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Case 18-2868, Document 280, 08/09/2019, 2628232, Page72 of 74 but not here. See Merriam-Webster (11" ed. 2006) (defining “madam” as “the female head of a house of prostitution”). Once again, Defendant conceals the relevant facts on this issue. First, multiple witnesses have testified to Defendant’s recruiting, maintaining, harboring, and trafficking girls for Epstein.** In fact, Defendant herself was unable to deny procuring Ms. Giuffre for Epstein.” While Defendant has attempted to fumble her way through explaining some plausible reason for bringing a sixteen or seventeen year old to Epstein, her explanations are, to put it blandly, unpersuasive. As with other issues, the jury will have to decide who to believe. One of the individuals Ms. Giuffre was trafficked to was Prince Andrew — trafficking that took place in Defendant’s own townhouse in London. There exist flight logs evidencing Ms. Giuffre flying to London alongside Defendant and Epstein on Epstein’s private plane, and a photo of Ms. Giuffre, Defendant, and the Prince, without Defendant ever offering a legal reasonable explanation for that photo being taken, or for traveling with a year old girl overseas. Defendant begins to meander somewhat aimlessly on this point, shifting Plaintiffs burden to substantiate Plaintiff's claim that Defendant was Epstein’s Madame, which is a point at issue, into whether or not Plaintiff has conclusively proven the identities and accurate job titles of the other men to whom Plaintiff was lent for sex by Epstein. No matter how hard Defendant tries to reframe this case, drag other people in, or split hairs, she is unable to contest the facts — facts showing she was more than a Madame but a full-fledged sex trafficker. Ms. Giuffre told the truth when she said that Defendant recruited her as a minor, under the pretense of giving a 8 See McCawley Dec. at Exhibit 16, 1, 18, 2, Sjoberg Dep. Tr. at 13; Alessi Dep. Tr. at 34; GIUFFRE000105 at 57- 58; GIUFFRE000241-242 at p. 212-213; Austrich Dep. Tr. at 34-35, 100-101, 127-128; Alessi Dep. Tr. at 34:19- 35:3; 98:5-98:12; 104:15-104:23. °° See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 214:14-215:3. 64