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9. was the source of the vast majority of the allegations made about Epstein. While the Police Report and probable cause affidavit rely on [J numerous assertions, all but omitted is any reference to the facts known about her by the PBPD, specifically, that at the time making these assertions 10. ile the Police Report and probable cause affidavit contain numerous assertions of omitted is reference to her long history of contacts with law enforcement. Among those are multiple runaway complaints by her parents and her assignment to a special high school for drug abusers. In addition to the prior criminal history of each of these critical witnesses, all of which was omitted from the Police Report and probable cause affidavit, significant additional material information concerning the credibility of these key witnesses was provided to the PBPD but never included in the Police Report, the probable cause affidavit or the public release. 11. “came forward” (as the probable cause affidavit characterizes it at pages 10-11), claiming she had knowledge of “sexual activity taking place” at Epstein’s residence and misconduct by Epstein. Thus, it becomes clear that bssertions of misconduct by Epstein were likely motivated by a strong desire to avoid the repercussions of her , Which should have been taken into account when assessing her credibility as a witness. 12. Pn Was 18 at the Time She Inaccurately Alleges to Have Engaged in Sexual Conduct with Epstein. Epstein denies he ever had sex with HJ However, even if he did, irrefutable evidence, in the form of a credit card receipt, was presented to the PBPD and the State Attorney’s Office which demonstrates that any such encounters occurred at a time when was already 18 years of age. (Indeed, it is our understanding that it was this information, combined with the character and credibility problems presented by the facts noted herein, that led the State Attorney’s Office to conclude that cr neither credible nor a proper complainant.) This information, though own to the PBPD, was omitted from the Police Report, the probable cause affidavit and the public release. 13. Steals From a An investigation by private investigators working for the defense revealed that in late 2005, 5 Public Records Request No. 19-372 DOJ-OGR-00033212