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Case 18-2868, Document 280, 08/09/2019, 2628232, Page2 of 74 TABLE OF CONTENTS I. PRELIMINARY STATEMENT 000... ccceccesceeeeseseseeecsesceececsesseesscseeesaesesesevaeseeesaeaaeeees IL. UNDISPUTED FACTS woe cecsecseeeseseeseseseeeseseseeecseacsececsessasscseeeasseeesesaeseeesasaaeeees A. It is an Undisputed Fact That Multiple Witnesses Deposed in This Case Have Testified That Defendant Operated as Convicted Pedophile Jeffrey Epstein’s Procurer of Underage Girls... cee ceceseseeeesescseeeeseseeesecsesseeeseseeeeseseeeeanseseeesseaeee 1. It is an undisputed fact that Joanna Sjoberg testified Defendant lured her from her school to have sex with Epstein under the guise of hiring her for a job answering PhOnes..........ccceccececeseeeeseneeseeeeeeceeeeceeeeeseeeeaeeaeeeens It is an undisputed fact that Tony Figueroa testified that Defendant would call him to bring over underage girls and that Defendant and Epstein would have threesomes with Ms. Giuffre....... eee e reece It is an undisputed fact that Rinaldo Rizzo testified that Defendant took the passport of a 15-year-old Swedish girl and threatened her when she refused to have sex with Epstein. .........ccccsesessesceceeecseeeeeeeneeseeees 8 It is an undisputed fact that Lyn Miller testified that she believed Defendant became Ms. Giuffre’s “new mama”.........ceeeeeeeeeeeeeteeeeneeneeeene It is an undisputed Fact that Detective Joseph Recarey testified that he sought to investigate Defendant in relation to his investigation of Jeffrey Epstein... eee ceseeeeeseseeseseseeececsesseececseseeacseseeeeacseeeeasaeeeesseaees 9 It is an undisputed fact that Pilot David Rodgers testified that he flew Defendant and Ms. Giuffre at least 23 times on Epstein’s jet, the “Lolita Express” and that “GM” on the flight logs Stands for Ghislaine Maxwell. oo. eecseceseseeeesescsececsesseecscseeseacsceesesseseeesasseeesesseseeesseseeesasseeee It is an undisputed fact that Sarah Kellen, Nadia Marcinkova, and Jeffrey Epstein invoked the fifth amendment when asked about Defendant trafficking girls for Jeffery Epstein... eee eeeeereeee It is an undisputed fact that Juan Alessi testified that Defendant was one of the people who procured some of the over 100 girls he witnessed visit Epstein, and that he had to clean Defendant’s sex toys. ... It is an undisputed fact that Defendant is unable to garner a single witness throughout discovery who can testify that she did not act as the procurer of underage girls and young women for Jeffrey Epstein. ...........