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Case 18-2868, Document 281, 08/09/2019, 2628234, Page62 of 66 DEFENDANT’S PURPORTED FACTS 54. Ms. Giuffre formed non-profit Victims Refuse Silence to attract publicity and speak out on a public controversy. In 2014, Ms. Giuffre, with the assistance of the same counsel, formed a non-profit organization, Victims Refuse Silence. According to Ms. Giuffre, the purpose of the organization is to promote Ms. Giuffre’s professed cause against sex slavery. The stated goal of her organization is to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. Ms. Giuffre attempts to promote Victims Refuse Silence at every opportunity. For example, Ms. Giuffre participated in an interview in New York with ABC to promote the charity and to get her mission out to the public. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre did not form the non-profit Victims Refuse Silence to "speak out on a public controversy," but instead to simply help survivors of sexual abuse and sexual trafficking. In order to provide assistance to victims, Ms. Giuffre attempted to talk about the non-profit’s mission when she had the opportunity to do so. See www.victimsrefusesilece.org. MS. GIUFFRE’S STATEMENT OF UNDISPUTED FACTS 55. Virginia Roberts was born August 9, 1983. See McCawley Dec. at Exhibit 51, Driver’s License GIUFFRE009209. 56. Virginia Roberts turned 18 on August 9, 2001. 57. In 2000, Virginia's father Sky Roberts worked at the Mar-a-Lago. See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 72, 74. 58. Sky Roberts got Virginia a job at Mar-a-Lago in 2000, either months before or just after Virginia's 17th birthday. See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 72, 74; Giuffre Dep. Tr. at 25:19-25:21; 28:10-28:12. 59. The only year in which Virginia was employed at Mar-a-Lago was 2000. See McCawley Dec. at Exhibit 49, MAR-A-LAGO 0173, 0176. 62