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Case 18-2868, Document 280, 08/09/2019, 2628232, Page25 of 74 ... [Ms. Giuffre] was approached by Ghislaine Maxwell who said she could help her get a job as a massage therapist . . . seemed respectable . .. was shown how to massage, etc., Geoff [sic] Epstein. Told to undress and perform sexual acts on person. Miss Maxwell promised her $200 a job.”° Therefore, years before Defendant defamed her, Ms. Giuffre confided in her treating psychologist that Maxwell recruited her for sex with Epstein. 6. Message Pads Detective Recarey, the lead investigator of the criminal investigation into Epstein and his associates’ sex crimes, recovered carbon copies of hand-written messages taken by various staff, including Defendant, at Epstein’s Palm Beach residence.”’ These were collected both from trash pulls from the residence and during the execution of the search warrant where the pads were found laying out in the open in the residence.”® The search warrant was executed in 2005 and the message pads collected include messages recorded in 2004 and 2005. Numerous witnesses have described that these copies of collected messages accurately reflect those taken by various staff at the Palm Beach Epstein mansion between 2004 and 2005.7 The messages raise a question of fact as to Maxwell’s involvement in the sexual abuse of minors and are relevant to refute Maxwell’s denial of any involvement with Epstein during relevant time periods, and, accordingly her denial of knowledge of certain events. While there were hundreds of these messages recovered during the investigation, this small sample demonstrates the undeniable reality that there exists a genuine issue of material fact with respect to Defendant’s involvement in and knowledge of the activities described by Giuffre which Maxwell has said we “untrue” and “obvious lies.” °6 See McCawley Dec. at Exhibit 38, Lightfoot Records, GIUFFRE005437. °7 See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 45:13-25; 97:9-98:8. 8 See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 25:12-21; 40:5-15; 41:16-23; 42:14-43:10; 45:13-25; see also search warrant video showing the pads openly displayed on the desk. » See McCawley Dec. at Exhibit 21, 1, 16, 11, Rodriguez Dep. Tr. at 73:19-74:12; Alessi Dep. Tr. at 141:18-21; Sjoberg Dep. Tr. at 64:1-6; Maxwell Dep. Tr. at 147:23-148:3; 148:19-149:14. 17