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Case 18-2868, Document 284, 08/09/2019, 2628244, Page7 of 38 itself recognized that she would be able to participate as a fact witness to achieve the same result she sought as a party. The court denied plaintiffs joinder motion. /d. at 7-10. a. Reply: Plaintiff offers no admissible evidence to refute these facts and they therefore should be deemed admitted. See Reply to Undisputed Fact 7, supra. 11. Undisputed Fact 11: One of the non-parties Ms. Giuffre “named” repeatedly in the joinder motion was Ms. Maxwell. According to the “lurid details” of Ms. Giuffre included in the motion, Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by Epstein: e =6Ms. Maxwell “approached” plaintiff in 1999 when plaintiff was “fifteen years old” to recruit her into the scheme. e Ms. Maxwell was “one of the main women” Epstein used to “procure under- aged girls for sexual activities.” e = Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme. e She “persuaded” plaintiff to go to Epstein’s mansion “in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children.” e At the mansion, when plaintiff began giving Epstein a massage, he and Ms. Maxwell “turned it into a sexual encounter.” e Epstein “with the assistance of’ Ms. Maxwell “converted [plaintiff] into... a “sex slave.’” Jd. Plaintiff was a “sex slave” from “about 1999 through 2002.” e =Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.” e =©Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea agreement, because the immunity protected her from prosecution “for the crimes she committed in Florida.” e =Ms. Maxwell “participat[ed] in the sexual abuse of [plaintiff] and others.” e =Ms. Maxwell “took numerous sexually explicit pictures of underage girls involved in sexual activities, including [plaintiff].” Jd. She shared the photos with Epstein.