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Case 18-2868, Document 280, 08/09/2019, 2628232, Page18 of 74 THE WITNESS: Ms. Maxwell, during her research, was found to be Epstein’s long-time friend. During the interviews, Ms. Maxwell was involved in seeking girls to perform massages and work at Epstein’s home.’ 6. 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. Notably, at Defendant’s deposition, Defendant refused to admit that she flew with Ms. Giuffre, and denied that she appeared on Epstein’s pilot’s flight logs.'* However, David Rodgers, Epstein pilot, testified that the passenger listed on his flight logs bearing the initials - GM — was, in fact, Ghislaine Maxwell, and that he was the pilot on at least 23 flights in which Defendant flew with Plaintiff.'* The dates of those flights show that Ms. Giuffre was an underage child on many of them when she flew with Defendant.’ 7. 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. Both Sarah Kellen and Nadia Marcinkova lived with Jeffrey Epstein for many years. They both invoked the Fifth Amendment when asked about Defendant’s participation in recruiting underage girls for sex with Epstein. Marcinkova testified as follows: Q. Did Ghislaine Maxwell work as a recruiter of young girls for Jeffrey Epstein when you met her? A. Same answer. [Invocation of Fifth Amendment] RK Q. Have you observed Ghislaine Maxwell and Jeffrey Epstein convert what started as a massage with these young girls into something sexual? A. Same answer.'° 2 See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 27:10-17; 28:21-29:20. '8 See McCawley Dec. at Exhibit 11, Maxwell’s April 22, 2016 Dep. Tr. at 78-79, 144. ‘4 See McCawley Decl. at Exhibit 41, Rodgers Dep. Ex. 1, GIUFFRE 007055-007161 (flight records evidencing Defendant (GM) flying with Ms. Giuffre). 5 See McCawley Dec. at Exhibit 15, David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36; see also Exhibit 41, Rodgers Dep. Ex. | at flight #s 1433-1434, 1444-1446, 1464-1470, 1478-1480, 1490-1491, 1506, 1525-1526, 1528, 1570 and 1589. '6 See McCawley Dec. at Exhibit 10, Marcinkova Dep. Tr. at 10:18-21; 12:11-15. 10