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Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 27 of 40 RFA No. 7. Admit that you did not work for Jeffrey Epstein for four years. Response: Denied in part. At the time she made the statement, many years after the events occurred, and based purely from memory without the assistance of any documents, she firmly believed she was with Jeffrey Epstein over a four year period. With the assistance of various records obtained after she made that statement, she now knows that she was not with Jeffrey Epstein for four years. She was sent to Thailand by Jeffrey Epstein in September 2002 and that was the last time she saw him. RFA No. 8. Admit that You did not spend four years as an underage sex slave for Jeffrey Epstein. Response: Denied in part. At the time she made the statement, many years after the events occurred and based purely from memory without the assistance of any documents, she firmly believed she was with Jeffrey Epstein over a four year period. With the assistance of various records obtained after she made that statement, she now knows that she was not with Jeffrey Epstein for four years; however she was a sex slave for Jeffrey Epstein for years. RFA No. 13. Admit that You never observed Al Gore on the island of Little St. James. Response: Denied in part. Her memory from 15 or more years ago is that it was on the island where she met Mr. Gore, although she has testified that she could have been incorrect on that location. While traveling with Epstein and Maxwell, she met so many people and was taken to so many places as a minor that perfect recall of exact locations is difficult, but based on her best recollection, denied. In Request for Admissions Nos. 1-8 and 13, Plaintiff answered “[d]enied in part” and then provided a narrative that implicitly admitted the request for admission while explaining why she believed otherwise at an earlier time. None of these responses is proper. Rule 36(a)(4) provides in relevant part: If a matter is not admitted, the answer must specifically deny it or state in detail why the answering party cannot truthfully admit or deny it. A denial must fairly respond to the substance of the matter; and when good faith requires that a party qualify an answer or deny only a part of a matter, the answer must specify the part admitted and qualify or deny the rest. 24