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Case 18-2868, Document 281, 08/09/2019, 2628234, Page41 of 66 This entire statement is wholly irrelevant to the case being tried, and is improperly being inserted to tarnish the record. Ms. Giuffre’s dating history as a young teen bears no relation to the allegations made within Ms. Giuffre’s complaint against Defendant. As previously stated, Defendant is attempting to muddy the record with nonsensical teen drama in an effort to detract from her salacious sexual abuse of a minor child. Such statements bear no relation to the issues presented through her motion for summary judgment, and should be given weight reflecting the same. As specifically set forth in Ms. Giuffre’s objections to designated testimony, the alleged information would be excluded by multiple rules of evidence, and contested by Ms. Giuffre. See McCawley Dec. at Exhibit 5, Virginia Dep. Tr., passim. Moreover, it was the Defendant who solicited Anthony Figueroa to recruit high school aged girls for Epstein. See McCawley Dec. at Exhibit 4 Figueroa Tr. at 200 and 228-229. DEFENDANT’S PURPORTED FACTS 43. Ms. Giuffre freely and voluntarily contacted the police to come to her aid in 2001 and 2002 but never reported to them that she was Epstein’s “sex slave.” In August 2001 at age 17, while living in the same apartment, Ms. Giuffre and Figueroa hosted a party with a number of guests. During the party, according to Ms. Giuffre, someone entered Ms. Giuffre’s room and stole $500 from her shirt pocket. Ms. Giuffre contacted the police. She met and spoke with police officers regarding the incident and filed a report. She did not disclose to the officer that she was a “‘sex slave.” A second time, in June 2002, Ms. Giuffre contacted the police to report that her former landlord had left her belongings by the roadside and had lit her mattress on fire. Again, Ms. Giuffre met and spoke with the law enforcement officers but did not complain that she was the victim of any sexual trafficking or abuse or that she was then being held as a “sex slave.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This statement is misleading in several respects and irrelevant. The fact that Ms. Giuffre did contact police on two occasions for two specific purposes and did not take that opportunity to also inform the police of everything else that was going on in her life at the time is immaterial. Defendant implies that anytime someone calls the police for one thing they should tell the police 4l