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Case 18-2868, Document 276, 08/09/2019, 2628224, Page66 of 77 two page Palm Beach Police Department affidavit does not mention Ms. Maxwell’s name once (id. at 177), and she was never considered a suspect and she was never mentioned in the grand jury testimony. /d. at 203. Ms. Maxwell was not seen coming or going from the house during any of the Palm Beach Police Department’s surveillance of Epstein’s home. Jd. at 214-15. None of her property was seized from Epstein’s home. Jd. at 257. In sum, Det. Recarey denied that knowing anything “about Ghislaine Maxwell’s sexual trafficking conduct.” Jd. at 278. He confirmed he has no knowledge that Ms. Maxwell sexually trafficking “anybody.” Jd. at 278-79. Likewise, he has no knowledge of Plaintiffs conduct that is subject of this lawsuit. /d. at 259-60. Plaintiff thus has uncovered no evidence that the “government” came to “know” that Maxwell participated in sexual exploitation of Jane Doe #3, 1.e., Plaintiff. Plaintiff has not and cannot present clear and convincing evidence to demonstrate the falsity of Ms. Maxwell’s denial. 3. The January 2015 statement accurately denied that “with [Ms. Maxwell’s] assistance, [Epstein] converted [Plaintiff] into what is commonly referred to as a ‘sex slave.”” Plaintiff claimed in the joinder motion that Ms. Maxwell helped Epstein transform her into a “sex slave” as that term is “commonly” used, yet the incontrovertible evidence establishes the opposite. A “slave” as defined by Merriam-Webster is a “person held in servitude as the chattel of another.” Oxford Dictionary defines “slave” as a “person who is the legal property of another and is forced to obey them.” Common definitions of “‘sex slave” include a person who is confined and is raped, sexually abused or prostituted. See “Sex Slave,” Free Dictionary, located at http://www.thefreedictionary.com/sex+slave (last visited Jan. 5, 2017) (underlining supplied). Plaintiff, however, was far from confined or the legal property of another. Throughout 2000, 2001 and 2002, Plaintiff enjoyed complete freedom of movement and choice. She had a car and then a pickup truck she shared with Figueroa. EXHIBIT P at 67.. She traveled freely to and from multiple jobs working as a waitress, bird aviaries, veterinarian 59