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Case 18-2868, Document 284, 08/09/2019, 2628244, Page26 of 38 herself as a masseuse to others, in her own handwriting, beginning in January 2001. Exs. MandN. These facts should be deemed admitted. 42. Undisputed Fact 42: Plaintiff resumed her relationship with convicted felon Anthony Figueroa. In spring 2001, while living with Austrich, plaintiff lied to and cheated on him with her high school boyfriend, Anthony Figueroa. Ex.L at 68, 72. Plaintiff and Austrich thereafter broke up, and Figueroa moved into the Bent Oak apartment with plaintiff. Ex.L at 20; Ex.P at 28. When Austrich returned to the Bent Oak apartment to check on his pets and retrieve his belongings, Figueroa in Plaintiffs presence punched Austrich in the face. Ex.X; Ex.L at 38- 45. Figueroa and plaintiff fled the scene before police arrived. Ex.X. Figueroa was then a convicted felon and a drug abuser on probation for possession of a controlled substance. Ex.Y. a. Reply: Plaintiff argues relevance regarding these facts, but contests none of them. They should be deemed admitted. Plaintiffs lies, cheating, and association with a convicted felon and known drug abuser all are relevant in this defamation case concerning her reputation, purported damage to such reputation, and whether she was a known liar, as the January 2015 statement contends. 43. Undisputed Fact 43: Plaintiff freely and voluntarily contacted the police to come to her aid in 2001 and 2002 but never reported to them that she was Epstein’s “sex slave.” In August 2001 at age 17, while living in the same apartment, plaintiff and Figueroa hosted a party with a number of guests. Ex.Z. During the party, according to plaintiff, someone entered plaintiff's room and stole $500 from her shirt pocket. Jd. Plaintiff contacted the police. She met and spoke with police officers regarding the incident and filed a report. She did not disclose to the officer that she was a “sex slave.” A second time, in June 2002, plaintiff contacted the police to report that her former landlord had left her belongings by the roadside and 25

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Filename DocumentCloud_Epstein_Docs_p01877.png
File Size 298.9 KB
OCR Confidence 94.6%
Has Readable Text Yes
Text Length 2,074 characters
Indexed 2026-02-04 12:31:22.013455