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Case 18-2868, Document 280, 08/09/2019, 2628232, Page17 of 74 A. Yes. Q. Was she in fear? A. Yes. Q. You could tell? A. Yes. A. She was shaking uncontrollably.’ 4. It is an undisputed fact that Lyn Miller testified that she believed Defendant became Ms. Giuffre’s “new mama”. Lyn Miller is Ms. Giuffre’s mother. She testified that when Ms. Giuffre started living with Defendant, Defendant became Ms. Giuffre’s “new momma.”!° Incredulously, Defendant testified that she barely remembered Ms. Giuffre."! 5. It is an undisputed Fact that Detective Joseph Recarey testified that he sought to investigate Defendant in relation to his investigation of Jeffrey Epstein. Detective Recarey led the Palm Beach Police’s investigation of Epstein. He testified that Defendant procured girls for Epstein, and that he sought to question her in relation to his investigation, but could not contact her due to the interference of Epstein’s lawyer: Q. A cross-reference of Jeffrey Epstein’s residence revealed which affiliated names? A. It revealed Nadia Marcinkova, Ghislane Maxwell, Mark Epstein. Also, the cross- reference, any previous reports from the residence as well. Q. During your investigation, did you learn of any involvement that Nadia Marcinkova had with any of the activities you were investigating? RK Q. The other name that is on here as a cross-reference is Ghislane Maxwell. Did you speak with Ghislane Maxwell? A. I did not. Q. Did you ever attempt to speak with Ghislane Maxwell? A. I wanted to speak with everyone related to this home, including Ms. Maxwell. My contact was through Gus, Attorney Gus Fronstin, at the time, who initially had told me that he would make everyone available for an interview. And subsequent conversations later, no one was available for interview and everybody had an attorney, and I was not going to be able to speak with them. Q. Okay. During your investigation, what did you learn in terms of Ghislane Maxwell’s involvement, if any? ° See McCawley Dec. at Exhibit 14, Rinaldo Rizzo’s June 10, 2016 Dep. Tr. at 52:6-7; 52:25-53:17; 55:23-58:5 '© See McCawley Dec. at Exhibit 12, Lynn Miller’s May 24, 2016 Dep. Tr. at 115. "! See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 77:25-78:15 (April 22, 2016). 9