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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. 51

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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