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Extracted Text (OCR)
Case 18-2868, Document 281, 08/09/2019, 2628234, Page51 of 66
From September 29, 2002 through October 19, 2002, Defendant and Epstein sent Ms.
Giuffre on a commercial flight to Thailand for massage training and provided her with all
accommodations. See McCawley Dec. at Exhibit 43, Giuffre00741 1-Giuffre007432.
DEFENDANT’S PURPORTED FACTS
45. Ms. Giuffre and Figueroa shared a vehicle during 2001 and 2002. Ms. Giuffre and
Figueroa shared a ’93 white Pontiac in 2001 and 2002. Ms. Giuffre freely traveled around
the Palm Beach area in that vehicle. In August 2002, Ms. Giuffre acquired a Dodge
Dakota pickup truck from her father. Figueroa used that vehicle in a series of crimes
before and after Ms. Giuffre left for Thailand.
MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS
Ms. Giuffre and Tony Figueroa did not share a vehicle during 2001 and 2002. Instead,
Figueroa borrowed Ms. Giuffre’s car while she was traveling with Defendant and Epstein.
Figueroa testified that he “got to take the car, because she was going somewhere else in the
world and did not need it, so...” Figueroa Dep. Tr. At 89-90.
In fact, Ms. Giuffre was frequently traveling with Defendant and Epstein. See McCawley
Dec. at Exhibit 1, Alessi Dep. Tr. at 9-14 (stating that Virginia started traveling on an airplane
with Ghislaine and Jeffrey “not too long” after she started going over to the house). Figueroa
further testified that Virginia “would normally go about two weeks out of every month” with
Epstein. Figueroa Dep. Tr. at 90. He further stated, “Pretty much every time I took her there, it
was always to his mansion. I picked her up one time -- maybe it was a couple of times --from
the jet stream place. But pretty much every single time it was at the hou- -- at the mansion.” Jd.
Moreover, Ms. Giuffre testified she purchased a car from the $10,000 payment she received from
Epstein after she was forced to have sex with Prince Andres in London at Defendant’s home
when Ms. Giuffre was a minor. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 120:1-20.
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Extracted Information
Document Details
| Filename | DocumentCloud_Epstein_Docs_p00944.png |
| File Size | 312.6 KB |
| OCR Confidence | 94.6% |
| Has Readable Text | Yes |
| Text Length | 2,064 characters |
| Indexed | 2026-02-04 12:27:07.611380 |