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Case 18-2868, Document 284, 08/09/2019, 2628244, Page27 of 38
had lit her mattress on fire. Ex.AA. Again, plaintiff met and spoke with the law enforcement
officers but did not complain that she was the victim of any sexual trafficking or abuse or that
she was then being held as a “sex slave.” Jd.
a. Reply: Plaintiff, again, presents no admissible evidence to contradict these
facts, instead arguing their relevance. They should be deemed admitted.
44. From August 2001 until September 2002, Epstein and Maxwell were almost
entirely absent from Florida on documented travel unaccompanied by Plaintiff. Flight logs
maintained by Epstein’s private pilot Dave Rodgers evidence the substantial number of trips
away from Florida that Epstein and Maxwell took, unaccompanied by Plaintiff, between August
2001 and September 2002. Ex.BB. Rodgers maintained a log of all flights on which Epstein and
Maxwell traveled with him. Ex.CC at 6-15. Epstein additionally traveled with another pilot who
did not keep such logs and he also occasionally traveled via commercial flights. Id. at 99-100,
103. For substantially all of thirteen months of the twenty-two months (from November 2000
until September 2002) that Plaintiff lived in Palm Beach and knew Epstein, Epstein was
traveling outside of Florida unaccompanied by Plaintiff. Ex.BB. During this same period of
time, Plaintiff was employed at various jobs, enrolled in school, and living with her boyfriend.
a. Reply: Plaintiff goes to great lengths to dispute facts other than those presented
as Undisputed Fact 44. Her voluminous, repetitive recitation of the flights that Plaintiff
was on do nothing to demonstrate the 13 months of flights from July 2001 until August
2002 that Epstein and Maxwell were on without Plaintiff, as reflected in the logs. Her
assertions regarding the other flights that she took, commercial or on another plane, do
nothing to establish all of the many flights she was not on during 13 of the 22 month
period during which Epstein and Maxwell were away from Palm Beach. Plaintiff does
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Document Details
| Filename | DocumentCloud_Epstein_Docs_p01878.png |
| File Size | 295.5 KB |
| OCR Confidence | 95.4% |
| Has Readable Text | Yes |
| Text Length | 2,065 characters |
| Indexed | 2026-02-04 12:31:21.859912 |