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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 159 of 239 A. Can you repeat the question? MR. PAGLIUCA: Same objection. A. No. Q. Other than yourself and the blond and brunette that you have identified as having been involved in three-way sexual activities, with whom did Mr. Epstein have sexual activities? A. Lwasn't aware that he was having sexual activities with anyone when I was with him other than myself. Q. I want to be sure that I’m clear. Is it your testimony that in the 1990s and 2000s, you were not aware that Mr. Epstein was having sexual activities with anyone other than yourself and the blond and brunette on those few occasions when they were involved with you? A. That is my testimony, that is correct. The defendant primarily argues that her answers were literally true. In the defendant’s telling, the phrase “[w]hen I was with him,” refers not to the duration of the defendant’s relationship with Epstein, but instead to only those moments when she was in the act of having sex with Epstein and either the blond or brunette identified above. (Def. Mot. 4 at 16). P| she further argues, because the question asked the defendant about the 1990s and 2000s, it therefore covered any “‘sexual activities’ spanning more than a millennium.” (/d. at 16-17). DOJ-OGR-00003093