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Case 18-2868, Document 281, 08/09/2019, 2628234, Page57 of 66 trafficking scheme from a high level, and insulated herself from most of the underage girls who were being paid for sex. Tony Figueroa, Ms. Giuffre's ex-boyfriend, did testify that Maxwell personally requested that he find and bring girls to Epstein for sex once Ms. Giuffre had escaped, and that when he brought the girls Maxwell interacted with them. See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 200:6-18; 228:23-229:21. Rodriguez testified unequivocally that Maxwell was "the boss" and that she knew everything that was going on. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. 169:1-169:4. DEFENDANT’S PURPORTED FACTS 49. No nude photograph of Ms. Giuffre was displayed in Epstein’s home. Epstein’s housekeeper, Juan Alessi, “never saw any photographs of Virginia Roberts in Mr. Epstein’s house.” Detective Recarey entered Epstein’s home in 2002 to install security cameras to catch a thief and did not observe any “child pornography” within the home, including on Epstein’s desk in his office. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This is false. Nude photographs were displayed throughout Epstein’s home. Furthermore, Alfredo Rodriguez testified to Maxwell having pornography on her computer. Rodriguez Dep. Tr. 150:10-17; 306:1-306:24. He also testified to there being a collage of nude photos in Epstein's closet. Jd. 253:14-254:18. That collage was eventually taken into evidence by Detective Recarey, who testified to that fact in his deposition. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 73:19-73:24. And those photos are still in the possession of the FBI or US Attorney's Office. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 74:2-74:7. Numerous other people have testified about nude photographs being on display in the home including Ronaldo Rizzo, who visited the home on numerous occasions and who was reprimanded by Maxwell herself for looking at the nude photos. See McCawley Dec. at Exhibit 14, Rizzo Dep. Tr. at 25:19-26:20. Additionally, the search warrant video, taken at a time when 57