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Case 18-2868, Document 284, 08/09/2019, 2628244, Page31 of 38 Roberts in Mr. Epstein’s house.” Ex.HH at { 17. Detective Recarey entered Epstein’s home in 2002 to install security cameras to catch a thief and did not observe any “child pornography” within the home, including on Epstein’s desk in his office. Ex.GG at 289-90. a. Reply: Plaintiff offered no evidence that a nude photograph of her was displayed in Epstein’s home. All of the testimony she submits has nothing to do with a nude photograph of herself. The fact should be deemed admitted. 50. Undisputed Fact 50: Plaintiff intentionally destroyed her “journal” and “dream journal” regarding her “memories” of this case in 2013 while represented by counsel. Plaintiff drafted a “journal” describing individuals to whom she claims she was sexually trafficked as well as her memories and thoughts about her experiences with Epstein. Ex.II at 64- 65, 194; Ex.N at 205-08. In 2013, she and her husband created a bonfire in her backyard in Florida and burned the journal together with other documents in her possession. /d. Plaintiff also kept a “dream journal” regarding her thoughts and memories that she possessed in January 2016. Ex.II at 194-96. To date, Plaintiff cannot locate the “dream journal.” Id. a. Reply: Plaintiff offers no contrary admissible regarding her destruction of her journal and it should be deemed admitted. 51. Undisputed Fact 51: Plaintiff publicly peddled her story beginning in 2011. Plaintiff granted journalist Sharon Churcher extensive interviews that resulted in seven (7) widely distributed articles from March 2011 through January 2015. Doc. 216 {J 2-11 and referenced exhibits; Doc. 261-1 to 216-8, incorporated by reference. Churcher regularly communicated with plaintiff and her “attorneys or other agents” from “early 2011” to “the present day.” Plaintiff received approximately $160,000 for her stories and pictures that were published by many news organizations. Ex.N at 247-248. 30

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Filename DocumentCloud_Epstein_Docs_p01882.png
File Size 298.3 KB
OCR Confidence 94.8%
Has Readable Text Yes
Text Length 1,985 characters
Indexed 2026-02-04 12:31:21.435457