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Case 18-2868, Document 281, 08/09/2019, 2628234, Page37 of 66 eventually put her on their payroll, but paid her very little. Giuffre Dep. Tr. at p. 52; Aviculture Breeding and Research Center taxable earnings for 2000 is $99.48, See McCawley Dec. at Exhibit 46, GIUFFRE009178. DEFENDANT’S PURPORTED FACTS 40. Ms. Giuffre’s employment at the Mar-a-Lago spa began in fall 2000. Ms. Giuffre’s father, Sky Roberts, was hired as a maintenance worker at the The Mar-a-Lago Club in Palm Beach, Florida, beginning on April 11, 2000. Mr. Roberts worked there year-round for approximately 3 years. After working there for a period of time, Mr. Roberts became acquainted with the head of the spa area and recommended Ms. Giuffre for a job there. Mar-a-Lago closes every Mother’s Day and reopens on November |. Most of employees Mar-a-Lago, including all employees of the spa area such as “spa attendants,” are “seasonal” and work only when the club is open, i.e., between November | and Mother’s Day. Ms. Giuffre was hired as a “seasonal” spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she had turned 17. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre disputes this statement. Defendant cannot simply infer Ms. Giuffre’s employment history and claim it to be undisputed. The Mar-a-Lago Club produced 177 pages of records in response to Defendant’s subpoena. However, not one page indicated Ms. Giuffre’s actual dates of employment, nor whether she was a full-time or seasonal employee. In fact, the only significant record produced was a single, vague chart entry indicating that Ms. Giuffre was terminated in 2000. MAR-A-LAGO 0173, 0176. TERMINATIONS Box #1 1998 terms LAST NAME FIRST NAME Box'#2 eck amaameae Box #3 1999 terms Box #4 2000 terms Box #5 2000 terms Box #6 2001 terms Roberts Virginia Box #4 MAR-A-LAGO 0176 MAR-A-LAGO 0173 37