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Case 18-2868, Document 284, 08/09/2019, 2628244, Page36 of 38
Fact 40 includes the statement, “Ms. Giuffre 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.” Yet, Plaintiff sets forth as her
own “Undisputed Fact 58” that “Virginia [got] job at Mar-a-Lago in 2000, either months before
or just after [her] 17" birthday.” Plaintiff has done nothing more than set forth her “dispute”
with Defendant’s Undisputed Fact 40 as her own “undisputed fact.” It makes no sense. See also
Plaintiffs “Undisputed Fact” 63. The other alleged undisputed facts are simply Plaintiff’s
assertion of her deposition testimony, and hearsay of her statements to other witnesses, couched
as “Undisputed Facts.” Ms. Maxwell strenuously disputes almost all of the alleged “undisputed
facts” claiming that she engaged in any sexual acts, misconduct or communications with plaintiff
or others; indeed, over the course of two days and thirteen hours of deposition Ms. Maxwell
disputed all such allegations.
Because none of Plaintiff's “undisputed facts” have anything to do with the issues raised
by Defendant’s Motion for Summary Judgment, Ms. Maxwell moves to strike plaintiff's
statement of “undisputed facts.”
Conclusion
For the foregoing reasons, Ms. Maxwell requests that the Court deem her Undisputed
Facts admitted, and that the Court strike plaintiff's statement of “undisputed facts.”
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Dates
Document Details
| Filename | DocumentCloud_Epstein_Docs_p01887.png |
| File Size | 226.6 KB |
| OCR Confidence | 94.1% |
| Has Readable Text | Yes |
| Text Length | 1,440 characters |
| Indexed | 2026-02-04 12:31:21.247114 |