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Extracted Text (OCR)
Case 18-2868, Document 284, 08/09/2019, 2628244, Page28 of 38
not dispute that Epstein and Maxwell were on the flights without her. The facts as
presented by Defendant should be deemed admitted.
45. Undisputed Fact 45: Plaintiff and Figueroa shared a vehicle during 2001 and
2002. Plaintiff and Figueroa shared a ’93 white Pontiac in 2001 and 2002. Ex.P at 67; Ex.EE.
Plaintiff freely traveled around the Palm Beach area in that vehicle. Jd. In August 2002, Plaintiff
acquired a Dodge Dakota pickup truck from her father. Ex.P at 67-68. Figueroa used that
vehicle in a series of crimes before and after Plaintiff left for Thailand. /d.; Ex.FF.
a. Reply: Again, the Response has nothing to do with the facts stated. As Plaintiff
concedes, she and Mr. Figueroa had one car that they both used. In fact, they traveled to
and from school together. Ex.P at 67-68. She also does not dispute that she traveled
freely around the Palm Beach area in that vehicle, or that “her car” was used in a series of
thefts while she was in Thailand. All should be deemed admitted.
46. Undisputed Fact 46: Plaintiff held a number of jobs in 2001 and 2002. During
2001 and 2002, plaintiff was gainfully employed at several jobs. She worked as a waitress at
Mannino’s Restaurant, at TGIFriday’s restaurant (aka CCI of Royal Palm Inc.), and at
Roadhouse Grill. Ex.R. She also was employed at Courtyard Animal Hospital (aka Marc
Pinkwasser DVM). Id.; Ex.W.
a. Reply: Plaintiff admits all of the facts set forth above, aside from the use of the
word “gainfully.” They should be deemed admitted.
47. Undisputed Fact 47: In September 2002, Plaintiff traveled to Thailand to
receive massage training and while there, met her future husband and eloped with him.
Plaintiff traveled to Thailand in September 2002 to receive formal training as a masseuse.
Figueroa drove her to the airport. While there, she initially contacted Figueroa frequently,
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Extracted Information
Dates
Document Details
| Filename | DocumentCloud_Epstein_Docs_p01879.png |
| File Size | 284.5 KB |
| OCR Confidence | 95.0% |
| Has Readable Text | Yes |
| Text Length | 1,925 characters |
| Indexed | 2026-02-04 12:31:21.998754 |