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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. /d. Indeed, the spa advertises for its new employees in local newspapers
in the fall of every year. EXHIBIT V. Even plaintiffs father — a long time employee of Mar-a-
Lago -- described the seasonal nature of the club during his deposition: “[Plaintiffs
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, Plaintiffs 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 plaintiffs 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 twenty-
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Document Details
| Filename | DocumentCloud_Epstein_Docs_p00114.png |
| File Size | 309.7 KB |
| OCR Confidence | 94.5% |
| Has Readable Text | Yes |
| Text Length | 2,156 characters |
| Indexed | 2026-02-04 12:22:36.030162 |