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Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 27 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
9. Admit that you were no younger than 17 years old when you worked at Mar-a-
Lago.
Response to Request For Admission No. 9:
Denied. After thorough investigation, she has only been able to discover the year in
which she worked at Mar-a-Lago was 2000, and consequently was recruited by Ghislaine
Maxwell, for sex with Epstein. The month has not been made available, therefore denied.
10. Admit that You never observed Ghislaine Maxwell ever have any sexual contact
with any person under the age of 18.
Response to Request For Admission No. 10:
Denied.
11. Admit that You never observed Bill Clinton on the island of Little St. James.
Response to Request For Admission No. 11:
Denied.
12. Admit that You never had a conversation with Bill Clinton regarding him flying
with Ghislaine Maxwell in a helicopter.
Response to Request For Admission No. 12:
Objection. Defendant Maxwell has clearly incorrectly interposed and comingled the facts
which comprise the foundation of this request for admission. Ms. Giuffre has never alleged that
she “had a conversation with Bill Clinton regarding him flying with Ghislaine Maxwell in a
helicopter.” Instead, Ms. Giuffre has alleged, “I flew to the Caribbean with Jeffrey and then
Ghislaine Maxwell went to pick up Bill [Clinton] in a huge black helicopter that Jeffrey had
bought her.” Sara Nathan, Bill Clinton Pictured with Jeffrey Epstein’s Social Fixer, Daily Mail,
(12 January 2015).
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Document Details
| Filename | Giuffre_Maxwell_Batch4_p00111.png |
| File Size | 259.4 KB |
| OCR Confidence | 95.3% |
| Has Readable Text | Yes |
| Text Length | 1,585 characters |
| Indexed | 2026-02-04 12:40:53.331088 |