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Case 18-2868, Document 281, 08/09/2019, 2628234, Page6 of 66 MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. DEFENDANT’S PURPORTED FACTS 9. As the district court noted in ruling on the joinder motion, Ms. Giuffre “name[d] several individuals, and she offers details about the type of sex acts performed and where they took place.” The court ruled that “these lurid details are unnecessary”: “The factual details regarding whom and where the Jane Does engaged in sexual activities are immaterial and impertinent . . ., especially considering that these details involve non- parties who are not related to the respondent Government.” Accordingly, “[t]hese unnecessary details shall be stricken.” Jd. The court then struck all Ms. Giuffre’s factual allegations relating to her alleged sexual activities and her allegations of misconduct by non-parties. The court said the striking of the “lurid details” was a sanction for Ms. Giuffre’s improper inclusion of them in the motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. DEFENDANT’S PURPORTED FACTS 10. The district court found not only that the “lurid details” were unnecessary but also that the entire joinder motion was “entirely unnecessary.” Ms. Giuffre and her lawyers knew the motion with all its “lurid details” was unnecessary because the motion itself recognized that she would be able to participate as a fact witness to achieve the same result she sought as a party. The court denied Ms. Giuffre’s joinder motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. DEFENDANT’S PURPORTED FACTS 11. One of the non-parties Ms. Giuffre “named” repeatedly in the joinder motion was Ms. Maxwell. According to the “lurid details” of Ms. Giuffre included in the motion, Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by Epstein: = Ms. Maxwell “approached” Ms. Giuffre in 1999 when Ms. Giuffre was “fifteen years old” to recruit her into the scheme. = Ms. Maxwell was “one of the main women” Epstein used to “procure under-aged girls for sexual activities.” = Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme.