DocumentCloud_Epstein_Docs_p01875.png

Case 18-2868, Document 284, 08/09/2019, 2628244, Page24 of 38 of time, Mr. Roberts became acquainted with the head of the spa area and recommended plaintiff for a job there. Jd. at 72. Mar-a-Lago closes every Mother’s Day and reopens on November 1. Ex.U at Mar-a-Lago0212. Most of employees Mar-a-Lago, including all employees of the spa area such as “spa attendants,” are “seasonal” and work only when the club is open, i.e., between November | and Mother’s Day. Ex.T at 72-73; Ex.U at Mar-a-Lago0212; Ex.V. Plaintiff was hired as a “seasonal” spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she had turned 17. a. Reply: Plaintiffs response is misleading. First, she does not dispute that Mr. Roberts, her father began working at Mar-a-Lago in April 2000, nor that he worked there for some time, became acquainted with the head of the spa area and recommended his daughter for a job. Second, Plaintiff contends that “job postings and job descriptions” “from 2002 and later are irrelevant.” There are no such “job postings” cited. Rather, the job posting cited was from October 2000, the same time that Plaintiff was hired. Compare Ex.V (posting for “Saturday October 14 and Sunday October 15”) with calendar for year 2000, showing Saturday and Sundays in October corresponding to those dates. Finally, Plaintiff points to her own “recollection” as contrary proof. Her “recollection” about when she worked at Mar-a-Lago has shifted dramatically over time. First, she claimed it was 1998. See Jane Doe 102 complaint. Then, it was 1999. See Doc. 1, Complaint in this matter. Now, in this response she has changed her answer to 2000. Her vague recollections about what year have been off base, no credit should be given to her newfound recollection of which month she worked there. In any event, she presents no admissible credible evidence to contradict Mar-a-Lago’s own records. Ex.U 23