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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 151 of 239 defense counsel and which the defendant ultimately answered by saying “I cannot tell you what Jeffrey’s story is. I’m not able to.” (Ud. at 251:13-253:12). This colloquy followed: Q. Did Jeffrey Epstein have a scheme to recruit underage girls to use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can you ask me again, please? Q. Did Jeffrey Epstein have a scheme to recruit underage girls to recruit them for sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can you ask it a different way? Q. Did Jeffrey Epstein have a scheme to recruit underage girls for sexual massages? MR. PAGLIUCA: Objection to the form and foundation. Q. If you know. A. I don't know what you are talking about.*® (Ex. 10 at 253:13-254:8). The defendant argues that the question was ambiguous, as shown by her requests for the questioner to rephrase the question. (Def. Mot. 4 at 9-10, 18). A properly instructed jury could readily conclude otherwise in light of the evidence the Government expects to introduce at trial. The defamation case involved allegations that Giuffre was a victim of that scheme: Giuffre had alleged that Epstein and the defendant had sexualized a massage that Giuffre gave Epstein. The preceding questions focused on (1) whether the defendant brought underage masseuses to work for Epstein, and (2) whether Epstein had a sexual preference for underage girls. Moreover, at trial and as discussed further below, the Government expects to elicit testimony from one or more of ‘8 Underlined sentences are charged as false statements in the Indictment. 124 DOJ-OGR-00003085