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Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 48 of 179 perform massages? A. I did not. Q. When you were either in the USVI or in Palm Beach, did you ever observe any females either topless or naked out by the pool? A. Yes. Q. What did you observe? A. Mostly skinny-dipping. Q. Do you know who the individuals were that you observed? A. Sarah Kellen and Ghislaine. Anybody else? Yes, but I don't recall who. Did that happen on more than one occasion? Q A. Q. A Yes. Q. How often do you remember making those observations? A. Three times. Q. Do you recall giving a statement to the police regarding Jeffrey Epstein? A. Yes. Q. Do you recall when you gave that statement? A. I don't recall the date. Q. Do you recall the year? MAGNA® LEGAL SERVICES