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Case 18-2868, Document 284, 08/09/2019, 2628244, Page9 of 38 a. Reply: Again, Plaintiff offers no evidence that these “lurid details” were included in the Joinder Motion, as indeed they were, and thus the fact that they were should be deemed admitted. 13. Undisputed Fact 13: Plaintiff said after serving for four years as a “sex slave,” she “managed to escape to a foreign country and hide out from Epstein and his co-conspirators for years.” Id.at 3 a. Reply: Plaintiff does not dispute that she made this statement in her joinder motion and it is admitted. 14. Undisputed Fact 14: Plaintiff suggested the government was part of Epstein’s “conspiracy” when it “secretly” negotiated a non-prosecution agreement with Eptstein precluding federal prosecution of Epstein and his “co-conspirators.” The government’s secrecy, plaintiff alleged, was motivated by its fear that plaintiff would raise “powerful objections” to the agreement that would have “shed tremendous public light on Epstein and other powerful individuals. Jd. at 6-7. a. Reply: Plaintiff does not contest the quoted contents of the joinder motion, but rather offers argument regarding Plaintiff's purported “belief.” Plaintiff did not submit an affidavit attesting to such “belief” and therefore no admissible evidence was cited or offered. The facts should therefore be deemed admitted. 15. Undisputed Fact 15: Notably, the other “Jane Doe” who joined plaintiff's motion who alleged she was sexually abused “many occasions” by Epstein was unable to corroborate any of plaintiffs allegations. Jd. at 7-8. a. Reply: Plaintiff states the facts are “untrue” but offers no admissible evidence to support that statement. She has no affidavit or other statement from “the other ‘Jane