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Case 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 2 of 10 Ms. Giuffre intends to strongly disprove Defendant’s false assertions and to demonstrate that Defendant recruited Ms. Giuffre to be involved in massages of a sexual nature with Epstein. To develop evidence to support her position, Ms. Giuffre recently deposed Defendant about the central subjects in her case. Defendant flatly refused to answer a number of questions, and for the majority of the others, gave varying versions of “I don’t recall.” For example, when faced with the police report which contains statements from approximately thirty (30) different victims during a time frame which the Defendant acknowledges she was actively working for Epstein at his various homes, Defendant challenged the veracity of the victims’ reports: “Q. Are you saying these 30 girls are lying when they gave these reports to police officers? A. I’m not testifying to their lies. I’m testifying to Virginia’s lies.” See Declaration of Sigrid McCawley (“McCawley Decl.”) at Exhibit 1, April 22, 2016 Deposition of Defendant at p. 89-90; 83-84. While Defendant was working with Epstein during the time period when these underage girls were visiting Jeffrey’s home, Defendant claimed to be at the house maybe once in 2005. /d. at p. 84. Yet, according to flight manifests, in that same general time period, Defendant was listed as a passenger at least eleven times either landing in or departing from West Palm Beach, Florida on Jeffrey Epstein’s private plane. See McCawley Decl. at Exhibit 1, April 22, 2016 Depo Tr. at p. 84; see also McCawley Decl. at Composite Exhibit 2, Flight Logs from Jeffrey Epstein’s private planes. Moreover, again according to flight logs, Defendant was on Epstein’s planes over 300 times — including 23 times with Ms. Giuffre when Ms. Giuffre was underage. Yet, quite remarkably, Defendant claimed she “couldn’t recall” even one of those flights. See McCawley Decl. at Exhibit 1, April 22, 2016 Deposition of Defendant at p. 120-122.