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Case 18-2868, Document 281, 08/09/2019, 2628234, Page10 of 66 and it is Ms. Giuffre's belief that the Government did fail to so inform the victims, and intentionally did not inform the victims because the expected serious objection from many of the victims might prevent the Government from finalizing a NPA with Epstein. See McCawley Dec. at Exhibit 50, Joinder Motion (GIUFFRE00319-00333). DEFENDANT’S PURPORTED FACTS 15. Notably, the other “Jane Doe” who joined Ms. Giuffre’s motion who alleged she was sexually abused “many occasions” by Epstein was unable to corroborate any of Ms. Giuffre’s allegations. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This is untrue. The other Jane Doe could corroborate many of Ms. Giuffre's allegations based on a similar pattern of abuse that she suffered by Epstein. She did not know Ms. Giuffre though. a. who was deposed in this case, and who was a minor, corroborates the same pattern of abuse. See McCawley Dec. at Exhibit 7, | Dep. Tr. at 54:25-57:5. DEFENDANT’S PURPORTED FACTS 16. Also notably, in her multiple and lengthy consensual interviews with Ms. Churcher three years earlier, Ms. Giuffre told Ms. Churcher of virtually none of the details she described in the joinder motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This is untrue. Furthermore, Defendant does not offer any citation or evidence on this point. Defendant's statement here is knowingly false. Having read the articles and taken Ms. Giuffre's deposition, Defendant knows that Ms. Giuffre did reveal details in 2011 consistent with those in the joinder motion. See McCawley Dec. at Exhibit 31, GIUFFRE003678, FBI Redacted 302, GIUFFRE001235-1246. DEFENDANT’S PURPORTED FACTS 17. Ms. Maxwell’s response to Ms. Giuffre’s “lurid” accusations: the January 2015 statement. As Ms. Giuffre and her lawyers expected, before District Judge Marra in the 10