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Case 18-2868, Document 276, 08/09/2019, 2628224, Page70 of 77
seized from Epstein’s home during the execution of the search warrant, which would include any
“child pornography” reportedly created by her. Jd. at 257. Detective Recarey who had entered
Epstein’s home in 2002 to install security cameras to catch a thief did not observe any “child
pornography” within the home, including on Epstein’s desk where Plaintiff alleges he kept such
a nude photograph of herself. /d. at 289-90. And Epstein’s housekeeper, Juan Alessi, swore that
he “never saw any photographs of Virginia Roberts in Mr. Epstein’s house,” EXHIBIT HH at § 17,
contradicting Plaintiff's claims that nude photographs of her were prominently displayed
throughout all of Epstein’s homes.
No sexually explicit photographs of Plaintiff were ever produced in discovery in this case
or subpoenaed by Plaintiff from any governmental agency. Plaintiff has presented no evidence
the government “possesses” any such photographs or indeed ever became "aware of" them.
6. January 2015 statement accurately denied Maxwell acted as “madame” for
Epstein to traffic Plaintiff to the rich and famous.
Finally, in the joinder motion, Plaintiff asserted that Ms. Maxwell had “facilitated” sexual
abuse “by acting as a ‘madame’ for Epstein, thereby assisting in internationally trafficking Jane
Doe #3 (and numerous other young girls) for sexual purposes.” Plaintiff has utterly failed to
substantiate her allegation.
Not a single “other young girl” made a claim that Maxwell, or even Epstein for that
matter, trafficked them to a third-person for commercial sexual acts. Detective Recarey
confirmed that he had no knowledge of Ghislaine Maxwell sexually trafficking anyone. EXHIBIT
GG at 278-79. He also confirmed that not a single one of the alleged victims of Epstein ever
claimed to have any sexual contact with any man other than Epstein, or that they were sent to
another location to have sex with another man or to give a massage to another man. /d. at 300-
02. None of the other alleged victims of Epstein ever claimed to have gone on his plane with him
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Document Details
| Filename | DocumentCloud_Epstein_Docs_p00119.png |
| File Size | 304.6 KB |
| OCR Confidence | 94.6% |
| Has Readable Text | Yes |
| Text Length | 2,120 characters |
| Indexed | 2026-02-04 12:22:39.323772 |