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Case 1:20-cr-00330-PAE Document 662 Filed 06/15/22 Page 10 of 29 17. (GX-3-B). Carolyn further testified that she had trouble remembering details of the events in question and affirmed that she “[doesn’t] remember the times and dates” of her visits to Epstein’s Palm Beach residence. (Tr. 1525, 1559). The government asserts that Carolyn’s recollection can be credited because even if she cannot recall the year that an event took place, she has been consistent about how old she was when the event took place. (PSR at 53). As set forth above, this claim is flatly contradicted by the record. If Carolyn could not accurately remember how old she was when she first met Epstein, the Court should not credit her recollection of how old she was when she last saw him. Carolyn’s memory of when she stopped seeing Epstein was not only unreliable, but also contradicted by the other evidence in the record. Carolyn herself testified that her last interactions with Epstein were when she returned from Georgia after giving birth to her son on March 14, 2004. (Tr. 1548-49). Carolyn stated that she went back to Epstein “four or five times” because she needed money to buy things for her son, but eventually gave up when it became clear that she was too old for Epstein. (Tr. 1549).4 The message pads that were admitted in evidence corroborate that these interactions occurred from approximately late spring through summer 2004, when Carolyn was 17 years old. (See GX-3-E (undated message from “Carolyn Andriano”; surrounded by messages dated April 29 and May 2 and included in a book of messages from 2004); GX-3-I (July 6 message from “Caroline Ambriano”; included in a book of messages from 2004); GX-1-B (July 30 message from “Carolyn Andriano”; next to a message dated August 12, 2004 and included in a book of messages from 2004). Accordingly, the trial * Carolyn’s memory of her interactions with Epstein around the time of the Georgia interlude was also inconsistent and contradictory. On the one hand, Carolyn testified that she left Florida in 2003 “to escape the traumatic events” that had happened in Palm Beach and traveled to Georgia where she became pregnant with her child. (Tr. 1548-49, 1617, 1668). On the other hand, Carolyn testified that she continued to visit Epstein in Palm Beach while she was pregnant. (Tr. 1549). DOJ-OGR-00010427