 yvember 14, 2005, Det. Sandman and I traveled to in Loxahatchee, Florida and spoke with ie was told of the ongoing investigation involving Epstein. advised she had gone to the house on several occasions. During a sworn taped statement, she advised she star xi one year ago and was brought by state al brought her into the house and she was introduced to a girl named Sarah. Once shy Sarah brought her upstairs into a master bedroom bathroom. reat she met Jeffrey in the bathroom. He lay on the t @ and picked the massage oils. She provided the massage, as he lay naked on the massage bed, She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed himself from the massage table and paid her $300.00 for the massage. a; -: d only been at the house approximately five or SLx Times. aid each time she went to the house she was notified by Saran, Bpstein's assistant, that Epstein was in town and would like her to work. GR st atea she returned to the house and was again led upstairs by Sarah. She provided the massage, clothed. GIUFFRE005664 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page648 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 52 Time: 98:47:53 Incident Report Program: CMS301L Case No. . = 1-05-000368 advised it wasn't really weird until later on. asked if she ever removed her clothing to provide a massage. stated it was not until the third time she went that she removed oer clothing. eg] stated she was notified by Sarah that Epstein wanted her to come to work. She arrived at the house and was led upstairs by Sarah. She started pr je massage when Epstein asked her to remove her clothing. aes her pants, shirt and bra. She stayed in her thong p: id continued rubbing Epstei —_ turned over onto his back and she rubbed his chest area. tated was masturbating himself as she providing the massage. tated she believed he climaxed based on his breathing. She jew either the climax or the fact that he was masturbating. stated once the breathing relaxed he got up and told her to get dressed. She was paid $300.00 for her services. stated on the last time she went to provide a mass. she was notified by Sarah to come to the house and work. stated she was now dating her current boyfriend and did not teel comfortable going. She recalled it was approximately January 2005. She said she went, already thinking that this would be the last time. She went upstairs and went into the master bathroom, She met with Epstein, who was _ wearing only a towel as he entered the room to lie on the table. stated Epstein caught her looking at the clock on several occasions. Epstein asked her if she was in a by stated her boyfriend was in the car waiting for her. ‘urther stated that Epstein got upset, as she wasn't enjoying the massage. She told him that she didn't want to continue and she would not be back. Epstein told her to leave as she was ruining his massage. asked her if she had any contact with Epstein's organization, she stated she received $200.00 from Western Union in Royal Palm Beach and Okeechobee Blvd as a Christmas gift. sed she had no formal training in provide any massages so stated she was sixteen years old when she first went to Epstein's use. i At approximately 4:22 pm, I made telephone contact with at =a She agreed to meet with me at a public place. suggested she come to the police station for an interview. did mot want to meet at the police station, JI recommended we meet at the Palm Beach Gardens Mall in the food court area. She agreed and an appointment was made for November 15, 2005 at 5:00 pm at the food court. Investigations Continue. HERE RER RHR RA TR RKEREAEREEEREE NARRATIVE # 20 #0tetekteneaeeaeeeeeaeeeee NA Reported By: SANDMAN, JENNIFER R. 11/16/05 Entered By,: ALTOMARO, NICKIE A. 11/17/05 On 10/20/2005, I assisted executing a search warrant at 358 El Brillo Way in the Town of Palm Beach, Palm Beach County Florida under the direction of affiant Detective Joe Recarey. GIUFFRE005665 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page649 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 53 Time: Incident Report Program: CMS301L Case No. .. . : 1-05-000368 (Continued) Detective Melnichok and I searched the pantry room that is west next to the kitchen. This room had all white cabinets with a dark grey and black counter top. We did not find anything in this room, We searched the yellow and blue room.that is west next to the pantry room. This room had a very large statue of man with a bow. Taken into evidence from this room were nine photographs in frames of various women. We searched the main entrance foyer that is to the north of the yellow and blue room. This room contained two bamboo chairs and ottomans with cushions. It also contained a round table with numerous books . We searched another blue room that is west of the foyer. This room had a stereo system and book shelves that were from the floor to the ceiling. Taken into evidence from this room were eight photographs in frames of various women and/or Epstein, the owner of the residence. We searched the room to the west of the blue room that has sliding glass doors that lead out to the pool. In this room in a dresser were two DVD's and two VCR tapes. These items were taken into evidence. We searched a 2004 black Chevy Suburb earing Florida tag X99-EGL, registered to Jeffrey Epstein DOB which was located on the east side of the driveway facing sout: I found a Thrifty rental agreement between the passenger seat and the middle anna Sjoberg from The phone number on the rented was a white The vehicle was rented on 3/25/05 at 17:58 hours and was returned on 9/26/05 at 16;52 hours. The last four numbers of the credit card used are Detective Melnichok found a piece of paper in the middle console that said I used the cash in here to fill up the tank and was signed by Johanna. I searched the 2005 black Cadillac Escalade ESV bearing Florida tag Q29-9GT, registered to Jeffrey Epstein dob (NJ which was located on the west side of the driveway facing south. I did not find anything in this vehicle. All of the items that were taken into evidence were photographed in the place they were located and then turned over to crime scene. Pkt ttt NAR RAT IV EB # 21 ttttetetkecere eran kere kee NA Reported By: RECAREY, JOSEPH 11/17/05 Entered By.: ALTOMARO, NICKIE A. 11/17/05 GIUFFRE005666 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page650 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT 47:53 Incident Report Case No. - + 1-05-000368 (Continued) ember 15, 2005, Det. Sandman and a: Royal Palm Beach. We met with = seventeen-year old juvenile who was_not MNOOL this day due to a cold from which she was suffering. as told that I needed to speak with her in reference to an ongoing investigation involving a } subject she would know as Jeffrey Epstein. Prior to speaking with her, I explained that because of the fact that she is a minor, I needed to speak with her p. + speaking with her. She telephoned her father, Mr. on his cell phone and explained to him that Det. Sandman and I were there to speak with her. I spoke with Mr. §BBMMMMon the telephone and informed him I needed to i his daughter in reference to an ongoing investigation. Mr. advised he had no problem with us speaking with his daughter. During a sworn taped statement, HE s 2c ea she met Jeffrey Epstein over he was sixteen years of age and was | approached — = informed her that she could make monies providing a massage to Epstein for $200.00. i emed her that she would have to provide this massage topless le the arrange) Epstej o is assistants and took to the house. en: she entered through a glass door that led into a kitchen took her upstairs, to a master bedroom and master bathroom. She recalled the bathroom had a large pink couch, sauna and matchi: shower Epstein entered into the room wearing only a towel. oo removed their clothing | remaining only in thong underwear. She further stated that Epstein | lay on his chest on_the table. stein selected which oils to use for the massage. Both and rovided the massage on his legs, back and feet. Forty minutes into the massage, Epstein turned ied stairs in the kitchen ar haz Ep) ind to finish t age, As got dressed, i ing his chest, left the room, and Epste, sturbating himself as| rubbed Epstein s chest. stated he continued masturbating until he climaxed on the towe @ was wearing. When asked if he had removed the towel she stated he turned the towel around so that the opening would allow him to expose bi 1 After he cleaned himself off with the towel, he instructed age was done and to get dressed and met with him downstairs. got dressed and met with Epstein in the ili She was paid $200.00 dol Zor providing the massage. stated she was aware cnet li? =< received monies for the same thing. T) cond time she went to the house she was again approached by Sked if she wanted to return to the house to provide c massage; MEM agreed and t ments were made by for her to return to the house. stated RR drove her to the house and knocked on the same glass door that leads to the kitchen area. They were allowed entry into the house by one of the staff members. ms her upstairs to the master bedroom and GIUFFRE005667 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page651 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 55 Time: 98:47:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) master bathroom area. MEM left | see time to do t alone. Epstein entered the room again wearing only a towel. began removing her clothing as she did the last time she was iS house. Epstein instructed her to get maked. He lay on the table on his stomach as MM) began massaging his legs and back, As MEM finished with Epstein's back and legs, Epstein then turned over onto his back. ed to rub his chest and he began masturbating himself. As rubbed his chest, Epstein leaned over and produced a massager/vibrator, He turned it on and began i s vagina and masturbating himself at the same time. Stated she continued to rub his chest as this was occurring. She described the vibrator/massager as large, grey with a large head. Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the vib: her vaginal area and concentrated on masturbating himself |r he climax ie towel again and informe that the massage was done. ot dressed and met with who was waiting in the kitchen area. She received $200.00 for the massage. =: she nevi d to the house and had no desire to return to the house. a... asked if she received any formal massage training. sne advised she had no formal training. was asked if Epstein knew her real age, stated he knew as he asked her questions about herself and high scho He was aware she attended and is still attending eS :::;:: School . The interview was concluded. I sugested MME: corm her parents of what occurred at the Epstein house. tated she would tell her father as he was unaware this had occurred. I left my business card for any questions they may have. We left the area and returned to the police station. The tape was placed into evidence. Investigation Continues. FARKKKA EAA HRA ERE RERERARAAE NA RRA T IV EB # 22 +hekkckeheaananeeea eee eene NA Reported By: RECAREY, JOSEPH 11/17/05 Entered By.: ALTOMARO, NICKIE A. 11/17/05 On November 15, 2005, Officer Munyan and I responded to the Palm Beach Gardens Mall food court don to meet with a At approxi 510 p.m., arrived and met with us at the food eee ie oo 22s @ sworn taped statement in which she stated going was she had been at the Epstein house over fifty times. She to Epstein's.house when she turned eighteen years old. asked if she knew of the on-going investigation, stated she Was aware there was an investigation as she had been told by other girls that were interviewed. Additionally, she has had several telephone conversations with Epstein's assistants as to what had been going on during the investigation. I asked MEL... she was introduced to Epstein. MMMetetea she did not want to disclose who brought her to the house but she would GIUFFRE005668 CONFIDENTIAL

Case No. . Case 18-2868, Document 283, 08/09/2019, 2628241, Page652 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT | 8:47:53 Incident Report a (Continued) { — | other questions. When I asked her what happened at the house, stated everything happened. It all began with the Massages. Each time she went more things happened. She would massage Epstein and he would masturbate and climax. She stated things escalated from there. She provided oral sex on Epstein and he provided oral sex on her. She stated he would also use a Massager/vibrator on her vagina to stimulate her as she massaged him. He d his assistant Nadia or Nada to have vaginal intercourse oT She stated Nada or Nadia would utilize a strap-on (synthetic penis) to have intercourse with her. She was told to masturbate herself as Epstein and Nada had sexual intercourse. All this was done at Epstein's direction. ae... not provide exact dates as she had been to the house so many times. =a stated Epstein inserted his fingers in her vagina to stimulate ner as she massaged him. When I asked her if there had been any vaginal intercourse with Epstein, she stated she did not have sex with him. She did admit having sex with Nada, his assistant. stated not every time she went involved sexual favors. Sometimes she would just talk with him and get paid. I asked_her hi much she was paid each time she went to Epstein s residence. =z stated she got paid $300.00 every time she went to the hous: She was told to bring other girls to him to provide massages. QM declined stating that she does what she does and did not want to introduce anyone else to do what she does. tated she had never received any formal training in providing massages. I showed a photo line up in which Nada Marcinkova was placed in position six. She reviewed the six photographs and immediately identified Nada Marcinkova as the person with whom she had intercourse. Additionally, it was the same person she watched have intercourse with Epstein. She signed the photo line-up under Nada Marcinkova s photo as the person she identified. We then left the mall and returned to the police station. THe photo line up and tape were placed in to evidence. Investigation Continues..-~ 1 ReKKKKKARKAA RARER ERE RAEN BRRRATIVE $ODD RR RR REE NA Reported By: RECAREY, JOSEPH 11/28/05 | Entered By.: ALTOMARO, NICKIE A. 12/01/05 On November 17, 2005, I received a phone message from Atty. Guy Fronstin who advised to call his cellular phone reference his client Jeffrey Epstein. I telephoned his cell phone and left a message for him to return my call. TI did not receive a call back on-Thursday, November 17, 2005. On Friday, November 18 2005, I retrieved another voice mail from my work phone from Mr. Fronstin advising he would not produce his client Jeffrey Epstein for any statement. Fronstin stated he had spoken with ASA Lana Belohlavek and expressed Mr. Epstein has a passion for massages. I called ASA Lana Belohlavek and confirmed that GIUFFRE005669 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page653 of 883 7/28/06 PALM BEACH POLICE DEPARTMENT 7953 Incident Report Case No. . .. : 1-05-000368 (Continued) Fronstin had telephoned her reference this case. Although nothing was discussed, Mr. Fronstin did advise her that Epstein is very passionate about massages. I also spoke with ASA Daliah Weiss reference the previous employees, duan and Maria Alessi. She advised that they had been served through a subpoena process server. They were both scheduled to appear on Monday November 21, 2005 at 12:00 p.m. On November 21, 2005, I met with ASA Weiss, Atty. Donnie Murrell and Juan and Maria Alessi at the State Attorney Office. ASA Weiss had requested a court reporter to be present to take the statement of the Alessi s. I spoke with Maria Alessi, in the presence of her attorney, Donnie Murrell. She advised she had worked for Epstein for eight years, from the period of 1994 through 2002. She advised she had mever had any direct conversations with him. She stated it was her husband who spoke directly with Epstein. Her work consisted of doing house cleaning, ‘shopping and other preparations when Epstein would arrive in town. Alessi stated the preparations consisted of preparing the house and bathrooms for his arrival. She advised she did view several masseuses that arrived at the house. She advised that two or three girls would come during a day and provide the massages. The girls that arrived looked young in age. Mrs. Alessi did not know any of the girls personally and were always different. She was told that when Epstein was in residence he did not want to encounter the Alessis during his stay in Palm Beach. I then spoke with Mr. Alessi in the presence of his attorney, Donnie Murrell, Mr. Alessi stated that he was employed for eleven years with Mr. Epstein. He originally was hired as a part time employee and then moved up into a full time position. His duties included everything. Alessi stated he was the house manager, driver and house maintenance person. It was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. He remembered dealing with his girlfriend, Ms. Maxwell originally and then dealt with Epstein directly. I asked Mr. Alessi about massages that occurred within the home. Mr. Alessi stated Mr. Epstein had up to three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. There were times he recalled that he would set up the massage tables either in Epstein s bedroom or in his bathroom. I asked if there) were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have ‘to wash off a massager/vibrator and a long rubber penis, which were in the isink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. Alessi was never privy to what went on during the GIUFFRE005670 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page654 of 883 PALM BEACH POLICE DEPARTMENT Page: Incident Report. Program: CMS301L Case No. . . . : 1-05-000368 (Continued) massages, He was asked if he remembered any names of the girls that massaged Epstein. He tried to remember and was unable to provide any exact mames of any girls. Alessi was asked about any contact with anyone from the Epstein organization. Alessi said he did speak with Mr. Epstein shortly after my initial contact with him to find out what was going on. Alessi also stated that approximately on November 11, 2005, he was contacted by a private investigator from the Law Office of Roy Black. The investigator had called him to meet with him to ascertain what he was going to tell the police. Alessi stated they met at the Carrabba s Restaurant in Boynton Beach and discussed the same questions I was asking him. I informed Mr. Alessi and Mr. Morrell that as this is an ongoing investigation and anything we discuss should be confidential. They both acknowledged the fact that the information would be kept confidential. It should be noted that a court reporter was present during the interviews and would be providing a copy of the statements to me when they become available. On November 21, 2005, I received a voice mail from Mr. Fronstin who advised he would not be making Mr. Epstein available for any statements. He did have some words that he wanted to relay on behalf of Mr. Epstein. I telephoned his office and left a message for him to return my call. f On November 29, 2005, I received a call back from Mr. Fronstin who left a voice mail after hours on November 28, 2005, advising he would return my call during normal business hours to speak with me reference the case on November 29, 2005. FARRER ALE REARASERALEEAHSES NA RRA T IV EB § 24 4448S Eee EERAERERE RRR RRR EE NA Reported By: RECAREY, JOSEPH 11/29/05 Entered By.: ALTOMARO, NICKIE A. 12/01/05 On November 29, 2005, at approximately 2:30 p.m. I received a telephone call on the department issued cell phone. Mr. Fronstin stated he was calling to relay information that Mr. Epstein wished he could relay. Mr. Fronstin stated that he would not allow Mr. Epstein to speak with me at this time. He further stated that Mr. Epstein is very passionate about massages. He continued that Mr. Epstein had allegedly donated over $100,000 to the Ballet of Florida for massages, The massages are therapeutic and spiritually sound for him that is why he has had many massages. Mr. Fronstin stated he appreciated the way the investigation has not been leaked out into the media, I explained to Mr. Fronstin that it is as important to protect the innocent if the allegations are not substantiated. Mr. Fronstin was told of the allegations that the private investigators assigned to the case have been portraying themselves as police officers. Additionally, I explained that my cell phone had been called by the private investigators, Mr. Fronstin advised he was not aware of that and advised they were under the direction of Attorney Roy Black in GIUFFRE005671 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page655 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) Miami. Mr. Fronstin further stated Epstein had originally called mr. Dershorwitz in Boston, who recommended Roy Black in Miami, who asked | Mr. Fronstin to assist. I informed him that if and when any charges j would be presented I would notify him. The call was then terminated. Investigation continues. SPREE REAEEE RAP EREARERERASER NAR RA TIVE § 25 t0tketbeeeteteeseeeeeeeee NA Reported By: RECAREY, JOSEPH 12/15/05 Entered By.: ALTOMARO, NICKIE A. 2 12/16/05 A review of the telephone message books, which were obtained during the search warrant, was conducted in which various messages from different dates were made to Jeffrey Epstein. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls, i dates and telephone numbers were on the copy of the messages, I | recognized various numbers and names of girls that had already been } interviewed. The body of the messages was time of the day that they + called for confirmation of “work." Other names and telephone numbers were located in which the body of the messages were, "I have girls for | him" or "I have 2 girls for him." These messages were taken by Sarah j for Jeffrey Epstein. Based on the context of the body of the i messages, I requested subpoenas for subscriber information on the telephone numbers and the time frame involved. Copies of the messages were made for evidentiary purposes. I obtained High School yearbooks for 2005, 2004 and | | 2003. I first reviewed the 2005 yearbook and loca: girls I had spoken with. Additionally, I located Based on the corrected name spelling, I was able to locate her to her residence in Loxahatchee. On December 8, 2005, De responded to ME «02252 chee, T located t her home, She advised she is attending High and is participating in the early release program so she can maintain her part time job. As she is still a minor, I left my business card to have her mother return my call to request an interview with her daughter. We then left the area. I also had previously researched the telephone number for MM ana telephone number A subpoena had been issued for the information on The telephone number was registered to cry of ME. c roa 2a S a is currently residing at - Det. Caristo and I attempted contact with with negative results. I left my business card on nq she retu: call. We then responded to I also attempted contact with with negative result. I left my business card for him to return my call. GIUFFRE005672 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page656 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT 8:47:53 Incident Report Case No. . . . : 1-05-000368 (Continued) 2005, I received a telephone call from s mother, who was made aware of the on going investigation in Palm Beach. QMMMadvised she was told of everything that occurred at Epstein's house involving Epstein and his staff. She advised she would allow me to question her daughter about what occurred and would cooperate with the investigation. provided me wit: cellular telephone number to schedule an appointment for an official interview. I telephoned her cellular telephone and made a tentative appointment for Monday, December 12, 2005. I then received a telephone call from ae father of —_=s MMM, sino stated he found the business card on his door. I explained that I was conducting an investigation and needed to speak with MMs she information that could assist in the investigation. Mr. tated that his daughter no longer resides with him and has he: iler in another trailer park. He advised he would tell her to call me. On December 12, 2005, dué to i with schedules, arrangements were made to meet with| on Tuesday, December 13, 2005 at 5:00 pm. On December awson and I traveled to Loxahatchee_and met with| During a sworn taped statement, MBBBBMMstated that when she was sixteen years taken to Epstein's house to provide a massage stated it was before Christmas last year when her and asked if she needed to make money for she did and agreed to provide a massage for money. arrangement’ ke o the house and drove to the house to "work." tated she could not remember the street name but would be able to drive to the street. They drove to the last house on the street and pulled in the last house on left side. They walked up the driveway and entered through a side gate which led to a kitchen door. ry knocked on the door and were encountered by an employee who lescribed as a "Spanish looking lady." They informed her that ey were expecte were then encountered by a white female with long blond hair. was unable to remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom_and bathroom. The massage table was already set up in the bathroom. Rescribed the bathroom as a large spacious bathroom with a steam room and shower beside it with a sink to the right. as introduced to Jeff who was on the phone when she ente} f£ was wearing a white towel and 1 is stomach so that lay Massage his feet and calves. tarted the massage with the massage oil Jeff chose and rubbed his feet and Calves. Jeff got off the phone and requested she massage his back as well. (BBBMMMbegan rubbing his back and got to the small of his back. During the rubbing of his back Jeff asked her to get comfortable. He GIUFFRE005673 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page657 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 61 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) and pulled her pants off. stayed in her Dra and thong panties. | As she finished the. small back, Jeff then turned onto his back. He instructed she rub his chest and pinch his nipples. As she o rub his chest, Jeff asked her quest) Li remembered telling him she attended High School. Jeff asked her if she was sexually active. Before mie. = he also asked what sexual positions does she enjoy. tated she was shy didn't like talking about those things. She continued rubbing his chest. Epstein reached up and unsnapped her bra from the front. EN oi nincc the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed. MMbaid "no, I don't like that." requested she remove her = - shirt. fe removed her shirt ) Epstein loved his towel and lay on the bed naked exposing his penis to He began touching his penis and masturbated as he touched her breasts. a eT Jeff then touched her vagina area by rubbin ina with his fingers on the outside of her thong panties. ensed up and stated Jeff was aware that she was uncomfortabi Ma .::-: that Jeff told her , "Relax, I'm not going inside." She ner explained Jeff commented to her how beautiful and sexy she was. deff then moved panties to one side and now was stroking her clitoris. said "Jeff commented how hard my clit was." He then inserted two fingers in her vagina and was stroking her within her vagina. She tried pulling back to pull out his fingers from within her vagina. Jeff removed his fingers from within her vagina and apologized for putting his fingers inside her Du is time he kept his hand on her vagina area rubbing her va \ stated he rubbed her real hard as he was masturbating. Sal ie climaxed onto the towel he had been previously wearing and got up from the table. Jeff told her there was $200.00 dollars for her on the dresser within the master bathroom. Jeff als er that there was an additional $100.00 that was to be given to or bringing her there to massage him. Jeff told her to leave her telephone number with his assistant as he wanted to see her again. Jeff stated his assistant would contact her to work again soon. her if she ever received any formal massage training to which | stated she did not. INS acc it was the only time she i ever went to work for Jeff and kne happened to her was wrong. She stated she no longer speaks to because she was upset that j took her there. She further stated that she had never been Ontacted for any additional work. The interview was terminated and | we left the area. Investigation Continues... RAKE RIRKERERAERARKEKERAAEERN A RRATIVE HG RRRARR RRR ARERR EEE REE NA Reported By: DICKS, ALLEN C. 12/18/05 Entered By.;: ALTOMARO, NICKIE A, 12/13/05 GIUFFRE005674 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page658 of 883 PALM BEACH POLICE DEPARTMENT Incident Report + = 1-05-000368 (Continued) On 102005 at approx 0930hrs I assisted with the execution of a search warrant at 358 El Brillo Ave, Palm Beach. i Initially I was assigned to enter the residence and conduct a 1 sweep of the premises for safety purposes. I then accompanied CSEU tech Pavlik while she photographed the exterior of the house. Once this was complete I was assigned to search certain areas of the house with Det. Dawson as part of the search warrant. We began in the garage, searching three Mercedes Benz vehicles, a Harley Davidson motorcycle and adjacent closets in the garage. Nothing of evidentiary value was located. } We then searched two closets off the kitchen area on the east side. These can best be described as pantry or storage closets. Nothing of evidentiary value was obtained. A small office with adjoining bath was then searched. In the bath ' area I located a phone message book with recent messages, This item | was seized as evidence. Please note this bath and shower area are not t used as designed but are storage areas containing a variety of items to include a gun safe in the shower and assorted household items. We then searched a bath area and closet at the base of the main { stairs in the foyer. Inside the closet two massage tables were } located as well as partial nude female photographs. These items were { later seized as evidence. Nothing of evidentiary value was noted in the bathroom. residence. Located in the bath room of the south bedroom was penis shaped soap. Located in the bedroom of the northern bedroom was penis and vagina shaped soap as well as an adult sex toy. These items were | seized as evidence. i | | We then searched two bedrooms upstairs on the east side of the i 1 We then searched the pool cabana located in the south west corner i of the property. Several photographs of nude females were seized as evidence, I was then assigned to stand by with a person I believe was Douglas Schoettle. Mr. Schoettle was in the residence at the beginning of the search warrant. He was present during the warrant service and subsequent search. I stood by with him until the search was completed and I departed the residence, I had no conversation i with him regarding the reason for our presence. { Regarding seized evidence, all items were photographed in place and then collected by CSEU personnel. This concludes my involvement in this case. GIUFFRE005675 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page659 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 63 Time: 8:47:53 Incident Report Program: CMS301L Case No. .. . : 1-05-000368 (Continued) RRAKKARAEKHHEARAATEAERESESEE NARRATIVE HQT ERK RHERERREED LER RE EERE NA Reported By: KRAUEL, CURTIS D. 12/21/05 Entered By.: ALTOMARO, NICKIE A. 12/21/05 On Thursday, October 20, 2005 at approximately 0936 hours, I assisted in the execution of a search warrant located at 358 El Brillo Way, Palm Beach, Florida, residence of Jeffrey Epstein. I was instructed by Case Agent Det. Joseph Recarey, to secure all computer and media related material from the residence. Upon my arrival I was directed by Det. Recarey to a room designated as the Kitchen Staff Office. I observed a, Silver in color, CPU with the left side cover removed, exposing the CPU s hardware sitting on floor next to a glass type desk, The CPU had no discernable identifiers or features indicating a make or model. This CPU was powered off with the power cord not plugged in. The keyboard and mouse were atop the cpu. It should be noted that the CPU was not connected to a monitor, printer, or other media device, On the back Panel of the CPU, I observed an A/V card with RCA jacks attached. This type of hardware would allow audio and video to be downloaded onto the CPU s hard disk. The ends of the RCA jacks were unattached at the time of the search and no external camera was located within this room. The CPU was located on the right side of a desk that held a flat panel LCD screen. The desk also held another keyboard and mouse, indicative of a second computer; however, no other computer was found. It appeared as though a second computer had been recently removed as the cables ends from the monitor, keyboard and mouse were in the same area. A further search of the room revealed no media storage devices, i.e. CD s, Floppy Disks, Zip Disks, etc. This type of media is commonly stored in an area where computers are placed, yet no media was found, After completing a search of this room, I secured the CPU and turned all items over to the Evidence Custodian for future forensic analysis via a property receipt. I was then directed by Det. Recarey to a room designated as the Garden Room, where I observed a wooden desk facing west. The desk held a flat screen LCD monitor, keyboard, mouse, media card reader and printer; however, no CPU was located. All of the cables were removed from an area where a computer had once been. A search of the desk area revealed no signs of any media devices. Det. Recarey directed me to a third location designated as the Cabana room, which is detached from the residence and located just south of the pool, In the South Hast corner of the room, I observed an office type setting, with an L-shaped desk holding a flat screen LCD monitor, keyboard; mouse and printer; however, no CPU was located. All of the cables were removed from an area where a computer had once been. A search of the desk area revealed no signs of any media devices. GIUFFRE005676 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page660 of 883 PALM BEACH POLICE DEPARTMENT Page 64 Incident Report Program: CMS301L 7/25/06 3 Case No. . .. : 1-05-000368 (Continued) Det. Recarey directed me to a second detached structure located on the South Bast corner of the property. This area of this structure was assigned with single letters to identify a particular part of the room, In the office area, designated as Room B, I observed a powered on Dell Dimension 2350, attached to ai LCD flat panel monitor. The screen displayed an open Microsoft Internet Explorer browser with URL address of http://home.bellsouth.net/. I observed no other active windows in the Start panel window and photographed screen. The power cord was removed from the back of the Dell CPU and I disconnected the cable modem to prevent remote access, At that time, the Dell CPU, marked with Serial. Number 6WIVN21, was secured and turned over the evidence custodian for future forensic analysis via property receipt. I also located several media related items within Room B, which were recorded onto a property receipt and turned over the Evidence Custodians. I then responded to a Bedroom designated as Room F, where I observed a white in color CPU marked Premio. The Premio CPU was in a computer desk which held a white CRT monitor, both of which were powered on. The CRT monitor displayed a message from Norton Antivirus software, warning of an expired subscription. I observed no other active windows in the Start panel window and photographed screen. I removed the power cable from the back of the Premio CPU and shutdown all other “media. The Premio CPU, marked with Serial Number 2000091078, was secured and turned over the evidence custodian for future forensic analysis via property receipt. I also located several media related items within Room F, which were recorded onto a property receipt and turned over the Evidence Custodians. This concluded my participation in the search of the residence. RARKKRKAHHERRRE RARER ERRARERE NARRATIVE # 28 *8ttbeeteeeeeecaceeceeeeee Reported By: RECAREY, JOSEPH 12/21/05 Entered By.: ALTOMARO, NICKIE A. 12/21/05 On December 20, 2005, I contacted ASA Daliah Weiss in an attempt to subpoena the Epstein former houseman, Alfredo Rodriguez. Rodriguez, who resides in Miami, had eluded the process servers previously and was not served the investigative subpoena. A telephone message was left as she is not available during the week of 12/19/2005. I made contact with State Attorney Inv Theresa Wyatt and requested the same via telephone message. I then researched the victim's SG cellular telephone subpoena data which had been received from a previous subpoena request. I analyzed the records which depict several calls from Haley Robson. The telephone calls start on February 6, 2005 at 12:49 pm.; the same day which the victim and the victim's father stated the incident occurred at Epstein s irst incoming call was from Robson's residence at The second incoming call from Robson's GIUFFRE005677 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page661 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: Time: 8:47:53 Incident Report Program: CMS301iL Case No. ...: a (Continued) cellular phone occurred at 1:02 pm. The call durations were one minute or less. The time frame was within thirteen minutes apart. It should be noted that Robson s residence was in close proximity to the victim's. The next call occurred at 5:50 pm when the victim telephoned Robson s residence. Several calls were made after the above mentioned calls both incoming and outgoing to Robson. Further analysis showed no telephone calls to either Robson's cellular telephone or Robson's residence were registered prior to February 6, 2005. Additionall I also conducted an analysis on the telephone calls from ad The subscriber information confirmed that the number is i registered to Paul A Lavery from Hialeah, Florida. The address was crossed referenced to the Office of Kiraly and Riley Private Investigators. I researched the web page www.rileykiraly.com which also showed various cases in which they assisted. I also located another web site under www.coralspringssparklandrotary.org in which Mr. Riley attended a Miami Rotary meeting and confirmed Atty. Roy Black is among his clientele. The telephone calls revealed Lave had telephone contact with i ee RE just after I attempted to interview em, Or Jus ELOY. ackground was conducted on Lavery which revealed he holds a current Private Investigator License. A criminal arrest record revealed he had been previously arrested for possession of cocaine and solicitation of prostitution. I also researched the girls using www.myspace.com. This web site is a new social networking service that allows members to create unique personal profiles online in order to find and communicate with old and new friends. The site allows one to establish your own myspace.com ' page and decorate the page any way one wishes. I found the followin eople have myspace sites: Ha: I received a Cingular Wireless packet which contained a CD which contained the results of the subpoena request for verbatim calls on An analysis will be conducted in the near future on the phone numbers called. Investigation Continues. AERAHRE ERE R ARERR RARARERERE NA RRA TIVE $f 29 tt eRERE RAR RE REE REE EER NA Reported By: RECAREY, JOSEPH 12/27/05 Entered By.: ALTOMARO, NICKIE A. 12/29/05 | red in the search The Upon doing research on the message I located the identity of warrant MN 2.5 cecistered to seventeen years old and is attending GIUFFRE005678 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page662 of 883 : PALM BEACH POLICE DEPARTMENT Page: 66 | Incident Report Program: CMS301L | Case No, . . . : 1-05-000368 (Continued) responded to 1801 Palm Bea evard, also known as the Palm 11. I located che MMM I located imside the foundation inrormed her that I was the house. started to cry and advised she had put that part of her life behind her. I explained that although she is seventeen years old I needed to inform her parents that she would be interviewed. She provided her home telephone number. I attempted contact and left voice mail messages at the house to speak with her che house. il a_case against Jeffrey Epstein and knew she had been at parents. Det. Caristo and I then located es. her residence located at mn West Palm Beach. I attempted to interview her about Jeffrey Epstein. She advised she is so in love with Jeff Epstein and would do anything for him. She further explained that she would not speak with us about him either negative or positive. She asked us to leave her property. I informed her that although she did not wish to speak with us, I had sufficient information at this point in the investigation to know she was at Epstein's house and provided girls to Epstein to work. I also explained that prior to at her residence I had telephone contact with hi who was told she would be interviewed. 'y seventeen years old and as a juvenile, parental notification | would be required. We then leff the area and returned to the police station, the police station, I left another telephone message for parents. I began an ah Kellen's Cellular | telephone. The telephone number is assigned to Sarah | Kellen and the financially responsible party 1s Jeffrey Epstein of 457 | Madison Ave. in New York City, New York. The time frame which was subpoenaed was September 2005, through October 2005. There were | eighty seven pages of calls made either to the cell phone or from the j cell phone. The local (561) numbers were analyzed. A spread sheet was prepared and placed into the attachment file of who was called. The unknown numbers were researched using FoneFinder,com and subpoenas were requested to determine subscriber information. This was done to identify additional victims or witnesses. The analysis revealed that ] Kellen had called the victim/witnesses frequently when Epstein was in the Town of Palm Beach to "work." This confirms what the girls { interviewed had previously stated. Kellen would notify them when j Epstein was in town and their willingness to "work." The CD was placed into evidence. Investigation Continues. KEKKERARERKREEEAKAE EH ARAHRAEE NARRATIVE $0 FARRAR RRRR REE ERARKEREREE NA Reported By: RECAREY, JOSEPH 1/03/06 | Entered By.: ALTOMARO, NICKIE A. 1/03/06 | On December 29, 2005, I received a facsimile from National Compliance GIUFFRE005679 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page663 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: Time: 7:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 inued) Center from Cingular Wireless for telephone nunder This was the telephone number for Haley Robson during the time frame when the victim, was brought to the Epstein house to "work." An analysis of the phone records, of all incoming and outgoing calls, showed that on February 6, 2005, the day the victim, MM owes brought to le house, Robson first called Sarah Kellen, Epstein's assistant, at t 12:50 pm (EST). The next call was made to Epstein's Palm Beach, at 12:52 pm (EST). The following call was made to the victim (iil at 1:01 pm (EST) and at 1:02 pm (EST). This confirms the information provided by the victim and victim's father. I photo copied the records and enlarged the page 8 of 10 to show the calls made by Robson on February 6, 2005. To this date, I have not heard —l Ta parents. TI will attempt to establish contact wit eae Uteoa evening hours. I received a package from Atty. Guy Fronstin, which was hand delivered at the police station. Within the package, was a letter from Alan Dershowitz, and two www.myspace.com profiles, The profiles were that of and aT MySpace.com is a social networking service that allows members to create unique personal profiles online in order to find and communicate with old and new friends. This package was in response to a previous meeting in which Mr. Dershowitz called to assist in the investigation in providing any additional witnesses such as house employees who have been reluctant to speak with law enforcement. I reviewed the profiles Mr. Dershowitz enclosed. i i her blog to be ‘is still attends High School, sends and receives messages from friend; some profanity. Upon reviewing her friends' comments section from Myspace, most of her good friends sent messages to establish contact and invite her to go out. I then reviewed s web blog whic ded by Mr. Dershowitz. Ms. her blog to be a: Her blog states that her interests include music, theater and weed (Marijuana) . _I reviewed her packet in which declares her love for her live-in = She also describes using marijuana with her boyfriend = > house i The letter Mr. Dershowitz sent advised he was looking into the allegation that one of the private investigators used by the private attorneys of Epstein, attempted to impersonate or state that they were police officers from Palm Beach Biz advised that the investigators used to interview had "quite a distinct speech impediment", did not claim to be nor did they impersonate themselves as a police officer. This package was sent to both ASA Lana Belohlavic and ASA Daliah Weiss at the State Attorney's Office. I made telephone contact with ASA Weiss to confirm she received the package and request an interview with Sarah Kellen, Nada Marcinkova, and Janusz Banasiak. She advised she would assist in attempting to GIUFFRE005680 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page664 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 68 Time: 8:47:53 Incident Report Program: CMS30iL Case No. . . . : 1-05-000368 (Continued) contact Mr. Dershowitz. On January 3, 2006, I received a telephone call from ASA Weiss who informed me that she made telephone contact with Mr. Dershowitz. She had tequested the employees be available the week of January 3, 2006. Mr. Dershowitz informed her that the assistants are out of the country and would require additional time to locate them and make them available. Investigation Continues. EEKKEARERE RAR RRR RE REET NARRATIVE HBL RARHER RARER ERAS RR ERE NA Reported By; MINOT, LORI Ss. 1/03/06 Entered By.;: ALTOMARO, NICKIE A. 1/03/06 On Thursday, 03/31/05, I started conducting surveillance at 358 E1 Brillo. At this point I observed at 1155 hours, a_Tan Altima bearing PL tag MBM Roadway, bearing FL tag jin drive, Tan Honda Civic bearing FL tag in Roadway, Black Chevy Suburban in driveway and a Black ae in driveway. At 1325 Hours I observed Tan Honda Civic nm roadway, Black Chevy Suburban in driveway, Black Caddy Escalade in drive and a White Kia eel" FL — | At 1615 hours I observed a Tan Honda Civic, in roadwey, Black Chevy Suburban_in drive, Black Caddy Escalade in driveway and a White Kia car mz: roadway. On Friday, 04/01/05, I continued surveillance at 358 EL Brillo. At 1130 hours I observed a Tan Honda Civic bearing FL tag in roadway, Black Cadd scalade in driveway and a Tan u own make/model bearing FL ta m roadway, At 1227 hours, I observed a Tan Honda Civic cadway, Black Caddy Escalade in driveway and a Black Chevy ocated behind the Escalade, At 1345 hours, I observed a Tan Honda Civic n roadway and a Black Che suv in iriveway. At 1558 hours, I observed a Tan Honda Civic IIE <n roadway, Black Chevy SUV in driveway, Black Caddy Escalade in driveway and a dark unknown model/make car parked in garage. On Saturday, 04/02/05, I continued surveillance at = a SS At 0713 hours, I observed a Red Explorer bearing FL tag in roadway and a Black calade in driveway. At 0814 hours, served a Red Explorer in roadway, Black Caddy Escalade in driveway and a Tan Honda Civ: At 0952 hours, I observed a Red Explorer a roadway, Black Caddy Escalade in driveway, Tan Honda Civic in roadway and also a Grey unknown make/model with a B.M in trunk retrieving landscaping tools. At 1155 hours, I observed a Grey Camaro bearing FL tag parking in the roadway in front of 358 El Brillo. A W/F, blond hair, teens to early 20's, thin and tall wearing a white tank top and short blue jean shorts, exited the vehicle and wi to the rear of the house. also observed a Red Explorer in roadway, Tan Honda Civic i in roadway and a Black Caddy Escalade in driveway. At 1310 hours, I GIUFFRE005681 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page665 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 69 Time: 8:47:53 Incident Report Program: CMS301L Case No. : . . : 1-05-000368 (Continued) observed a Red Explorer W/F driver leavi |e area, Tan subcompact on roadway and a Red Neon bearing FL tag Then observed 3 W/Fs, approximately 16 to 18 years of age jogging. All 3 females ran into the driveway. There were 2 with blond hair and one brown hair. On Sunday, 04/03/05, I continued surveillance at 358 El Brillo. At 0719 hours I observed a Tan Honda Civic Min roadway and a Black Caddy Escalade. At 0934 hours, I observed a Tan Honda Civic in roadway and a Black Caddy Escalade i veway. At 1057 hours observed only the Tan Honda on On Tuesday, 04/05/05, I continued su: i at 358 El Brillo. At 1052 hours, I observed a Red lorer nm roadway, a Green Explorer, bearing FL = roadway, a Grey Altima bearing FL = in roadway, White Ford Trock a roadway, Black Mercedes in driveway being washed by a B/M and an unknown dark car parked in the garage. At 1059 hours a Blue Chevy Suburban drove to the house of 358 El Brillo and park in the driveway. At 1119 hours, I observed the White Fort Truck leave the area and the drive was the pool man. At 1126 hours, I observed a Grey unknown make/model car park in roadway. W/M got out of the car and walked to a house on the south side of El Brillo. At 1406 hours, I observed a Red Explorer parked on roadway and a large white box truck parked behind the surveillance suburban. tee deeeeetee ee neet ERROR! NA RRA TIVE § 32 tt ER REAR RHE EEE NA Reported By: BATES, MICHAEL J. 1/03/06 Entered By.: ALTOMARO, NICKIE A. 1/03/06 On 03/31/05, at approximately 1500 hours while conducting surveillance at 358 El Brillo, I observed a Black Cadillac Escalade, unknown tag, a Black Chevrolet Suburban, unknown tag, a Black Mercedes S600 FL tag (QM parked in the east driveway next to the 3-car garage. There was a Tan Honda Civic FL tag HE >= 23 on the street in front of the residence. At approximately 1700 hours, I observed the Black Suburban, Black Escalade, Black Mercedes and Tan Honda Civic parked in the same place. At 1750 hours, there was no change in vehicles. At 1840 hours, I observed the Black Escalade, Black and Black Mercedes along with a Silver Hyundai Accent FL ta lall_ parked in the east driveway and a Red Ford Explorer FL’ parked on the street in front of the residence. At 2000 hours, I observed the Black Escalade, Black Suburban parked in the ease driveway and the Red Explorer and Tan Civic parked on the street. On Friday, 04/01/05 at approximately 1700 hours, I observed the Black GIUFFRE005682 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page666 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Case No. . . . : 1-05-000368 (Continued) Escalade and Black Suburban parked in the east driveway and the Tan Honda Civic parked on the stréet in front of the residence. At 1820 hours, I observed the Suburban and Civic in the same place and a Gold Chevrolet Camaro FL tag QBBBMM|parked on the street in front of the residence. At 2250 there was no change. At 2330, I observed the Black Escalade parked in the driveway and the Red Explorer parked on the street in front of the residence. On Saturday, 04/02/05 at approximately 1700 hours, I observed a Black one unknown tag, parked in the driveway and a Tan Honda Civic FL ag arked in the street in front of the residence. At 1805 heures the eee ei SSS were in the same position and the Black Mercedes FL ta was also parked in the east driveway. At 1920 hours the Escalade and Civic were the only vehicles and both were in the same position. At 2030 hours and 2145 hours there were no vehicles observed. At 2115 hours, red a Black Mercedes, 4-door parked in the east driveway PL tag At 2300 hours, 2350 hours and 0045 hours, the Black Mercedes was the only vehicle observed. AREREAA REAR ENR A RAR KAKEEREES NARRATIVE fe BQ RRAERERRE EER RRR REE NA Reported By: RECAREY, JOSEPH 1/05/06 Entered By.: ALTOMARO, NICKIE A. 1/05/06 I made contact with Mr. father of who was told that I wished to interview his daughter, stated he was aware and had spoken with his daughter about incident. He stated that his daughter had previously — | she was hired to model lingerie at a Palm Beach mansion. stated he knew nothing else about what she did when she — lo to "work." Mr. advised he would cooperate with the investigation and make his ugnter avail e for interviews. I asked if she was available for an interview Mies: she was not at home at the mom I_informed him I wou. €@ contact with her at a later time. Me Ma ==: his interest in the resolution in this matter as he stated this information has affected his daughter emotionally. On January 4, 2005, I acquired the subpoenas from the State Attorney's Office for Cingular Wireless, Metro PCS, Verizon, Bell South Telecommunications and Sprint for the unknown telephone numbers from Sarah Kellen's cellular telephone. The subpoenas were sent to the respective telephone carriers for subscriber information. I received a telephone call from State Attorney's Office, who informed me that the former houseman for Jeffrey Epstein, Alfredo Rodriguez, was present at the State Attorney's Office for an interview. Rodriguez was issued an investigative subpoena for an interview on the on-goings at Epstein's house during his employ. I responded to the State Attorney's Office and encountered Mr. Rodriguez waiting in the lobby. I brought Mr. Rodriguez to the interview room, GIUFFRE005683 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page667 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 71 8:47:53 Incident Report Program: CMS301L + 1-05-000368 (Continued) Case No. Buring a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months. He was referred by associates and his employment lasted the months of November 2004 through May 2005. His responsibilities as house manager included being the butler, chauffer, chef, houseman, run errands for Mr. Epstein and provide for Epstein's guests. Rodriguez advised he had very limited contact with Mr. Epstein. If Rodriguez needed to relay a message to Mr. Epstein, he would have to notify Epstein's secretary "Leslie" in New York City, who would then notify Epstein's personal assistant, Sarah, who would relay the message to Epstein. Rodriguez stated Epstein did not want to see or hear the staff when he was in residence. I asked Rodriguez if Epstein received many guests during his stay in Palm Beach. Rodriguez advised he had many guests. I asked specifically about masseuses coming to the house. Rodriguez stated he would have two massages a day. Epstein would have one massage in the morning and one massage in thé afternoon everyday he was in residence, Rodriguez stated he would be informed to expect someone and make them comfortable until either Sarah or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them entry into the kitchen area and offer them something to drink or eat. They would then be encountered by either Sarah or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. He advised he didn't ask their ages but felt they were very young. Rodriguez stated they ate like his own daughter who is in high school. Rodriguez stated they would eat tons of cereal and drink milk all the time. Rodriguez stated the girls that would come appeared to be too young to be masseuses, He st, ler Epstein's direction, he delivered a dozen roses to High School for oneof the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the massages. He felt there was a lot more going on than just massages. He would clean Mr. Epstein's bedroom after the alleged massages and would discover massager/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's bed. Epstein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl he brought the roses to, so that she could drive her self to Epstein's house without incident. Rodriguez said the girl always needed rides to and from the house. Rodriguez referred himself as a "human ATM machine" and was ordered by Epstein to maintain a minimum balance of $2,000 dollars on him at all times. When a girl would come by the house and Mr. Epstein was either not in residence or ‘was not at home at the time, Rodriguez was to provide the girl (masseuse) several hundred dollars for their time and to notify Epstein the amount they were given. Epstein also ordered Rodriguez to GIUFFRE005684 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page668 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 72 Time: 8:47:53 Incident Report Program: CMS301L Case No. 1-05-000368 (Continued) purchase several gifts and provide them as tips to the girls. I asked what kind of gifts: Rodriguez stated he purchased IPODS, jewelry, anything the girls would want. Rodriguez stated the amount of girls that came to the house was approximately fif' girls knew each other and all seemed to know at High School who Mr. Epstein was. When asked to identify these girls, Rodriguez stated he could not at the moment but knew he wrote their names down on a journal he kept during his employ with Mr. Epstein. He kept a journal in the event he needed to explain either to Mr. Epstein or his assistants what was done at the house or who visited the house as he stated he was in-charge of Mr. Epstein's personal security while in Palm Beach. I informed him I would need to view this journal to which he stated he would research the book and contact me to provide the book. The interview was concluded and left the area. I returned back to the police station where the micro cassette was placed into evidence. At approximately 7:20 pm, I was notified Rodriguez located the journal and would call me on January 5, 2005 to provide the journal. Investigation Continuesaa SteRER RARER ERE NA RRA TIVE § 24 #eeeRERERRERA RRR ERE NA Reported By: RECAREY, JOSEPH 1/03/06 Entered By.: ALTOMARO, NICKIE A. 1/10/06 On January 5, 2006, I attempted to meet with Alfredo Rodriguez to recover the folder or journal in which he kept the notes that were given to him during his employ with Mr. Jeffrey Epstein. He kept this folder to justify what he did during his employ should the need arise to justify what occurred with the monies he had to keep or any questions as to the petty cash he withdrew from the household account from the bank. At approximately 10:00 pm, I attempted contact with Mr. Rodriguez and discovered he was assisting his wife at her place of employment and would not be able to meet with me. Mr. Rodriguez stated he would meet with me on January 6, 2006, in Broward County, in the morning hours. On January 6, 2006, at approximately 9:00 am, I received a telephone call from Mr. Rodriguez who advised he had the file in hand and would be traveling northbound to meet with me in Broward County. At 10:50 am, I met with Alfredo Rodriguez at the parking lot of Bank of America in Boca Raton on Yamato Road and Military Trail (known as the Polo Center). Rodriguez produced a green folder which contained documents, a note with Mr. Ep: u with direction to deliver a bucket of roses ia: School atte ie high school drama so in that same note was direction to rent a car for jand direction to extend the rental contract. I returned to the Palm Beach Police Station and placed the folder into evidence. 3 I received a fax from Verizon from the subpoena request sent on GIUFFRE005685 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page669 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page Time: 8:47:53 Incident Report Program: CMS301L. (Continued) Case No. . . . +: 1-05-000368 01-04-06, for telephone number ars The phone number is registered to Dr Perry Bard, from West isa chiropractor and has an office located in West Palm Beach. The cellular number is Dr Bard's personal cellular number. On January 9, 2006, Det. Caristo and I traveled to eS Palm Beach Gardens in an attempt to locate Johanna Sjoberg, who had been previously seen on the property and identified through her Florida Drivers License and Florida license Plate. A business o was left for her to return call. We then traveled to the GR Foundation and locate wae agre ro} speak with us and in a private room within the school provided us a taped statement. During the statement, dvised that when she was fifteen or sixteen ye age, she was taken to Jeffrey Epstein's house by her associate, ME <2-<< this occurred late May 2004 or early June 2004. She was told she could model lingerie for money for a wealthy Palm Beacher, She remembered they traveled by yellow cab from their residence in West Palm Beach to Epstein's house. She remembered encountering Epstein at the front door during the evening hours. He introduced himself and brought them into the kitchen so that the chef could prepare somethi: ng for them to eat. After having a meal, == = had a large bathroom. She opserved a large style shower, sauna and land Epstein brought there was a large massage bed also in the bathroom. Epstein entered a room within the bathroom and came out wearing on . said they would provide a massage on his feet. a why they are doing this. a eT her this was part of ine and told her to rub his legs and calves. Epstein had told coe calve comfortable. Epstein's direction, by herself. Epstein To. Oo get comfort: her blouse and pants and stayed in her panties. stated she was not wearing a bra. She believed she was wearing thong panties. Epstein turned over onto his back and began touching her. Epstein continued rubbing Epstein's ft the room leavin touched her breasts and began touching her in her vagina area ro Epstein instructed her to rub his chest and rub his nipples. stated the touching consisted over the panties on the first t stroked her vagina but stayed on top of the panties. During the first massage, she stated Epstein was stroking her and began masturbating himself at the same time. He put his hands under the towel and appeared as to masturbate himself however she never saw his penis. She continued rubbing his chest until he grabbed her and pulled her closer to him. He appeared to have climaxed because after he pulled her closer to him the massage was over. Epstein had told her that there was two hundred dollars for her on the dresser. He told her that she could not tell anyone what happened at the house or bad things could happen. es upstairs to a master bedroom which tated she went to Epstein's house three GIUFFRE005686 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page670 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page Time: 98:47:53 Incident Report Prograr Case No. . . . : 1-05-000368 (Continued) or four times total. was very scared and felt very nervous. | She knew because of Epstein's money he was powerful. After the massage, Epstein ordered his houseman at the time to drive the girls home. The employee was to drop off the girls at their house and watch them go inside their house. could not remember who the houseman was. She stated Epstein anda fis assistant Sarah would call her at her father's house to arrange for her to come and "work," She advise i she returned to the house, Epstein would do the same thing. tated it was a routine with Epstein. She would rub his feet and calves. He would then turn over and begin to touch her on her vagina area. The only aifference was that it was done without panties. Epstein's fingers would’ stroke her vagina area as he would masturbate and finally climax and the massage would be over. She was paid $200.00 each time she went. Each time she went she was reminded not to speak of what happened at the house and that she would be contacted again. She began to purposely miss the calls when_either Sarah or Epstein would call her. She once brought a friend, w= name, to work for Epstein. She was paid $200. ie os ll zs) stated she no longer retuned to work for Epstein. She also stated wanted to notify the police of what happened at the house. ania: she was scared of what could have happened to her or jer family if she notified authorities. On January 10, 2006, I received the results from the subpoena from BellSouth Telecommunications for telephone number The mumber is assigned to s father in Palm | | Beach Gardens. I also receive stern Union which | { | confirmed the money order sent to from Jeffrey Epstein in New York City. The "wire" was sent by Jeffrey Epstein of 457 Madison Ave in New York City on December 23, 2004 at 12:05 pm. The amount of $222.00 was charged to Epstein's credit card so that could receive $200.00 in Royal Palm Beach. The twenty-two Ollars was for processing and local fees to sen via Western Union. A copy of the check presented to as a attached to the receipt of the wire. This confirmed what advised she received as a Christmas bonus from Epstein. Investigation continues. FRE NRA RAARRKRAR HARARE NA RRA T IV BE $35 tHRRRAR RRR AR RRR Re NA Reported By: RECAREY, JOSEPH 1/10/06 Entered By.: ALTOMARO, NICKIE A. 1/10/06 I received and reviewed the Cingular Wireless results from the joena requests for subscriber information for telephone numbers } The first number, | is assigned to Janusz Banasiak in care of Jeffrey Epstein of 457 Madison Ave in New York City. Banasiak is the current houseman/house manager for 358 Bl Brillo Way in Palm Beach, Fl 33480. The second number, ie is assigned to Christina Venero of GIUFFRE005687 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page671 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 75 Time: 8:47:53 Incident Report Program: CMS301L Case No... . : 1-05-000368 (Continued) West Palm Beach. Research conducted on Venero reve she is a licensed Massag ist with a Florida conditional/active license | Venero had been previously arrested for battery / unwanted t = id DUI. Requests for copies of the reports involving the arrests were reque Palm Beach County Sheriff's Office. = The last =U assigned to Thomas Rofrano Of (NM Palm Beach Gardens. Research on Mr. Rofrano, revesied that he is a Florida Chiropractic Physician, Vehicles that were previously documented on the property while surveillance was being conducted were res. I determined a tan Chevrolet Camaro, bearing Florida license was seen on the property in which a young white female wa: tering the Epstein property. Res ch i revealed that the vehicle is as two daughters, s currently residing in Connecticut an e@Siding with her father in Lake Worth. Research on xevealed she was recently involved in a traffic stop in Lake Clarke Shores in May 19, 2005. A request to discover any information from the stop was requested. I spoke with ASA Daliah Weiss who informed me that Janusz Banasiak will be available for an interview tomorrow at the State Attorney's Office in West Palm Beach at 1:30 pm. I informed her that I would be at her office for the interview. ERKKKK AREER KARE EEEE NARRATIVE BG RHRRKRKKHERREREAKER RR EEE NA Reported By: RECAREY, JOSEPH 1/23/06 Entered By,: ALTOMARO, NICKIE A. 1/23/06 006, Det. Caristo and I met with Johanna Sjoberg at m Palm Beach Gardens. Sjoberg was identified as a iicensed massage therapist who had previously been seen on EZpstein's property when physical surveillance was done. Sjoberg was told of the on going investigation and I felt she may have information pertaining to the case. During a sworn taped statement, Sjoberg stated she met Epstein three years ago when Ghaline Maxwell approached her while she was attending Palm Beach Atlantic College to work around Epstein's house. Maxwell had told her that they needed some girls to work at the house to answer phones and run errands. Sjoberg accepted the job and began working at Epstein's house on El Brillo in Palm Beach. Sjoberg stated it was a part time job during the time she went to Palm Beach Atlantic College. She continued going to Epstein’s house and would be notified when Epstein would travel to Palm Beach. Sjoberg advised she would be notified by Maxwell, Bostein or Sarah, his assistant, when he would travel to Palm Beach. Sjoberg stated she began providing massages to Epstein before she became a massage therapist. She continued giving massages not only to Epstein but to Nadia Marcinkova, and Sarah, his assistant. Sjoberg was asked about what occurred during the massages. Sjoberg stated as she was twenty GIUFFRE005688 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page672 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 8:47:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) three years old when she met Epstein, anything that happened was between two consenting adults. I explained to her that she was not in any trouble however as part of this investigation, I needed to ask certain questions. Sjoberg stated that there were times that Epstein would ask her to perform during the massage. He would instruct her, to rub his nipples as he masturbated himself. Sjoberg stated she felt "grossed" about the behavior but as she was getting paid, she just continued. Sjoberg also advised she would on occasion perform the massages naked. Epstein would on occasion, utilize the vibrator/massager on her vagina area when she performed the massages, Sjoberg explained that Epstein never exposed himself to her as he maintained himself covered under the towel he would be wearing. When Epstein would masturbate he would be covered. I asked if Sjoberg ever received any gifts, or any gratuities from Epstein. Sjoberg advised aside from being paid well, she advised Epstein took care of her tuition from Palm Beach Atlantic College. She received a rental car for a week when her scooter broke down. Additionally she received other gifts from Epstein. Epstein also recommended her to another client who resides at Breakers Row in Palm Beach. The client she was referred to was "Glenn" unknown last name, and his wife, who she provided a massages to. The statement was concluded and placed into evidence upon our return to the Palm Beach Police Department. While at the police station, I researched Florida tag HE ich was also previously seen on the property when there was physical surveillance being done at the property. The vehicle is registered to Lake Worth, Florida, (BBM anc the vehicle revealed that his daughter, had been driving the vehicle and was cited for unlawful speed in Lake Clark Shores The vehicle is a tan, et Camaro, 2-door. TI a te of birth, 987, resides at pace page called In her web page, shows various photos of photographed at a beach. An interview is forthcoming. A review of the video disks which was extracted at the Palm Beach County Sheriff's Office Computer Crime Unit revealed that only one hidden camera was functional at the time. Several images of Epstein working at his office were seen. Additional footage of Sarah Kellen and Nadia Marcinkova was seen. There was other footage of females seen. The identity of the females is unknown at this time, until such time as I meet with certain females to show the video footage to confirm if, in fact, it is them on the video. At this time it appears = and Haley Robson are seen sitting with Epstein beside his desk in the evening hours. Due to poor lighting, a direct confirmation cannot be made at this time. Inv. Continues. GIUFFRE005689 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page673 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 77 8:47:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) See H AE AEA ARR EEEEREAEEEH KEES NA RRA T IV EB 9 37 £tkeeeeReRE RAR REE ER EE EE NA Reported By: RECAREY, JOSEPH 1/30/06 Entered By.: ALTOMARO, NICKIE A. 1/30/06 On _Janua: 25, 2006, Det Carist Wded_to eS met with stated last year, when she was seventeen ve @, she met Jeffrey Epstein through her former room mate MMMMMMMI2s allegedly dating Epstein at the time jane once cohabitated together when they modeled. explaine: called her on her telephone and advised her that she was in Palm Beach and requested to see her GB nade arrangements to 1) t Epstein's house. | arrived and met Epstein and and went to the Palm Beach Mall together and went shopping. advised that SM and she had received money from Epstein to go to the mall. They visited victoria's Secret and purchased undergarments from the store utilizing monies given by Epstein. advised she purchased one item and MMMM purchase various items. The money used to purchase the items was the money given by Epstein. ret. continued shopping and having a day together. a stated plained how she and Epstei en dati other and he has been paying all of her bills. Ta imed fl civ sea they met in New York and had been dating ever since. They later returned to Epst me and encountered Epstein. He had a brief conversation with ut her modeling career. He knew of her modeling career fro He requested to see her modeling io and explained that he cou. her with modeling jobs. ad her book with her to show and showed the book to a He commented negatively abou er photographs and portfolio. felt uncomfortable with the comments made as she had been working with other professional modeling companies who had offered her work from her photograp) tein requested to see what was purchased at the mall. ook out the undergarments which were purchased. She immediately showed Epstein different chased. Epstein then requested to view what BI uchased . a: reluctant to show the outfit however since it was Epstein's money that purchased the he pulled it out of the bag. Epstein asked her to try it on. looked at MBBMMwho told her "yeah, try it on." Feeling compelled to try the undergarment outfit on; she went to another room and put on the bra and panty set. She walked out to the living room where they were sitting, and modeled the suit, She then went back into the other room and chai ck into her clothes. returned into the room an she would be going home. scheduled another day for ito return for massages with her. tated within that same week, she returned to meet with and have a massage. ad told her that she would be unable to stay with her as she wou. e going on a bike ride with Epstein. explained she could stay at the house and take advantage of the massage. GIUFFRE005690 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page674 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT 8:47:53 Incident Report Case No. + + = 1-05-000368 (Continued) tated she met with an unknown herapist and had the already set up in a guest room emoved her clothing, leaving her panties on, and wrapped herself with a towel for the massage. =a remembered that the door to the guest room was closed but not locked. As the therapist was working her back, the door was opened by Epstein and entered into the room. MENMMM—Mwas trying to conceal herself as Epstein was talking to her about hi ractic session. Epstein told§MMMFurn over onto her back. aa eventually turned over exposing her breasts to Epstein as he applied pressure on_her shoulder and her waist. QBBMMstated epstein "popped" her back. emoved her se’ he table, got dressed and left the house further state ad attempted to call her several occasions t ‘ her back to Epstein's house to os il ss 'm busy." dvised she has not had contact with ei effrey Epstein. It should be noted that her mother, fas present during the interview. The interview was concluded and we thanked them her for their time. Skee HeARReREREHEEREAEREEAAE NA RRA TIVE #§ 39 ttttthetieereneeteneeeenee NA Reported By: RECAREY, JOSEPH 1/31/06 Entered By.: ALTOMARO, NICKIE A. 1/31/06 — lee I made telephone contact with Christina Venero, at Venero is a licensed massage therapist who had frequented the home of Jeffrey Epstein. Ms. Venero has been unable to meet with me in Palm Beach County, and because she lives and works in Port St Lucie, a telephone interview was conducted. I explained to Ms. Venero that there was an on going investigation involving Jeffrey Epstein. Venero stated she knows Epstein and has been employed by him for approximately three years, Epstein has paid Vemero to perform Swedish Massages (Deep Tissue) on him and other guests. Venero explained that approximately three year ago she met Ghislaine Maxwell and Jeffrey Epstein through a mutual friend. Epstein and Maxwell were looking for a massage therapist. Venero stated since that time, she is notified when Epstein is coming to Palm Beach. Venero stated she comes to his house and provides the massage or massages. Venero explained she has also massaged his guests and assistants. enero continued that she is paid $100.00 and hour for the massage. I asked Venero if anything occurred during the massage that would have made her feel uncomfortable. Venero stated she only provided massages and that was it. She never was approached for anything else. I asked if Epstein ever asked her to rub his chest she stated she would not rub his chest as that is not part of her massage. Venero explained that she was not Epstein's type. The girls she’ would see at Epstein's house were very thin, beautiful and without tattoos. Venero explained she has several tattoos that are visible. Maxwell and Epstein have commented negatively about her tattoos previously when she has provided massages. GIUFFRE005691 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page675 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 79 Time: 8:47:53 Incident Report Program: CMS30iL Case No. . . . : 1-05-000368 (Continued) Venero stated she only provided massages for Epstein and his associates and nothing happened during those massages. Venero stated as she does Swedish style massages, the patient is usually sore after the massages. I thanked her for her assistance and the interview was concluded at this time. I received a facsimile from T-Mobile Cellular service on telephone number MBM. swhich is assigned to David Rodgers, pilot for Mr. Epstein, who resides in Lake Worth. Rodgers' telephone number was dialed on several occasions by Sarah Kellen. A background on Rodgers indicated he has a valid FAA pilot license First Class for the Southern FAA Region, Rodgers has another historical FAA license for Airline Transport Pilot. Investigation Continues. HEKRKEREESEE KE KARKAEAAERESE NARRATIVE HBG RERRETEARAAKHRARERKREEEEES NA Reported By; RECAREY, JOSEPH 2/14/06 Entered By.: ALTOMARO, NICKIE A. 2/16/06 Xs Ty 3, 2006, I had made arrangements to meet with tt the Palm Beach Police Station. At approximately and her friend, arrived at the police station. During an interview witn She stated she met Epstein when she turned eighteen ye! id was brought to Epstein's house to provide a massage. She advised this occurred on May of 2005. She advised Haley Robson had informed her if she wanted to provide a massage for $200.00. reed and was brought to Epstein's house to provide a massage. stated she_had been to the house on many occasions during the massage sessions. also stat e would remove her clothing to provide the massage on Epstein. dvised Epstein would pay her $300.00 to rub his back, legs and chest. During the massages, Epstein would masturbate himself as she rubbed his chest, I asked her if Epstein ever touched her breasts during the massages. a «= " » I asked her if Epstein ever touched or massaged” fe. io. MM 2:52 he had on several occasions. I asked her g penetrated her with either his penis or any other objects. iS: that during a massage he inserted his fingers in her vagina as she massaged him. She stated this occurred one time only. stated the massage would be over when Epstein would climax onto a towel, I asked f she had_any formal massage training to which she replied that she did not. Ue then asked if she ever brought anyone to the house to "work." [——— she brought two people to the house. She advi. ceived money for bringing people to the house to "work." stated she brought a gi: and her friend i itt in tne lobby of the police station. Ea or her time and her cooperation and escorted her to the lobby. 1:00pm, I asked Ms MBBBMMKf I could speak with her about this investigation. I GIUFFRE005692 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page676 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 80 8:47:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) brought her to the interview room and explained to her that I was conducting an investigation on Jeffrey Epstein and_felt she may have information, the investigation. Ms identified herself as id resides in Wellington, Florida. She advised approximately a year ie she was brought to Epstein's house to stated she needed to make money and e was ein and his provide a massage for money. felt it was a quick way to make some money. stated brought to the house by §MMbod was introduced to @ assistant. She was brought to his main bathroom and prov, massage, I asked her if she provided the massage naked. ed she did. She rubbed Epstein's legs, back and chest. [I al LE Epstein touched her during the massage. She advised he did not, however he did masturbate himself as she rubbed his chest. Once he climax massage was over. She was paid her money and left the area. advised it occurred one time and she never returned to Epstein's house. The interview was concluded and was escorted to the lobby. I located a telephone number for ind attempted to contact several occasions. calle d spoke with Ms. ho advised she would speak with me in Deerfield Beach where she resides. Due to a scheduling conflict, we were unable to meet. I informed her I would contact her to schedule another appointment to speak with her about this investigation. JI have attempted to meet with her and make telephone contact with negative results. On February 13, 2006, I met with David Rodgers at in Lake Worth. Rodgers was identified as Epstein's pilot. I spoke with Rodgers who advised he has been employed with Epstein since 1991. He flies both planes for Epstein depending where he wants to fly to. Rodgers was asked about passengers in the plane he flies. Rodgers stated unless Epstein flew to his island off of St Thomas, there would be no way of knowing who the passengers were. I mentj nt flight to Ohio; where Rodgers flew to Ohio to pick Rodgers he recalled flying on several occasions 1 remember Rodgers stated once he is in the cockpit, he does not kriow who the passengers are. When he prepares the passenger manifests, he lists Epstein and his assistants he knows by name, Sarah and Adrianna. Rodgers stated he would list either female or male passengers on the manifests only to keep a count on the passengers. Mrs. Rodgers came into the living room and recommended that her husband consult with an attorney. Mr. Rodgers agreed he would speak with the family attorney to inform him of this questioning. I explained to Mr, Rodgers that he was not the suspect in this investigation and ceased all questions. Based on the fact Rodgers could not advise who passengers were in the plane, I then left the area. rattenpted to 1ccot hh a: Wellington. I left my business card for her to return my call. February 14, 2006, at 12:06 pm, I received a call back from Ms. a A GIUFFRE005693 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page677 of 883 PALM BEACH POLICE DEPARTMENT Page: Incident Report Program: CMS301L Case No. 1-05- 0 (Continued) left her telephone number for a return on my voice mail.- Ms > arian I left her a message to return call. Investigation Continues.. Feehbee heehee eee ee eeeEREEEEH MN A RRA TIVE $40 #t#hkteettrtekeeeeanceeenee NA Reported By: RECAREY, JOSEPH 2/21/06 Entered By.: ALTOMARO, NICKIZ A. 2/22/06 On February 15, 2006, I made telephone contact with es. provided dir: could locate her. -Det Caristo and I responded to n Li ‘k to meet ch an Upon eet ll the parking lot directly behind MAACO Auto Painting. She was advised I was there to speak with her about an foing investigation that concerned Jeffrey Epstein in Palm Beach. jstated she knows Epstein very well and did not want to speak with me about Mr. Epstein. She was very fond of Epstein and did not want to speak with me about anything concerning Jeffrey Epstein, I explained to her that she was seen at the house and I would like to speak with her. She stated she knew there was an investigation and that I had spoken with other people and therefore IL should know what happened at Epstein's house. lended the conversation and walked back into her boyfriends business, Blanton Automotive. Det Caristo and I left the area and returned to the police station. Investigation continues. AEKKERARHREAKKAAAAEREAESAHAEEN RRRATIVE BAL FARRAR EH REAERRER EER HEE RE NA Reported By: RECAREY, JOSEPH 4/10/06 Entered By.: ALTOMARO, NICKIE A. 4/10/06 A Grand Jury Session was requested during the month of February 2006, in which all the girls that had been interviewed would have been called to testify before the Grand Jury to seek an indictment against deffrey Epstein. Due to subsequent meetings with the State Attorney's Office and Defense Attorney Alan Dershowitz the Grand Jury was postponed until a later time. Dershowitz had provided a package of material on the main victims in this case in which they appear on myspace.com and speak about alcohol use and some marijuana use. The State Attorney's Office wanted time to review the material. I requested additional subpoenas from the State Attorney's Office in which I requested information from Dollar Rent a Car and Jet Aviation. The information requested from Dollar Rent a Car was for the rented vehicle by Alfredo Rodriguez while under the employ of Epstein for one of the victims. The other subpoena requested was for Jet Aviation for dates and times when Epstein's planes were in Palm Beach County. I continued to research other names that were acquired either from interviews or intelligence gathered during the investigation. If GIUFFRE005694 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page678 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 82 8:47:53 Incident Report Program: CMS301L Khe NA Case N 5-000368 located in Royal Palm Beach. oyal Palm Beach. During the i: stated she knew I would be speaking with her. first introduced to Epstein when she turneucigitcen she was sure of her age as it was her senior year in igh School. She advised she was brought there to make money and was told she would have to provide a massage to this Palm Beach guy. She remembered she met Epstein and his assistant Sarah in the kitchen area. She stated she was taken by one of her friends, BBBMMJShe stated she went upstairs with Sarah whil i got ready for the massage. He exited his bathroom naked =z a. Epstein asked her if being naked offended hef stated it made her le. Epstein then put on a towel and lay on the table. ae: she rubbed his back and feet She stated she had no Seage eraining or experience. tated during the massage, Epstein attempted to touch her buttocks pulled away as he touched her buttocks. She told him again she was uncomfortable with him touching her. Epstein then cut the massage short and became upset with her. Epstein $200.00 for the massage and told her to leave the house. z returmed to the house. She did advise of ene she went wit, however she waited in the car for 6 she did not want to go into the house. lusion o: s visit with Epstein they left the area. Istated she nad neard from other girls that have gone to the house that Epstein now required them to do the massage naked and allow him to touch them in their private areas for monies. The interview was concluded as did not have any other information to provide. I then learned from the original victim, rt the defense attorney had learned of her identity. I spoke with the father of the victim, who stated there has been a private investigator on his house photographing his family and chasing visitors who come to the house. He provided a Florida License of This vehicle is registered to Ivan Robles of West Palm Beach. Robles is a private investigator intern who is licensed by the state. I informed the State Attorney's Office of the above information. I received the Grand Jury subpoenas to be delivered to three victims for a Grand Jury session to be held on April 18, through April 20, 2006. Investigation continues, teRKERESHAEAEAEAARAAEER NARRATIVE HAD RRREARR ERA RRR RE REE RE Reported By: RECAREY, JOSEPH 4/14/06 Entered By,: ALTOMARO, NICKIE A. 4/18/06 The Grand Jury Subpoenas were personally served to the individuals they were issued to. On April 5, 2006, at approximately 7:30 p.m., T personally served the parents of hho had informed me that the private investigators were still photographing the family. On April GIUFFRE005695 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page679 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 83 Time: 6:47:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) 10, 2006, at approximately 2:30 p.m., I served | & her dence in Royal Palm Beach. The subpoena was given to her mother, I learned through one of the victims MMM that she was personally contacted through a_source that has maintained contact with Epstein. The source assured MlMshe would receive monetary compensation for her assistance in not cooperating with law enforcement. AH also stated she was told, "Those who help him wi compensated and those who hurt him will be dealt with." I told that tampering with a witness/victim is an arrestable offense and very serious. I asked her who approached her during this encounter .{MBMMM originally was reluctant to provide the name of the person who approached her to offer her not to testify because she felt they were still friends. On April 11, 2006, Det Dawson and I traveled to Tallahassee, Florida and met with the victim, Mil Milicent. i W/F, |) as the person who approached her in Royal Palm Beach while she was home during Spring Break in March 2006. a stated she did not want to pursue the intimidation charges on Ss concerned that the defense attorney was given a copy of the report as in things she had told me in confidence were repeated to her by — Prior to our departure, the victim was given a copy of her ypoena for the Grand Jury which was scheduled to commence April 18, 2006. Upon our return from Tallahassee, I notified the State Attorney's Office of what was told to me. I also notified them that the subpoenas were delivered to the witnesses and they would be calling for arrangements for the date and time needed for the Grand Jury. I spoke with ASA Weiss and informed her of the possible intimidation by the defense. On April 13, and April 14, 2006 I attempted contact on several occasions with ASA Weiss and ASA Belohlavic to ascertain when the victims needed to report for Grand Jury testimony. Messages were left on their voicemail. On April 17, 2006, during the hours of 9:00 am and 11:30 am, I again left messages for ASA Weiss and ASA Belohlavic for either of them to return my call as I had not heard from the State Attorney's Office as to the time and date of the Grand Jury. At approximately 12:30 pm, I went to the State Attorney's Office and located ASA Weiss and ASA Belchlavic in their offices. I entered ASA Belohlavic's office who informed me that she was going to return my call. She explained that an offer was made to the defense, Atty Guy Fronstin and Atty Alan Dershowitz. The offer is 1 count of Agg Assault with intent to commit a felony, five years probation, with adjudication withheld. Epstein would have to submit to psychiatric/sexual evaluation and no unsupervised visits with minors. When asked about the all the other victims, Ohlavic stated that was the only offer made as to one victim, ASA Belohlavic cell phone rang and went to voice mail. She checked her voice mail and played the message on speaker. The caller identified himself as GIUFFRE005696 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page680 of 883 PALM BEACH POLICE DEPARTMENT Page: a4 Incident Report Program: CMS301L No. , . « : 1-05-000368 (Continued) Atty Guy Fronstin and acknowledged the deal made between them. Fronstin stated in the message, he spoke with his client, Jeffrey Epstein, and agreed to the deal. Fronstin asked to call off the grand jury as they would accept this deal. Belohlavic stated a probable cause would be needed to book Epstein in the county jail and would let me know as to when it would be needed. TI explained my disapproval of the deal and not being consulted prior to the deal being offered. However I expressed that was only my opinion and the final approval would come from the Chief of Police. She explained to have Chief Reiter call Barry Krisher about the deal. I left the area and returned to the police station where I briefed the Chief about the deal offered. I checked my voice mail messages and discovered a message from stepmother for the victim|MMMShe was calling because the State Attorney's Office still had not returned any of her calls as to when they are needed for this case. I then called ASA Belohlavic's office and left messages for her to call the victims on this case and explained to them what the State Attorney's Office had done. On April 17, 2006, at approximately 4:30 pm, State Attorney Investigator Tim Valentine called to officially notify me of the cancellation of the Grand Jury. He requested I contact the victims that had been served to appear, to notify them of the cancellation. I advised Valentine that as this Grand Jury session was called based on the State Attorney's Office decision to have the victims heard by the Grand Jury that I felt it was the States Attorney's Office responsibility to contact the victims and advise them of the reason they were no longer needed. HAHRRERHERERARE RTA ERATOR NARRATIVE § 43 *#0eeERRRE EH ER RRR E ER EERE NA Reported By: RECAREY, JOSEPH 5/04/06 Entered By.: ALTOMARO, NICKIE A. 5/04/06 As I had not received any contact from anyone at the State Attorney's Office, on May 1, 2006, I prepared three arrest warrant requests and submitted them to the State Attorney's Office. The packages were delivered to the Crimes against Children Unit in care of ASA Lana Belohlavek. Jeffrey Epstein's arrest warrant was requested for 4 counts of Unlawful Sexual activity with certain minors and one count of Lewd and Lascivious Molestation. Sarah Kellen, Epstein's assistant's, arrest warrant request was for 4 counts of Principal in the 1st degree Unlawful Sexual activity with certain minors and one count of Principal in the 1st degree Lewd and Lascivious Molestation, Haley Robson's arrest warrant request was for Lewd and Lascivious Acts on a victim under 16 years of age. The receipt of delivery was signed and brought back to the records division at the police department . On May 3, 2006, at approximately 2:54 pm, I received a telephone call from ASA Daliah Weiss on my cellular telephone. ASA Weiss advised she (GIUFFRE005697 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page681 of 883 PALM BEACH POLICE DEPARTMENT Incident Report Program: CMS301L Case No. . .. : 1-05-000368 (Continued) has been taken off the Jeffrey Epstein case because her husband is employed with Attorney Jack Goldberger. Attorney Goldberger is the 1 attorney of record for Jeffrey Epstein. His previous attorney, Guy | Fronstin, has been fired from representation. ASA Lana Belohlavek has been assigned the case. ASA Weiss stated she can no longer speak about the Epstein case with me. I thanked her for her telephone call. ASA Weiss further stated that ASA Belohlavek would be calling me. HAKEEHER RAKE REREAD NARRATIVE HAL BERRA RR ARERR AREER ERE NA Reported By: RECAREY, JOSEPH 5/15/06 Entered By.: ALTOMARO, NICKIE A. 5/15/06 On May 10, 2006, information was received that Epstein's associate, Leslie Wexner, The Limited Inc, CEO's, plane had arrived in West Palm Beach, PBIA. The plane, a Gulfstream 4 bearing a N900LS registration, was on the tarmac at Galaxy Aviation. As Epstein had recently acquired the services of a new attorney, and the fact that Epstein's house is currently under remodeling, it was believed that Epstein may be in Palm Beach. I conducted physical surveillance at the residence, 358 El Brillo Way. I observed a large construction crew conducting remodeling at the house. The contractor, David Norr, was observed driving a Ford Explorer, white in color. The vehicle has a Florida registration of F30QQF. Norr left Epstein's house and traveled north on County Road. Det Caristo and I conducted surveillance on Norr. Norr traveled to several construction sites and checked on certain jobs. Surveillance was discontinued on Norr and Det Caristo and I traveled ta-Galaxy Aviation. I observed the white plane with a blue stripe along the body and tail of the plane; the tail number was visible on the bottom of the tail, closer to the body of the plane. We maintained visual surveillance on the plane until 4:57 p.m., when a caravan of Cadillac Escalades drove onto the tarmac. We observed several people exit the vehicles and discovered that they were part of the executive team for Limited Inc.’ The executives were in Palm Beach County for an executive meeting for the day. They arrived in Palm Beach County on May 9, 2006 at 9:30 pm and were scheduled to leave on the 10th at 5:00 pm. On May 12, 2006, I met with ASA Lana Belohlavek at the State Attorney's Office. She explained that her boss, Barry Krischer, was requesting this case be taken to the Grand Jury again. I explained to her I had requested arrest warrants for Jeffrey Epstein, Sarah Kellen, and Haley Robson. I asked that she either issue the warrants or direct file, as so much time has elapsed since the original request to the Grand Jury. I explained that the Palm Beach Police Department had i concluded the case in December of 2005 and has been waiting for the case to go forward. Belohlavek stated the original offer was again j offered to the new defense attorney. She was waiting for their answer by Friday May 19, 2006. She stated she would advise me of the answer. j HEKKEAAERAEEAAEAEERAKEREARER NARRATIVE 5 FARAH RARAA HERR EERE REAR NA Reported By: RECAREY, JOSEPH 6/05/06 | GIUFFRE005698 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page682 of 883 Date: 7/25/06 Time: 98:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 86 Program: CMS301L On May 22 from Mr. investig' running errands throughout the county, 1-05-000368 Entered By.: ALTOMARO, NICKIE A. (Continued) 6/06/06 2006, I received several phone calls throughout the day ho st, d he had been followed aggressively by a private Or. Mr, tated that as he drove to and from work and the same vehicle was behind him running other vehicles off the road in an attempt not to lose sight of hicle. Mr. I explained to him as Mr. Epstein had retained new legal council it was possible it would be new private investigators following him to observe his daily activities. I also explained to him that there was a meeting scheduled with ASA Lana Belohlavek and Attorney Jack Goldberger at Mr. Krischer's office scheduled on June 1, 2006 at 9:00 am. I attempted to call ASA Lana Belohlavek to inform her of the private investigators following Mr. Jp during the week of May 22 through May 30 2006. On May 23 plate information. aggressively and caused Mrs. the vehicle is a green Chevy ' 2006, The subj o run off the road. mte Carlo bearing Florida tag The vehicle is registered to Zachary Bechard of Jupiter Florida. owever; she was on her vacation I received other phone calls from Mr. and Mrs.{—Who advised they were able to acquire the private investigators license Bao them was again 0. Bechard is employed with Candor Investigations from Jupiter, Florida. Bechard is a licensed Private Investigator in the State of Florida. Since the discovery of the threat made against one of the victims in this case received from cell phone an University the exact dates of Spring Break for 2006. 2006 through March 12, 2006. I re ome phone was from March 4, from Sprint/Nextel with all calls made during the month of March 2006. I reviewed the $89 calls made and r 2006. I observed on March 7, 2006, five calls during that day. Date 7-Mar-06 7-Mar-06 -Mar-06 Mar-06 Mar-06 axr-06 Time 11:03 AM ii: ats Li: tle 12: 16 22 37 33 02 AM aM AM AM PM Seconds 492 6 B87.2 48 28.2 727.2 In/Out Outbound Inbound Inbound Outbound Inbound Inbound To/From 561XXxxX 561XxXxK 561XXxx ested subpoenas for all calls made to and luring the month of March 2006 for her had confirmed with Florida State The Spring Break I received a subpoena during the month of March ade and received thirty table reflects the date of the calls, time of day (EST), duration GIUFFRE005699 CONFIDENTIAL 1 { |

Case 18-2868, Document 283, 08/09/2019, 2628241, Page683 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT a7 8:47:53 Incident Report CMS301L. : 1-05-0003638 (Continued) seconds, inbound or outbound calls and c de to or from MMMMMMs phone. On March 7, 2006, at 11:03 am, made a call to the victim mich lasted 492 seconds (8 minutes and 2 seconds) . The victim then returned the call at_11:16 am which lasted 6 seconds. The victim then made contact with MMMM at 11:22 am for 877.2 seconds (14 minutes and 6 seconds). These sequences of calls were consistent with what the victim had described to me on the date of th intimidation. Immediately after speaking with the victim, [IREEka%es a call to Sarah Kellen, Epstein's assistant, which lasts for forty-eight seconds. A call is then immediately received, a telephone number registered to a Corporation affiliated with Jeffrey Epstein located at 457 Madison Ave in New York. An extensive computer check revealed 457 Madison Ave is a business address in which Epstein has his corporations assigned to. Epstein had corporation attorney, Darren Indyke, register the businesses and register himself as an agent. JI also observed Epstein has his El Zorro Ranch Corporation, New York Strategy Group, Ghislaine Corporation, J Epstein and Company and the Financial Strategy Group reg: to this same address, Finally, a third call is received by at 12:02 pm from the same corporate number which lasts 12 minu 1 second. It should be noted that there is no further contact with either the victim during the month of March or April of 2006. I also noted that there was no further contact with Sarah Kellen or Jeffrey Epstein during the remainder of the month of March or April 2006. On dune 1, 2006, ASA Lana Belohlavek telephoned me to inform me of the meeting that occurred with Atty. Jack Goldberger and her reference this case. She advised she would make her determination on whether to file on this case or not by Monday June 5, 2006. Inv Continues. AAR HERAERR REA ERA EA ER EREARE NARRATIVE # £6 *8ttteeeeeeeeeeeee enna eeee NA Reported By: RECAREY, JOSEPH 7/12/06 Entered By.: ALTOMARO, NICKIE A. 7/12/06 On dune 29, 2006, I had spoken to ASA Lana Belohlavic who informed me that the case would be sent to the Grand Jury for charges. She informed me that the grand jury would convene on July 19, 2006 to hear the Epstein case. Belohlavic stated State Attorney Barry Krisher made the determination to go the Grand Jury to hear the case. On duly 12, 2006, I spoke with Mrs.[§§hother of the victim, [who inquired about the status of the case. I explained to her that I was told we would be going to the Grand Jury during the week of duly 19, 2006. She stated she had not been contacted as of yet by the State Attorney's Office for any information. I provided her with the telephone numbers to the State Attorney's Office. Investigation continues... +e ee RR OR HK OR HK Oe * * BND OF REPORT + tt eR EHR HR RRA RR E EE GIUFFRE005700 CONFIDENTIAL

EXHIBIT 40 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page685 of 883 mazon.com “amazon: COM, 1850 Mercer Ra Lexington, KY $0511 Jeffrey Epstein 358 I Brillo Way Palin Beach, Florida 23480 USA Sk 1 , a Nii Address; address and payment settings, alfer yol Jeffrey Epstein preferences, and much more ~ 24 houis; 58 EL Bale : - 358 El Brille Way 74 : Pali Bea eo "Palm Beach, Plonds sat gh + ar Visit http://www.amezon. com/reburs to retunt including gifts ~ in unopened or ori z ve so} days for'a full refund (other restrictions appl Ql. Hem a a Pri 2 Total. jour order 1D ready. ; "IN THIS SHIPMENT ae ee . SM 101: agente Introduction me Wiseman, lay ~2d se as a Your order of 4/tord57708/ ~: S SORT naar ack non AGODI5/OHI2 30/0911-19:45/inreed Box or Pad: BCLIB 12X9X2 2 NUNTR ELTHG GLAD UT GIUFFRE006581 CONFIDENTIAL

EXHIBIT 41 (Filed Under Seal)

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EXHIBIT 42 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page795 of 883 GIUFFRE007162 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page796 of 883 4 i es ees eee re scan scan0001 scan0003 scan0004 scan0005 scan0006 scan0007 scan0008 scan0009 scan0010 scan0011 scan0012 scan0013 scan0014 scan0015 scan0016 scan0017 scan0018 scan0019 GIUFFRE007163 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page797 of 883 GIUFFRE007164 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page798 of 883 GIUFFRE007165 CONFIDENTIAL

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Case 18-2868, Document 283, 08/09/2019, 2628241, Page800 of 883 GIUFFRE007167 CONFIDENTIAL

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Case 18-2868, Document 283, 08/09/2019, 2628241, Page802 of 883 GIUFFRE007169 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page803 of 883 GIUFFRE007170 CONFIDENTIAL

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Case 18-2868, Document 283, 08/09/2019, 2628241, Page806 of 883 GIUFFRE007173 CONFIDENTIAL

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Case 18-2868, Document 283, 08/09/2019, 2628241, Page810 of 883 GIUFFRE007177 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page811 of 883 GIUFFRE007178 CONFIDENTIAL

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Case 18-2868, Document 283, 08/09/2019, 2628241, Page813 of 883 GIUFFRE007180 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page814 of 883 GIUFFRE007181 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page815 of 883 GIUFFRE007182 CONFIDENTIAL

EXHIBIT 43 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page817 of 883 rox = south AFA Bios 9, Hoatonl so100 Tns. (063) 2010358 ued goro4a a ROOM SERVICE SUTAL Frans Che a mY Ak: ReLWOUNSAUNIN GO 14 2987 WAITER NO. | ob2 food $20 oo TAL S232 a VAT dc i neacT’ SERVICES 30.00 4 COFE/TEA-MILK 20.00 T FOOD TOTAL 20.00 VAT 7% 24.64 TRL 346 oA SERVICE 32:00 TOTAL WE «BPG lL E64 923 323/ROBERTS HOTEL GUEST 76.64 ACC RECIEVABLE 02U009-02-00278 TIN 3.10 1 61770 2 RDe 5014 22 000232 -——5 CHECK CLOSED 06:12AN—~Ss s < b wo wR PAID—CHARGES W ROOM NO. hy 9 (Vier \} ola SS — AbDRESS:— | ame GIUFFRE007413 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page818 of 883 112 0, Hanan w.FranaTw 0. silos v. HFodtyni 50100 Ins, (063) 261033-6 und 261044 5 ROOM SERVICE ROYAL PRINCESS (Chaawe Mas a v4 TAUGUNIZAUNYN So 14 9827 foo) "0-00 ver tn Siviee wpe = FRENCH FRIES uu FOOD TOTAL 149.01 “aT 72 8.47 EIR MeOey SERVICE a1-00 TOTAL WE | ASe ae 923 923/ROBERTS HOTEL. GUEST 2.47 ACC RECTEVABLE 024010-02-00310 TIN 340 4 51770 2 RDS SIGNATURE GIUFFRE007414 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page819 of 883 4, aFeean 0. tiles «. ‘Foal so1oo Ins. (068) 281039-6 uriny 281044 ® ROOM SERVICE + » % NeVOUMIAUNYN BO 14 2807 CHECK NO. NO 32117 Fa 4 @_ 1/29 ap ate ala Teh ives OK 47 aT a Sy. pf. If a0 39067 '02 ose240N 1.4/9.0 4 F RICE PORK CHIC 130.00 1 wal. y 20-4] FOOD TOTAL 120.00 sf VAT 7 0.04 (ef 93 0/ SERVICE 13.0 e TO ME §=«-4ASS.04 923 527/ROBERTS 3 HOTEL GUEST 153.04 ACC RECIEVABLE 921013-02-00495 TIN 3101 61770 2 ROE S044 22 000292 ~——S CHECK CLOSED fi6! 13AaN—-PAID—CHARGES “NATURE GIUFFRE007415 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page820 of 883 112 0, Fran a>.” av 0. tiles ¥, ‘Sealnl so100 Tns. (063) 281033-6 urine 281044 ® ROOM SERVICE a ea nzmuNiaNUNYN bo 14 2897 Tel 1/69 OK ast 4 dey ni. DF 00 140CT'02 O6¢ we fad 1 FRIED SPRING RA. 420.00 T yal Y 7/4. 5 1 F RICE PORK CHIC § 190.00 T ‘ FOOD TOTAL 250.00 ; VAT 7% 49.25 fey ANY 25 SERVICE 25.00 TOTAL WE 4.25 ' 925 r 529/RDBERTS . HOTEL GUEST 24.5 ACC RECTEVAELE 02%4044-)2-n0de4 TIN 340 4 61770 2 ROW 5014 22 0nn292 ———5 CHECK CLOSED 96: 0sAK—- SIGNATURE GIUFFRE007416 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page821 of 883 119 & Fyanany astimnony 0. sos, esl 50100 Ins. (053) 261085-6 une ganas ROYAL PRINCESS ming neiiuunvmunvn so 314 2687 CHECK NO, 0 23621 1 WATER BEVR. TOTAL 35.00 VAT TH 1.93 SERVICE 2.5, TOTAL UE 29.43 923 ‘923/ROBERTS HOTEL GUEST 23.49 ACC RECIEVABLE 924016-~12-00620 TIN 310 1 61770 2 RDF S014 22 gIzI2 ~-—-13 CHEEK “LOSED 92:-PH-—~~PAID—CHARGES NAME :— ROOM NO. VidGronss hes ry 26 M0, je ———— ee ADDRESS :— a a SIGNATURE \ GIUFFRE007417 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page822 of 883 112-0, Shanon athens o, tos v. rEoslyni 60100 Tns. (063) 261093-8 urine 281044 S ROOM SERVICE 4 sis neiuduNANWN 5o 14 9897 ee 2 FRIED SPRING 2 ; FOOD, ~STL 240.00 Fe ACS 48 WAT 7 48.43 SERVICE 24.00 TOTAL TUE | «PS ae 323 923/ROBERTS. HOTEL GUEST 4ft RECTEVABLE TIN 3 10 4 5: RIG 5014 22 0002 GIUFFRE007418 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page823 of 883 112.0, Hanmy Fann 0. titer v, Hostel so100 Tns, (063) 281093-6 uring 281044 ® ROOM SERVICE 4 oa MEITUNITMUNY 50 14 8887 2 FANILY SREAKFAS FOOD “OTAL VAT 7 SERVICE TOTAL DUE 923 923/' ROBERTS HOTEL GUEST HOC RECIEVABLE 6. FIN 340 1 34771 RoW 5914 22 000: ———S CHECK CLOSED 98:n0Ai}— GIUFFRE007419 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page824 of 883 112 0, * aFrano 0. tos &. ‘uslyni 50100 Tns. (063) 281033-6 ured 281044 0 ROOM SERVICE ROYAL PRINCESS Cuan Mar netiounsrinwt 50 14 2897 CHECK NO. No 32161 TOTAL DUE 323 923/ ROBE? TS, HOTEL SuEST ACE RECIEVABLE TIN 3 40 4 6177 rit Shi4 22 001 -———5 CHECK OLOSER 0 SAN—- ROOM NO. c.C. NO, GIUFFRE007420 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page825 of 883 nea u atone 0. sips 9, «eal 50100 Ins, (068) 263099-6 und 281044 ® ROOM SERVICE 4 v4 Newounrsunyn bo 14 2ea7 CHECK NO, Ne 4 COFE-TEASMILK FOOD “374. YAT TH SERVICE TOTRL DUE S416 94.25 1792-00679 ACC RECTEVABLE TIN et eDw “<§ a6an-———— ROOM Nj GIUFFRE007421 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page826 of 883 11, a. Hannu athanows 0. tiles ». roslyn! 50100 Tns. (063) 281033-0 urine 281044 ® ROOM SERVICE ROYAL PRINCESS ‘Gnawa Mas a » a TSUIUMIIAUNWN SC 14 2827 ‘CHECK NO, Ne 32160 WAITER NO. 2 OR GR YD NICE 180 Ol) ©00D ThTaL «OC oT ot SERVICE TOTAL DUE ————35 CHER OU | GIUFFRE007422 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page827 of 883 112 0, Hramoru wsranann 0. ties 4. Foslyni 60100 Ins. (063) 281033-6 rind va1044 @ ROOM SERVICE ROYAL PRINCESS Catanc Mar 4 oa NewWweunisminwn 60 14 2897 PERSONS TABLE NO. CHECK NO. q 41s NO 32171 AMOUNTS * ROOM-5. = PAID-CHARGE! names 7 fod (nv ROOM NO. ©.C. NO. ADDRESS :— } SIGNATURE pa — ’ GIUFFRE007423 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page828 of 883 son atrenanu B. tilos 9, tosleni so100 Tus. (068) 2810336 uring 261044 ® ROOM SERVICE a v4 NeivoUnIsAUNYN 50 14 2897 HOTEL PAID-CHARGES ADDRESS ;— SIGNATURE GIUFFRE007424 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page829 of 883 12, Fhanniy tranaiu &. alos», osbni 50100 Tm. (053) 261093-2 anny ee104s ROYAL PRINCESS CAFE Came Mat netiiounramavn 6o 14 aAB7 WAITER NO. PERSONS TABLE NO. |_ CHECK NO, “, i G NO 263581 DETAILS AMOUNTS TOTAL DUE | ERS. ath 70S MOTE GUEST 235.40 ACC RECIEVABLE = 923813-~02-00755 TIN 349 1 Bh776 2 4 SMle 22 990292 -—1 CHEDK CLOSER 18:S)aK-—-PAID-CHARGES: NAME :— i ROOM NO. 7 DA i. K4avGE Ms gS c.c, NO. ADDRESS :— SIGNATURE 3 j ew, angran a? GIUFFRE007425 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page830 of 883 112. 8 Hignmu vFrnann ov. les g, Foil! sooo Tns, (053) 281093-6 od gs1044 ‘Came Mar “ ad ReiveUuNIAUAUN O14 g897 PERSONS TABLE NO. a eb LS AMOUNTS CHECK NO. IN? 23629 2 SINGHA BEER -5 46.0) T 4 SOFT DRINKS 50.00 T BEYR. TOTAL 160.00 VAT 7% 2.22 SERVICE 46.00 TORL WE §=6091S8.32 Ne 307 /BROWNL_TE-MOE HOTEL SUEST 198.32 ACC RECTEVABLE 92017-112-09695 TIN 340 4 S177 Z RIE S014 23 990232 v~oo~12 CHECK SLOSED 12: 14PH-—- PAID-CHARGES NAME :— ROOM NO. FO 7 ty iC) RE c.c. NO. ADDRESS :— ‘SIGNATURE M mM chy hue GIUFFRE007426 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page831 of 883 San ALALMDRY. wit ok no. O34 wis, 01699 Regular Service Shirts to be ene D vameiaw (ofits 50%) an bP Express (50% Surcharge) (oer! chy \ey > $5, . a Laundry Mark i; PINK = CASHIER, YELLOW = ACCOUNT, WHITE = GUEST GIUFFRE007427 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page832 of 883 aimtsiuswaade ius oily 11 wdvenany wham aor esfuslud MINI BAR LIST HOYAL PRINCESS No. 416 0 f BEVERAGES AVAILABLE IN YOUR REFRIGERATOR ceva wiSniede Wuswa Safa Gon) @ wminswhgtomé 3 10 ssin10 2 NAME mreiimnansme ROOM NO. LEE: are | PAR | CONTENTS NET PRICE] CONSUMP. | TOTAL TION STOCK 2 | Singha Beer Sma 100 2 Heineken Beer 110 [ 2 | Soda Water so 1 Coca-Cola 50 1 60 2 | Mineral Water ol 2 fa | 1 | Brandy VS.0P 20c 550 1_[ Scotch Whisky 20 400 [ 1_| Thai whisky 730 I 1_| Gin20d. _| 40 | 1_[ Vodka 20 <1 400 4_| Chocolate Bar 60 ZO 1_| Potatoes Snack 40 ih 2 ha Water Complimenti Prices are inclusive of service charge and VAT an (70m 240 Lee Wie reil your rerigerator daily and bill the consumption decly to your Hotel account ‘And drinks will be charged fully when the bottle is open, PLEASE DO NOT PAY CASH Guest's signature ‘ Refilled by. Front Office Cashier GIUFFRE007428 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page833 of 883 @ anise 20 sarr02 ROYAL PRINCESS, 41678 Cane. BEVERAGES AVAILABLE IN YOUR REFRIGERATOR EW 00m no... A123 opre-19-A6 (UNIT PRICE, ‘cONSUMP- | TOTAL TION Mineral Water Brandy V.S.0.P. 20 cl, 550 Scotch Whisky 20 dl Thai Whisky 4_| Chocolate Bar bo is 1 Potatoes Snack 40 i 2_| Singhs Water Compliment Prices are inclusive of service charge and VAT a 490 ‘We refill your refrigerator da cern ecereten my fay Heil cement, ‘And drinks will be charged fully when | PLEASE DO NOT PAY CASH Guests signature enn Refilled by... GIUFFRE007429 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page834 of 883 esa fare le (orem @ sanuedagtom€ 3 10 101790 © ze, ee Aor eifeleal ROYAL PRINCESS (MINI BAR LIST Gaara ites w.41854 BEVERAGES AVAILABLE IN YOUR REFRIGERATOR PAR CONTENTS UNIT PRICE] CONSUMP-] TOTAL | TON stock BAHT Singha Beer (Smail) 100 2_| Mineral Water —s| rahi 1 | Brandy VSOP. 20d. 550_| 1_[ Scotch Whisky 20 ¢. 400) 1_| Thai Whisky i 1_| Voska 206. 400 4 | chocolate Bar Prices are Inclusive of service charge and VAT eae: ge 180 ‘We refil your refrigerator daily and bil the consumption directly to your Hotel account. ‘And drinks wil be charged fully when tho bottle is open. PLEASE DO NOT PAY CASH GIUFFRE007430 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page835 of 883 @ vanledofefidem 3 co ssir2 J 18 Oi enany eden eifing sider Ps BAR LIST HOYAL PRINCESS NO. 4 1 8 5 8 BEVERAGES AVAILABLE IN YOUR REFRIGERATOR (/LS* 4 ss: ROOM NO. ... 933 | ome OT 6 TOTAL BAHT —S Singha Beer (Small) 100 2 | Heineken Beer 110 2 | Soda Water 50 1 | CecaCola 50 2_ | Mineral Weiter 60 ll t-— 1_| Brendy SOR 20d. 550 1 [ scotch Whisky 20 ¢) 400 +] Thai Whisky 130 1 Gin 20cl, 400. 1_| Vodka 20 4. 400 4 _| Chocolate Bar 60 z 1_| Potatoes Snack 40 2 Water Complimentar ro Prices are inclusive of service charge and VAT qa. ‘We retil your refrigerator daly fe conemption det to our Hotel account, And enki be charged uy when Ve bende even PLEASE DO NOT PAY CASH GIUFFRE007431 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page836 of 883 otonemete dfeor Guna @ laniiehiyferé 6 seine Tete cr se ened ROYAL. CESS MINI BAR LIST a w0.41943 BEVERAGES AVAILABLE IN YOUR REFRIGERATOR KL \ [rar CONTENTS. J UNIT PACE] ConsuMP. | TOTAL STOCK TON BAHT ath 2 | Singha Beer (Small 100 | Heineken Beer 110 1_[ Me 2 | Soda Water 50 1 | Coto » | 4 | 50 2 | Mineral Water 60 | 1 | Brandy VSO 200, 550 1_| Scotch Whisky 20 <i 400 f 1__| Thai Whisky 130 1_| Gin20d. 200 1_| Vooka 20 ¢ 400 4 Chocolate Bar 0 1__| Potatoes Snack 40 Singha Water Prices are inclusive of service id VAT ces are charge ani aN 1b0 ‘We refill your refrigerator daily and bil the consumption dvectly to your Hotel account, ‘And rinks wil be charged fully when the bottle is open, PLEASE DO NOT PAY CASH GIUFFRE007432 CONFIDENTIAL

EXHIBIT 44 (Filed Under Seal)

Page838 of 883 868, Document 283, 08/09/2019, 2628241, Pag Case 18-2 ‘ State v. uj effrey Epstein Public Re. Cord No:16-208 - Audio & Redacte, "Walkthrough Video 'd Control Calis

EXHIBIT 45 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page840 of 883 Ons VEHICLES — Mercedes Benz of Palm Beach Mercedes Benz 600 (561) 309-6415 Rear 2001 Black @ ._ |(681) 379-9990 -Fragt 4000 Okeechobee Boulevard ) ah West Palm Beach, FL 33409 ay wv Licence: EOS3PRU “7 oo Att: Shawn Adison : I: (561) 689-6363 —pilic. u90-9Qr 193 oe oe” Tel: (561) 689-636 Mercedes Benz 600 1997 Black (561) 758-1672 Rear (561) 818-8867 Front Licence: G14KCT Paint tIekK Ceres eR cenpact Dorr (ger Mercedes Benz 600 Conv 1998 Silver (861) 346-7141 Licence: RAS85L Roger Dean Chevrolet 2235 Okeechobee Boulevard West Palm Beach, FL 33409 Tel; (561) 683-8100 Crysler Mini Van 1996 White Nestor Auto Repairs 2600 Florida Avenue West Palm Beach, FL 33401 a Licence: WGE52R ( 6 x Tel: (561) 835-0809 Cobra Grand 1993 Green Nestor Auto Repairs 12600 Florida Avenue West Palm Beach, FL 33401 Tel: (561) 835-0809 Volvo Palm Beach 5544 Okeechobee Boulevard West Palm Beach, FL 33417 (561) 686-3707 Tel: (561) 471-7600 1900 Southern Boulevard West Palm Beach, FL 33405 Oil change every 3 000 miles Tel: (561) 835-9374 Registration, insurance and yearly inspection papers to be kept in the glove compartment of each vehicle Spare keys are kept in the key box in the office 02/11/2015 Page 2296 Public Records Request No.: 16-268 GIUFFRE007834

Case 18-2868, Document 283, 08/09/2019, 2628241, Page841 of 883 Muvico Parisian City Place 545 Hibiscus Street West Palrn Beach, FL 33401 Tel: (561) 833-0400 GROCERY STORES Lae Bishop Water Co Egrbottled water (large and small) 12401 PGA Boulevard, Suite 172 |Fish, meat, gourmet foods Palm Beach Gardens, FL 33410 Carmine Giardini's Tel: (561) 775-0105 115-923 1280 Sunset Avenue Gourmet foods Palm Beach, FL 33480 C'est Si Bon Tel: (561) 659-6503 265 Sunset Avenue |General, cleaning, toiletries Palm Beach, FL 33480 Publix Super Market Tel: (561) 655-4120 Wild Oats 7735 South Dixie Highway Health Foods West Palm Beach, FL 33405 Tel: (561) 585-8800 HEALTH & BEAUTY Pharmacy Greens Pharmacy 151 North County Road Palm Beach, FL 33480 Tel: (561) 832-4443 Palm Beach, FL 33480 Tel: (561) 655-7867 02/11/2015 Page 2297 Public Records Request No.: 16-268 GIUFFRE007835

Case 18-2868, Document 283, 08/09/2019, 2628241, Page842 of 883 UTILITIES City of West Palm Beach Water shut-off for entire property is located 1226 Cypress Lane next to the mailbox on the sidewalk. Palm Springs, FL 33461 Tel: (561) 965-5770 Electricity Florida Power and Light General Mailing Facility Miami, FL 33188-0001 Tel; (561) 697-8000 Florida Gas Company 401 South Dixie Highway West Palm Beach, FL 33401 Tel: (561) 832-0872 City of West Palm Beach 1226 Cypress Lane Palm Springs, FL 33461 Tel: (561) 965-5770 Trash Removal City of West Palm Beach Daily (Monday -Friday) 226 Cypress Lane ed ; Palm Springs, FL 33461 Nec celdos\T hers aot Nout) Tel: (561) 965-5770~ by rker Dv) \) Bo GO2L Trew Comal ETC = 2921 N Australian Avenue West Palm Beach, FL 33407 Tel: (561) 881-8118 Bell South Tel: (561) 780-2611 02/11/2015 Page 2298 Public Records Request No.: 16-268 GIUFFRE007836

Case 18-2868, Document 283, 08/09/2019, 2628241, Page843 of 883 Foster Plumbing 2800 Westgate Avenue West Palm Beack, FL 33409 Tel: (561) 686-1721 |General plumbing repairs Roto Rooter 6600 NW 12th Avenue, Suite 213 Fort Lauderdale, FL 33309 Tel: (561) 832-1495 Blocked drains Hackl Pools 1331 Central Terrace Lake Worth, FL 33460 Tel: (561) 588-7493 wer Monday and Thursday at 10:30am Clean pool, filter, a (Wicnele] |County Wide Tree Service Tel: (561) 371-5786 First Monday in May and November STORAGE Storage USA 5580 Okeechobee Boulevard West Palm Beach, FL 33417 Tel: (561) 683-9955 10 ft x 20 ft unit available VEHICLES Car Detailing Clean Lak SERV Cos 6¥W Isl Pye Boynton peach F/ 83424 02/11/2015 Page 2299 ee 724 Sw 4 Ay Boynton Bead, Fl 3 Public Records Request No.; 16-268 GIUFFRE007837

Case 18-2868, Document 283, 08/09/2019, 2628241, Page844 of 883 MAIL & DELIVERY SERVICES FedEx 1-800-463-3339 Account No: Drop-off box is next to Palm Beach National Bank on Worth Avenue Post Office 1401 South County Road West Palm Beach, FL Tel: (561) 832-0697 MAINTENANCE Cassidy Air Conditioning Monthly service contract 501 Fern Street First Monday of every ol West Palm Beach, FL 33401 Job Ve char - Veby Tel: (561) ae ar Bob / EA Souckte (Air Conditioning ev American Awning Company 537 Pine Terrace West Paim Beach, FL 33405 Tel: (561) 832-7123 Adelphia Cable 1401 North Point Parkway West Palm Beach, FL 33407 Tel: (561) 478-8300 Carpet Cleaners Computers Palm Beach consultants: Chad Bonta Peter Kapopoulos <a. oo 02/11/2015 Page 2300 Public Records Request No.- 16-268 GIUFFRE007838

Case 18-2868, Document 283, 08/09/2019, 2628241, Page845 of 883 TRAVEL Pilots Larry Visoski “ Dave Rodgers Larry Morrison Mr Epstein's planes Jet Aviation (561) 233-7241 Procedure for leaving cars at the airport: Leave car at Jet Aviation landing strip Leave the keys in the car Advise Jet Aviation Tail #909JE or Tail #908JE They will tag and pull car to plane upon arrival Ms Maxwell's plane ‘Commercial Airlines ———— Raytheon Cnz ngs d Fl, © g Ras \o 1-888-835-9782 Contract No: Airé 5, \ Tail # ..TA ) ee Always a Beech Jet or Hawker Air France [American British Airways Continental Delta South African Airways United US Air 1-800-237-2747 1-800-433-7300 1-800-247-9297 1-800-525-0280 1-800-221-1212 1-800-722-9675 1-800-241-6522 1-800-428-4322 — Carles vile Wendy men (61) 02/11/2015 Page 2301 Public Records Request No.- 16-268 GIUFFRE007839

Case 18-2868, Document 283, 08/09/2019, 2628241, Page846 of 883 => Colowi2l Baal ror he ~DBen Lenn BANKING —_Cawnor Household Banking Account |Palm Beach National Bank Account No: 125 Worth Avenue Send to Eric Gany for reconciliation Palm Beach, FL 33480 $1,000 Petty Cash Float Tel: (561) 653-5594 BICYCLES Palm Beach Bicycle Trail Shop 223 Sunrise Avenue Palm Beach, FL 33480 Mongoose Crossway 450 Raleigh Aluminium 300 Mercedes Benz Cignal Sports Bike Tel: (561) 659-4583 Palm Beach, FL 33480 Tel: (561) 655-4120 Main Street News 255 Royal Poinciana Way Palm Beach, FL 33480 Tel: (561) 833-4027 CLEANING SERVICE Francis Peadon House Cleaning Services Every Tuesday and Wednesday UL. [. ]8:00am - 4:00pm (Francis and Pastora Peadon) |One South County Road Renew car park stickers every September Palm Beach, FL 33480 Tel: (561) 655-6611 Comedy Corner 2000 South Dixie Highway |West Palm Beach, FL 33401 Tel: (561) 833-1812 ‘The Mar-a-Lago Club 1100 South Ocean Boulevard Paim Beach, FL 33480 Tel: (561) 832-2600 02/11/2015 Page 2302 Public Records Request No.: 16-268 GIUFFRE007840

Case 18-2868, Document 283, 08/09/2019, 2628241, Page847 of 883 Dem Co, ps4 faiy 5~ 4 race Sam Energy Efficient Electric Tel: (561) 655-7211 Exterminator Palm Beach Exterminating Tel: (561) 689-0808 Arsnpsd ” Contact is Ken First Monday of every month at 10:30am Also use for termite tent Garden Service Alan Stopek Trace Wellington, FL 33414 Jerome Pierre Garage Doors The Doorsmith 4160 NW First Avenue Boca Raton, FL 33431 Tel: (561) 391-7768 . : Tom Gates Reich Metal Fabricators Tel: (561) 585-3173 ‘ John Irrigation Dolphin Sprinkler Inc Tet: (561) 844-8082 2vol Academy Services Landscape Spraying Tel: (561) 478-4629 Part-time help. Billed through Alan Stopek. In residence: Daily from 6.30am Not in residence: Mon - Fri from 2pm - 5m Also maintains Mrs Epstein's property on Saturday mornings. Back door gate switch - above garage door controls. When open, round red light is on. Front door gate switch - in telephone outlet above the kitchen telephone len Berta Arrange through Alan Stopek Locksmith Wilson Rowan Locksmiths 625 South Dixie Highway West Palm Beach, FL 33401 Tel: (561) 655-3637 Painter | Bi Chins 02/410015 Page 2308 Publi 2 GIUFFRE007841

_. Bee. q\ete 9) \ ( ¥ ex Bree _ powkdilel] at Yd 2 ud\@eels \ Suk. f- Geose Heo) = Ghasle Sen — — ‘Haller Ome af Aue c (Ieee » Hoclels ) Ps sell mm ?. ® Lede gv Fey ( 2 9 Gest Norye lle er e eats (0, i. \) ioe he wry (Eee ki GIUFFRE007842

Case 18-2868, Document 283, 08/09/2019, 2628241, Page849 of 883 Address / Telephone Sheet Rerekhs & Wel) fad # 358 El Brillo Way, Palm Beach FI, 33480 Name Address Telephone/Fax Mr. Jeffrey Epstein (NYSG LLC ) Offi 457, Madison Avenue 4" Floor New York, NY 10021. Email yea > Fenn (Sehr) helen Fex Ms. Ghislaine Maxwell Email Accountants Eric Ga il A + RRS BANA (sheep Jen cetcho Ben) Bella Klein-Accountant Email (Petty Cash Rep. ‘Assistants Leslie Groff (JE Sec) Email Cecelia Helan Kim Michelle CompesDenn Doyle Property Keith Blumberg. = Engineer e718 are : Richard Barnett 2) 111. 4672 F. 4 , \ inSeruce 02/11/2015 Page 2305 Public Records Request No.: 16-268 | NY 4, DOvUG Avelwkeck yo'> UC SschoeTle Computers oo Mark Lumberg, Residences of Mr. Jeffrey Epstein 9 East 71™ Street, New York NY 10021 Mr. Jeffrey Epstein Ms. Ghislaine Maxwell Staff House Manager Jojo House Manger Lynn Staff Phone Chef Brent Tindal! GIUFFRE007843

Case 18-2868, Document 283, 08/09/2019, 2628241, Page850 of 883 fv } aa Palm Beach Contractors General Plumbing Customer Service representative Amy 561 585 2591 Electrical Reel Power Inc Lenny (electrician) 561 706 0827 Gates Samco Systems Sam (owner) 561 719 4832 Service gate switch: above garage door controls, when round light is on Front gate switch: just above the telephone outlet kitchen area Garage doors The Door Smith Inc Keith Kelly ‘Telephones Southern Bell (repairs) 561 780 2355 Internal Phone system (NEC) Repair and Programming 561 881 8118 Alarm System Benham Industries Inc Keith 854 491 4112 Locksmith Wilson & Rowan 561 655 3637 eee A/C Maintenance Handyman Carlos Kegpenter) avy fothse Landscape Alan Stopeck » Pest Control Palm Beach Exterminator Kim 561 844 8082 Irrigation Dolphin Sprinkle 561 478 4696 Pool Heating National Pool Service When needed 561 585 8866 Pool Maintenance Hack Pool Service Monday/ Thursday 561 588 7493 Tree Trimming Country Wide Trees Twice, summer/winter 561 371 5786 Carpet Cleaners Stanley Steamers wall to wall 561 586 5700 Merry Rug area rug 561 588 8588 Mare- 9sq. 02/11/2015 Page 2306 Public Records Request No.: 16-268 GIUFFRE007844

Case 18-2868, Document 283, 08/09/2019, 2628241, Page851 of 883 j-6e2 a1ss7 ne ed a } post OFFce ee Soee oF) eS, Cable L ‘Adelphia cable Cable TV 561 46esa00 Ut I: é 41 Bottled Water. GEE OFF [09 © Bishop water company Avion water 561582 1367 Upholsterer Frank Jennes =a Gas Gas Energy Inc (Joe Di Giovanni) all gas repairs) 561 963 0505 Laundry equipment May Tag, 1800 622 4729 Painter Stora Storage USA 561 683 5835 5580, Okeechobee Blvd Unit 6218 Grocery & General Household items General Grocery Publix 265, Sunset Ave 561 655 4120 Gourmet food C’ est si bon 289, Sunset Blvd 561 659 6503 Carmines 2401 PGA Blvd Take 95 North to PGA Blvd 561 775 9233 Too Jays Gravelox/ Nova sliced salmon 561 655 6545 Green Pharmacy 151., N County Road 561 832 4443 Flowers fs Extra tough Flowers 561 835 8000 Hardware Home Depot 561 832 0783 Sewell Hardware 561 832 7171 528, Clematis Street Newspapers Main Street News 255, Royal Poinciana Way 561 833 4027 Post Office 401, South County Road, 561 832 0697 Car Detailing George Taxi Service/Limo Dan Tischen FedEx # 114420816 (Monday & Thursday) Recycling Every Thursday 6AM to SPM Trash collection MF once a day Early Morning Cars Mercedes of Palm Beach 561 689 6393 Chevrolet 561 683 8100 Auto Repairs Gray Sunoco 340 South County 561 655 6645 Nestor Auto 2600, Florida Avenue 561 835 0809 GasolineGray Sunoco <6) NQ- 4 SEE Ne MULICH) <HoTes sor Na-458 02/11/2015 Page 2307 Public Records Request No.- 16-268 GIUFFRE007845

Case 18-2868, Document 283, 08/09/2019, 2628241, Page852 of 883 Motnn A PUIEL from Syf Don S2arZ2eas oq, a de? fe d Coeds | vy | Cole, pid w/ stern Knows tom well IND YaSs€ d) nA wC ool 02/11/2015 Page 2308 Public Records Request No.: 16-268 GIUFFRE007846

Case 18-2868, Document 283, 08/09/2019, 2628241, Page853 of 883 ~werts total to you © something paste - a — ela 2:1 em —elr 55ST em Si\heae aa has © Q Fx your can ypu please coll Wee. — Gita tozoem = Tean Lue — Signed Heiman Mens ales 43s0+ omer = Ha ..\' be here @ U'300m orfob — Uliglor t:e0%m Tean We ~ Foor seo sou 2+ = Ghiglos™ &4o — ary olor a — TontAworid.com Tranns 02/11/2015 Page 2309 Public Records Request No.: 16-268 GIUFFRE007847

EXHIBIT 46 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page855 of 883 SSA-1826 ITEMIZED STATEMENT OF EARNINGS SOCIAL SECURITY ADMINISTRATION EARNINGS RECORD INFORMATION Date: 10/25/2016 Our records show the amount of earnings reported, not the amount of Social Security taxes that were paid. Wages were first covered under Social Security in 1937. Therefore, 1937 is the first year for which earnings may be shown on our records. Employers were required to report earnings semi-annually in 1937, and on a quarterly basis for the years from 1938 through 1977. Beginning with 1978, employers are required to report earnings annually. Our records do not show the exact date of employment (month and day) because we do not need this information to figure Social Security benefits. Employers do not give us this information. Each year, there is a maximum amount of earnings that is subject ta Social Security taxes and is used to compute benefits. If a person earns more than this maximum amount, the earnings statement will usually show the maximum rather than the total earnings. Maximum benefits can be found on the SSA website. http://www.ssa.gov/OACT/COLA/cbb. html Beginning in 1951, self-employed persons could also receive Social Security credit for their work. The maximum amounts of self-employment earnings that are subject to Social Security taxes and are used to compute benefits can also be found on the SSA website. http: //www.ssa.gov/OACT/COLA/cbb. html If you have any questions, you should call, write, or visit any Social Security office. If you visit or call, please bring this letter, It will help us answer questions. The toll free number to call is 1-800-772-1213 (for the deaf or hard of hearing, call our TTY number, 1-800-325-0778) . GIUFFRE009176 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page856 of 883 SSA-1826 FROM: SOCIAL SECURITY ADMINISTRATION OFFICE OF CENTRAL OPERATIONS 6100 WABASH AVENUE BALTIMORE MARYLAND 21215 NUMBER HOLDER NAME: VIRGINIA GIUFFRE YEARS REQUESTED: 1998 THRU 2002; 2013 THRU 2015 BOIES SCHILLER AND FLEXNER 401 E LAS OLAS BLVD STE 1200 FORT LAUDERDALE FL 33301 EMPLOYER NUMBER: [i KFC USA INC % PAYROLL DEPT 5200 COMMERCE CROSSING DR LOUISVILLE KY 40229-2182 YEAR 1ST QTR 2ND QTR 3RD QTR 1999 EMPLOYER NUMBER: i] PUBLIX SUPER MARKE’ PO BOX 32018 LAKELAND FL 33802-2018 YEAR 1ST QTR 2ND OTR 3RD QTR 1999 EMPLOYER NUMBER: se ASCENSION CHILD CA ASCENSION PEACE CHILD CARE CENTER 2701 N STATE ROAD 7 LAUD LAKES FL 33313-2731 YEAR 1sT QTR 1999 2ND QTR 3RD OTR PAGE ITEMIZED STATEMENT OF EARNINGS PS FOR SSN XXX-XX. *% XasVLONSMMOUOOALELDIOEOY 4TH QTR TOTAL $140.70 4TH QTR TOTAL $216.69 4TH QTR TOTAL $216.97 GIUFFRE009177 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page857 of 883 SSA-1826 ITEMIZED STATEMENT OF EARNINGS es 5r SS) s+ EMPLOYER NUMBER: aaa AVICULTURAL BREEDING & RESEARCH CENTER % ERNEST LAKS 14201 125TH AVE N WEST PALM BCH FL 33418-7945 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR 2000 EMPLOYER NUMBER: SOUTHEAST EMPLOYEE MANAGEMENT COMPANY 2559 PALM DEER DR LOXAHATCHEE FL 33470-2563 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR 2000 EMPLOYER NUMBER: MAR=A-LAGO CLUB LLC TRUMP DONALD J GEN PTR % TRUMP ORGANIZATION 1100 S OCEAN BLVD PALM BEACH FL 33480-5004 YEAR 1sT QTR 2ND QTR 3RD QTR 4TH OTR 2000 EMPLOYER NUMBER: z= OASIS OUTSOURCING 2054 VISTA PKWY STE 300 WEST PALM BCH FL 33411-6742 YEAR 1ST QTR 2ND QTR 3RD OTR 4TH QTR 2000 EMPLOYER NUMBER: =a NEIMAN-MARCUS GROU. % NEIMAN MARCUS GROUP LTD SOLE MBR 1201 ELM ST DALLAS TX 75270-2102 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR 2000 PAGE 2 TOTAL $99.48 TOTAL $3,212.44 TOTAL $1,866.50 TOTAL $2,037.60 TOTAL $1,440.79 GIUFFRE009178 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page858 of 883 SSA-1826 ITEMIZED STATEMENT OF EARNINGS res FOr $s) EMPLOYER NUMBER: ( MANNINOS INC MANNINOS RESTAURANT 12793 B W FOREST HILL BLVD WEST PALM BEACH FL 33414-4749 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 2001 $212.00 EMPLOYER NUMBER: CCI OF ROYAL PALM INC % ROBERT FURR TTEE 2255 GLADES RD STE 337-W BOCA RATON FL 33431-7379 YEAR 1isT QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 2002 9403.64 EMPLOYER NUMBER: ROADHOUSE GRILL INC ROBERT C FURR TTEE IN BANKRUPTCY 2255 GLADES RD STE 337W BOCA RATON FL 33431-7379 YEAR 1sT QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 2002 $1,247.90 EMPLOYER NUMBER: MARC PINKWASSER DVM PA 13860 WELLINGTON TRCE STE 31 WELLINGTON FL 33414-8541 YEAR 1sT OTR 2ND OTR 3RD QTR 4TH OTR TOTAL 2002 $1,561.75 EMPLOYER NUMBER: Sa GREAT OUTDOORS PRE V=GOLE RESORT COMMUNITY SVC ASSOC INC 145 PLANTATION DR TITUSVILLE FL 32780-2528 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 2014 $171.83 PAGE 3 GIUFFRE009179 CONFIDENTIAL lurtaernceeTees feasneenn ran

EXHIBIT 47 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page860 of 883 Monday, November 7, 2016 Page: 1 1Quicken Data - All Accounts QuickReport by Description 8/12/69 through 1/29/03 Date Account Num Payee Memo Category Cir 4/22/02 Courtyard Animal Hospital 1500 Virginia Roberts split R 5/6/02 Courtyard Animal Hospital 1522 VOIDvirginia Roberts R 5/6/02 Courtyard Animal Hospital 1523 Virginia Roberts split R 5/20/02 Courtyard Animal Hospital 1541 Virginia Roberts split R 6/4/02 Courtyard Animal Hospital 1555 Virginia Roberts split R Total 8/12/69 - 1/29/03 Total Inflows Total Outflows Net Total GIUFFRE009203 CONFIDENTIAL

EXHIBIT 48 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page862 of 883 From: <ross@acuityreputation.com> Date: 2 January 2015 at 20:29 Subject: Re: URGENT - this is the statement To: G Max <gmax] @ellmax,com> Ce: Philip Barden <philip.barden @devonshires.co.uk> OK G going with this, thanks Philip, Sent from my BlackBerry® wireless device From:| Date: Fri, 2 Jan 2015 20:14:53 +0000 To: Ross Gow<ross@acuityreputation.com> Ce: Philip Barden<philip.barden@devonshires.co.uk> Subject: FW: URGENT - this is the statement Jane Doe 3 Is Virginia Roberts so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts that Alan Derschwitz is involved in having sexual relations with her, which he denies Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. EXHIBIT 7 RG(UK)_000009

EXHIBIT 49 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page864 of 883 TERMINATIONS LAST NAME FIRST NAME Rinker Ross Box #7 Rivera Pablo Box #3 Rivera Eduardo Box #2 Rivero Alicia Box #7 Robbins Jody Box #4 Roberts Virginia Box #4 Roberts Walter Box #4 Roberts Diane Box #3 Robsham Lydie Box #7 Rodriguez Francisco Box #4 Rodriguez Abel Box #3 Rodriguez Kenia Box #3 Rodriguez Aristalia Box #2 Rogers. Howard Box #2 Romeus Melege Box #2 Rony Jean Box #2 Roqueta Maria Box #2 Rose Cheryl Box #2 Rosenberg Bradley Box #2 Rosier Sandra Box #2 Rotchford Bernadette Box #4 Rubio Pascual Box #2 Rueda Maria Box #4 Ruiz Juan Box #2 Russeau Heidi Box #4 Russell Kathryn Box #4 Russotto Vincent Box #7 Ryan Megan Box #2 Ryan Michael Box #7 Saint Gerard Manes Box #7 Saint Surin Jacquest Box #2 Salloum Adib Box #2 Salman David Box #2 Salvador Marian Box #2 Sanford Kevin Box #5 Santos Elimos Box #2 Sasaki Shoko Box #7 Saunders Sarah Box #2 Savage Angelia Box #5 Savoie Terry Box #2 Scanlan Peter Box #5 Schlechter Melissa Box #5 Schmantowsky Craig Box #2 Schoonover Richard Box #2 Schroeder Glenn Box #5 Schumacher Patricia Box #2 Schwab Emily Box #2 Scotland Jaycen Box #7 Scott Cecelia Box #2 Page 13 of 17

Case 18-2868, Document 283, 08/09/2019, 2628241, Page865 of 883 TERMINATIONS LAST NAME FIRST NAME Vasquez Sosmar Box #5 Vasquez Christian Box #2 Vaughn Matthew Box #2 Velasquez Rodollfo Box #2 Vidalis Chantal Box #2 Voluck Justin Box #2 Vyskrebentsev Aleksey Box #5 Wahl Steven Box #5 Walker Sylvia Box #7 Walkowiak Toni Box #7 Wallace Philip Box #2 Ward Terry Box #5 Webb Jacob Box #7 Weber Ronald Box #2 Weidner James Box #7 Weisman Brian Box #2 Wentworth Gayle Box #2 Weslowski Elaine Box #2 White Scott Box #5 Whitley Deborah Box #7 Whitney Moriah Box #7 Whittle ‘Tamara Box #2 Wilburn Jennifer Box #2 Williams Arhon Box #2 Williams Gretchen Box #2 Williams Jacqueline Box #2 Williams Ellen Box #7 Williams Kristin Box #7 Willoughby William Box #2 Willson Howard Box #5 Willson Joseph: Box #2 Woolf Elena Box #2 Wynn Beverly Box #2 Yancey Kathryn Box #2 Yancey Scott Box #7 Yeskey Dean Martin Box #5 Young ‘Todd Box #2 Zervoulis Matthew Box #2 Zivkovic. Milo Box #2 Zorn Christopher Box #7 Zwick Danielle Box #2 Box #1 1998 terms Box #2 1998 & 1999 terms Box #3 1999 terms Box #4 2000 terms Box #5 2000 terms Box #6 2001 terms Page 16 of 17

EXHIBIT 50 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page867 of 883 EXHIBIT12 GTUFFREO003 19

Case 18-2868, Document 283, 08/09/2019, 2628241, Page868 of 883 Case 9:08-cv-80736-KAM Document 280 Entered_on FLSD Docket 01/02/2015 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA _Case No, 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 ve UNITED STATES f JANE DOE #3 AND JANE DOE #4’s CORRECTED MOTION PURSUANT TO RULE 21 FOR JOINDER IN ACTION COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as “the new victims”), by and through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21 to join this action, on the condition that they not re-litigate any issues already litigated by Jane Doe #1 and Jane Doc #2 (also referred to as “the current victims”}. The new victims have suffered the same violations of their rights under the Crime Victims’ Rights Act (CVRA) as the current victims, Accordingly, they desire to join in this action to vindicate their rights as well. Because the new victims will not re-litigate any issues previously litigated by the current victims (and because they are represented by the same legal counsel as the current victims), the Government will not be prejudiced if the Court grants the motion. The Court may “at any time” add new parties to the action, Fed. R. Civ. P. 21. Accordingly, the Court should grant the motion,! FACTUAL BACKGROUND ' As minor victims of sexual offenses, Jane Doe #3 and Jane Doe #4 desire to proceed by way of pseudonym for the same reasons that Jane Doe #1 and Jane Doe #2 proceeded in this fashion. Counsel for the new victims have made their truc identities known to the Government. i GTUFFRE000320,

Case 18-2868, Document 283, 08/09/2019, 2628241, Page869 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 2 of 14 As the Court is aware, more than six years ago, Jane Doe #1 filed the present action against the Government, alleging a violation of her rights under the CVRA, 18 ULS.C. § 3771. DEL. She alleged that Jeffrey Epstein had sexually abused her and that the United States had entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her rights. At the first court hearing on the case, the Court allowed Jane Doe #2 to also join the action. Both Jane Doe #1 and Jane Doc #2 specifically argued that the government had failed to protect their CVRA rights (inter alia) to confer, to reasonable notice, and to be treated with fairness. In response, the Government argued that the CVRA rights did not apply to Jane Doe #1 and Jane Doe #2 because no federal charges had ever been filed against Jeffrey Epstein. The Court has firmly rejected the United States’ position. In a detailed ruling, the Court concluded that the CVRA extended rights to Jane Doe #1 and Jane Doe #2 even though federal charges were never filed. DE £89. The Court explained that because the NPA barred ‘prosecution of crimes committed against them by Lpstein, they had “standing” to assert violations of the CVRA rights. Id. The Court deferred ruling on whether the two victims would _be entilled to relief, pending development of a fuller cvidentiary record. Jd. Two other victims, who are in many respects similarly situated to the current victims, now wish to join this action. The new victims joining at this stage will not cause any delay and their joinder in this case is the most expeditious manner in which to pursuc their rights. Because the background regarding their abuse is relevant to the Court’s assessment of whether to allow them to join, their circumstances are recounted here briefly. Jane Doe #3’s Circumstances GIUFFREO00321

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Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 5 of 14 GIUFFREQ00324

Case 18-2868, Document 283, 08/09/2019, 2628241, Page873 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 6 of 14 The Government was well aware of Janc Doe #3 when it was negotiating the NPA, as it listed her as a victim in the attachment to the NPA. Moreover, even a rudimentary investigation of Jane Doc #3°s relationship to Epstcin would have revealed the fact that she had been trafficked throughout the United States and internationally for sexual purposes. Nonetheless, the Government secretly negotiated a non-prosecution agreement with Epstein precluding any Federal prosecution in the Southern District of Florida of Epstein and his co-conspirators. As with Jane Doe #1, and Jane Doe #2, the Government concealed the non-prosecution agreement from Jane Doc #3 — ail in violation of her rights under the CVRA — to avoid Jane Doe #3 from raising powerful objections to the NPA that would have shed tremendous public light on Epstein GTUFFREQ00325

Case 18-2868, Document 283, 08/09/2019, 2628241, Page874 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 7 of 14 _and other powerful individuals and that would likely have been prevented it from being concluded in the secretive manner in which it was. _dane Dog #4’s Circumstances Af permitted to join this action, Jane Doe #4 would allege, and could prove at trial, that sh has CVRA claims similar to those advanced by Jane Doc #1 and Jane Doe #2, based on the following: As with the other Jane Does, ae Dice #4. was repeatedly sexually abused by Epstein, In _or around the summer of 2002, Jane Dee #4, an economically poor and vulnerable sixteen-yearold child, was told by another one of Epstein’s underage minor sex abuse victims, that she could make $300 cash by giving an old man a massage on Palm Beach, An acquaintance of Jane Doe #4 (also a minor sexual abuse victim of Epstein) telephoned Epstein and scheduled Jane Doe #4 to go to Epstein’s house to give him a massage. During that call, Epstein himself got on the phone (a means of interstate communication) with Jane Doe #4, asking her personally to come to his mansion in Palm Beach. Jane Doe #4 then went to Epstein’s mansion and was escorted upstairs to Epstein’s large bathroom by one of Epstein’s assistants. Shortly thereafter Jeffrey Epstein emerged and lay face _down on the table and told Jane Doe #4 to start massaging him. Epstein asked Jane Doe #3 her _age and she told him she had recently tured sixteen. Epstein subsequently committed illegal sexual acts against Jane Doe #4 on many occasions. Epstein used a means of interstate communication (i.e. a cell phone) to arrange for these sexual encounters. Epstein also frequently travelled in interstate commerce (i.c., on his personal Jed) for purposes of illegally sexually abusing Jane Doe #4. 7 GTUFFREO00326

Case 18-2868, Document 283, 08/09/2019, 2628241, Page875 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 8 of 14 ‘The acis Epstcin committed against Jane Doe #4, constituted numerous federal sex offenses, some of which do not carry a statute of limitations and thus are not time-barred. See 18 U.S.C, § 3283. And these offenses were the kinds of offenses that the Federal Bureau of Investigation (FBI) and U.S. Attorney’s Office for the Southem District of Florida were pursuing _in 2007. So far as Jane Doe #4 is aware, the U.S. Attorney’s Office made ao serious effort to locate her. Instead, after identifying approximately forty separate underage sexually abused _victims, and apparently ptoparing # 53-page federal indictment and with full awarencss of the existence of many victims like Jane Doe #4 — unidentified and not interviewed — it entered into a non-prosecution agreement barring prosecution of Epstein’s federal crimes against these victims. This is contrary to the Government’s normal approach in prosecuting federal sex offenses. It also violated Jane Doe #4’s rights under the CVRA, including the fact that she had a “reasonable” right to confer with the U.S. Attorney’s Office before they entered into an agreement with a scx offender barring prosecution of him for the crimes he committed against her. 18 U.S.C. § 3773 {aj(5). _MOTION FOR JOINDER Jane Doe #3 and Jane Doe #4 now both move to join this action filed by Jane Doe #1 and Jane Doe #2, pursuant to Rule 21 of the Federal Rules of Civil Procedure. Rule 21 provides that ...a party.” Rule 2] “fojn motion or on its own, the court may at any time, on just terms, add “grants the court broad discretion to permit a change in the parties at any stage of a litigation.” Ford y. Air Line Pilots Ass'n Int'l, 268 F. Supp. 2d 271, 295 (E.D.N.Y. 2003) internal quotation omitted), The new victims should be allowed fo join the current victims in this aclion under Rule 21, GTUFFREQ00327

Case 18-2868, Document 283, 08/09/2019, 2628241, Page876 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 9 of 14 ‘The new victims will establish at trial that the Government violated their CVRA rights in the same way as it violated the rights of the other victims. The new victims* participation in this case is important because it appears that the Government intends to raise a factual defense that somehow it did keep Jane Doe #1 and Jane Doe #2 properly informed of what was happening in the criminal prosecution. Of course, if four victims all testify consistently that they were not _properly informed by the Government (as we believe they will), that provides a stronger case for a CVRA violation, In addition, Jane Doe #3 and Jane Doe #4’s participation is relevant to a defense the Court has allowed the Government to raise. The Court has previously ruled that the victims’ request for rescission of the NPA “implicates a fact-sensitive equitable defense which must be considered in the historical factual context of the entire interface between Epstein, the relevant prosecutorial authorities and the federal offense victims — including an assessment of the allegation of a deliberate conspiracy between Epstein and federal prosecutors to keep the victims ‘in the dark on the pendency of negotiations between Epstein and federal authorities until well aficr the fact and presentation of the non-prosecution agreement to them as a fait accompli.” DE 189 at 12 n.6 (emphasis added). Jane Doe #3’s and Jane Doe #4’s participation in this case will help to show what the “entire interface” was between the Government and the victims and thus _to respond to the Government’s estoppel arguments as well as other defenses that it appears to be preparing to raise. See, e.g., DE 62 (52-page response from the Govemment to the victim’s summary judgment motion, raising numerous factually-based and other arguments against the victim’s position). GIUFFREO00328.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page877 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 10 of 14 Jane Doe #3’s and Jane Doe #4’s participation is also directly relevant to the discovery disputes currently pending in this case. The Government has raised various relevancy objections to the documents that Jane Doc #1 and Jane Doe #2 are attempting to obtain. The current victims have responded by explaining how these documents are rclevant, including explaining how these documents might bear on the way in which Epstein used his powerful political and social connections to secure a favorable plea deal, as well as provide proof of the Government’s motive to deliberately fail to investigate certain aspects of the victims’ claims in an elfort to maintain the secrecy of the facts and resolve the case without the victims’ knowledge. See, e.g., DE 266 at 6-10. Jane Doe #3 and Jane Doe #4’s participation will help prove the relevancy of these requests, as well as the need for those requests. One clear example is Request for Production No. 8, which seeks documents regarding Epstein’s lobbying efforts to persuade the Government to give him a more favorable plea arrangement and/or non-prosccution agreement, including efforts on his behalf by Prince Andrew and former Harvard jaw Professor Alan Dershowitz. Jane Doe #1! and Janc Doe #2 have alleged these materials are needed to prove their allegations that, afier Epstein signed the non-prosecution agreement, his performance was delayed while he used his significant social and political connections to lobby the Justice Department to obtain a more favorable plea deal. See, €.8., DE 225 at 7-8 (discussing DE 48 at 16-18). Jane Doe #3 has directly person knowledge of _Epstein’s connection with some of these powerful people and thus how Epstein might have used them to secure favorable treatment. Adding two new victims to this case will not delay any of the proceedings. They will simply join ia motions that the current victims were going to file in any event. For example, the 10 GIUFFREQ00329

Case 18-2868, Document 283, 08/09/2019, 2628241, Page878 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 11 of 14 new victims will simply join in a single summary judgment motion that the current victims anticipate filing after discovery has been completed. Nor will adding the new victims prejudice the United States. As the court is aware, this Court is still in its initial discovery stage. The Court is currently considering whether to reject the Government’s assertion of privilege over documents regarding the case. See DE 265 (victims’ reassertion of objections to the Government privilege claims). The new victims do not seek any additional discovery beyond that previously sought by the current victims.” Accordingly, the United States will not be prejudiced or burdened by adding them to this case. The CVRA does not contain any statute of limitations for filing an action to enforce rights under the statute. Accordingly, were the Court to deny this motion, the result might be that the new victims would then be forced to file a separate suit raising their claims, which would then possibly proceed on a separate litigation track. Rather than require duplicative litigation, the Court should simply grant their motion to join, Jane Doe #1 and Jane Doe #2 support the joinder motion. Counsel for the victims have discussed this motion with the Government at fength in an effort to avoid any need to file a substantive pleading on the issue, Counsel for the victims asked the Government during the summer for its position on joinder. The Government, however, took the matter under advisement for months. Ultimately, after several inquiries from victims counsel, the Government indicated without explanation that it opposes this motion. Coursel for the victims has requested a meeting with the Government on this issue, which will hopefully occur in ? Jane Doe #3 and Jane Doe #4 have asked the Government to provide them with the record of their statements that they provided to the FBI. These FBI 302’s should be only a few pages long. 11 GTUFFRE000330,

Case 18-2868, Document 283, 08/09/2019, 2628241, Page879 of 883 Case 9:08-cv-80736-KAM Document 280 Entered_on FLSD Docket 01/02/2015 Page 12 of 14 January. In the meantime, however, counsel for the victims believe that it is no longer appropriate to delay filing this motion and accordingly file it at this time. Because the Government is apparently opposing this motion, Jane Doe #3 and Jane Doe #4 have described the circumstances surrounding their claims so that the Court has appropriate information to rule on the motion. GIUFFREO00331

Case 18-2868, Document 283, 08/09/2019, 2628241, Page880 of 883 Case 9:08-cv-80736-KAM Document 280 Enterecd_on FLSD Docket 01/02/2015 Page 13 of 14 CONCLUSION Jane Doe #3 and Jane Doe #4 should be allowed to join this action, pursuant to Rule 21 of the Federal Rules of Civil Procedure. Their joinder should be conditioned on the requirement that they not re-litigate any issues previously litigated by Jane Doe #1 and Jane Doe #2. A proposed order to that effect is attached to this pleading, DATED: January 2, 2015 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEITIRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 E-mail: brad@pathtojustice.com And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah" 332 S. 1400 E. Salt Lake City, UT 84112 ‘Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: casselip@law.utah.cdu Aitorneys for Jane Doe #1 and Jane Doe #2 ME this daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah 13 GTUFFREQ00332

Case 18-2868, Document 283, 08/09/2019, 2628241, Page881 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 14 of 14 CERTIFICATE, OF SERVICE _leertify that the foregoing document was served on January 2, 2015, on the following using the Court’s CM/ECF system: Dexter Lee A. Marie Villafatia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 “Fax: (561) 820-8777 E-mail: Dexter.Lee@usdoj.gov E-mail: ana.marie.c.villafana@usdoj.gov Attorneys for the Government is/ Bradley J. Edwards GTUFFRE000333,

EXHIBIT 51 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page883 of 883 si ETABUSHED'FOR "i [Aare tse Hl : VIShe \o \ At GIUFFRE009209 CONFIDENTIAL