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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 34 of 50 back with Defendant and Epstein, and went on five more flights on Epstein’s plane before finally escaping abroad. Accordingly, the records and testimony in this case establish that Ms. Giuffre had no continuity of education or residence or other markers that normally anchor specific events in time for a high schooler. Instead, she attended multiple schools sporadically, she was sexually assaulted at 14, she ran away from home multiple times, and then ended up being abused by Defendant and Epstein, traveling all around. It is not surprising that Ms. Giuffre had trouble identifying specific calendar dates. At any rate, in compliance with Rule 36(a)(4), Ms. Giuffre stated which part of the statement she denies. She denies statements involve her age. She was not 15, but 16, turning 17 in August the summer she was trafficked by Defendant and when she met Epstein. She was sexually trafficked as a minor child by Defendant and Epstein; she did celebrate one of her teenage birthdays with Defendant; Defendant did tell her that she would soon be too old for [convicted pedophile] Jeffrey Epstein’s taste; she did work at Mar-a-Lago the summer of 2000 when she was a minor; she did work for Epstein from 2000-2002. Ms. Giuffre will not deny those parts of Defendant’s requests for admission; and she did see recall seeing Al Gore during the time she was with Epstein and Defendant. B. Requests for Admission Nos. 12 Ms. Giuffre’s objection to Request for Admission No. 12 is correct pursuant to Rule 36(a)(5), Fed. R. Civ. P.'> Rule 36(a)(5) states “[t]he grounds for objecting to a request must be stated. A party must not object solely on the ground that the request presents a genuine issue for trial.” Ms. Giuffre’s objections are compliant with this Rule. Here, Defendant has made up a 8 Again, in violation of Local Rule 37.1, Defendant omits the case law that Ms. Giuffre put forth in support of her objection. 28