DocumentCloud_Epstein_Docs_p00885.png

Case 18-2868, Document 280, 08/09/2019, 2628232, Page66 of 74 sixteen years old before August 9, 2000, and turned seventeen on that date. It is unclear from the limited records available whether Defendant approached and recruited Ms. Giuffre before or just after Ms. Giuffre’s 17th birthday. However, what has now been established through numerous witnesses is that Defendant approached and recruited a minor child for the purposes of enticing that minor over to the house of Jeffrey Epstein, a currently-registered sex offender.*' The exact lure of Ms. Giuffre by Defendant - enticement of being paid money to give a billionaire a massage at his mansion - was used by Epstein and his many associates and employees to recruit dozens and dozens of other underage girls. There is no doubt that the crux of Ms. Giuffre’s statement on this point is that Defendant recruited her when she was only a minor child unable to consent to sex, not precisely how far under the age of consent she was. Defendant’s public claim that Ms. Giuffre’s account of this approach, and recruiting element, was “untrue” and “obvious lies” is not “substantially true,” but is itself an obvious lie — as Ms. Giuffre will prove to the jury at trial. B. Defendant’s January 2015 Statement Claiming as “Untrue” and an “Obvious Lie” the Allegation That She Regularly Participated in Epstein’s Sexual Exploitation of Minors and That the Government Knows Such Fact is Not Substantially True But Instead Completely False. Defendant next argues that she “accurately denied that [she] ‘regularly participate[d] in Epstein’s sexual exploitation on minors’ and that ‘the Government knows such fact.’” MSJ at 58. It is not clear whether Defendant is nitpicking this statement by contesting whether she “regularly” participated in Epstein’s sexual exploitation or whether she did participate, but the Government was unaware of the extent of her involvement. Call this the “yes-I’m-a-sex- trafficker-but-only-on-Tuesdays-and-Thursdays” defense — here again, to simply recount the claim is to see its absurdity. 5! See McCawley Dec. at Exhibit 1, 5, Alessi Dep. Tr. at 94:24-95:2; Giuffre Dep. Tr. at 111:12-111:21; 116:19- 117:12. 58