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Case 18-2868, Document 280, 08/09/2019, 2628232, Page20 of 74 A. Ms. Maxwell, Mr. Epstein and their friends, because their friend relay to other friends they knew a massage therapist and they would send to the house. So it was referrals. RK Q. Did you have occasion to clean up after the massages? A. Yes. Q. Okay. And that is after both a massage for Jeffrey Epstein, as well as clean up after a massage that Ghislaine Maxwell may have received? A. Yes. Q. And on occasion, after -- in cleaning up after a massage of Jeffrey Epstein or Ghislaine Maxwell, did you have occasion to find vibrators or sex toys that would be left out? A. yes, I did.” 9. It is an undisputed fact that Defendant was 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. Defendant has not been able to procure a single witness - not one — to testify that Defendant did not procure girls for sex with Epstein or participate in the sex. Even one of her own witnesses, Tony Figueroa, testified that she both procured girls and participated in the sex. Another one of Defendant’s witnesses, Ms. Giuffre’s mother, named Defendant as Ms. Giuffre’s “new mamma.” Indeed, those who knew her well, who spent considerable time with her in Epstein’s shared household, like Juan Alessi, Alfredo Rodriguez and Joanna Sjoberg, have testified that she was Epstein’s procuress. Others who lived with her — Jeffrey Epstein, Nadia Marcinkova, and Sarah Kellen — invoked the Fifth Amendment so as not to answer questions on the same. No one has testified to the contrary. B. Documentary Evidence also Shows that Defendant Trafficked Ms. Giuffre and Procured her for Sex with Convicted Pedophile Jeffrey Epstein while She Was Underage. 1. The Flight Logs Defendant has never offered a legal explanation for what she was doing with, and why she was traveling with, a minor child on 21 flights while she was a child, including 6 international flights, aboard a convicted pedophile’s private jet all over the world. Her motion for ' See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 28:6-15; 30:51-25; 52:9-22. 12