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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 32 of 50 IV. PLAINTIFF’S ANSWERS TO DEFENDANT’S REQUESTS FOR ADMISSIONS ARE NOT DEFICIENT AND DEFENDANT’S MOTION SHOULD BE DENIED Before rebutting Defendant’s unsupported arguments, she notes for the Court that for 27 out of 33 answers to Request for Admission Ms. Giuffre served upon Defendant, Defendant began her answer with the phrase, “Denied in Part.” Now, Defendant complains that Ms. Giuffre used the same phraseology in response to some of Defendant’s Requests for Admission. Such a complaint is unfounded. A. Requests for Admission Nos. 1-8 and 13 At the time of filing the Complaint, to the best of her recollection, Ms. Giuffre recollected that she met Defendant in the summer 1999 when she was working at Mar-a-Lago, a club in Palm Beach, Florida. Based on documents produced pursuant to litigation, Ms. Giuffre has learned that, instead, she met Defendant at the Mar-a-Lago club in 2000. During the summer of 2000, Ms. Giuffre was 16 until August 3, when she turned 17. Accordingly, Ms. Giuffre has learned that she did not meet Defendant when she was 15, but, rather, likely at 16. Either way, Ms. Giuffre was indisputably a minor when Defendant recruited her to have sex with convicted pedophile Jeffrey Epstein, with whom Defendant shared a household. Thereafter, Ms. Giuffre flew on Epstein’s private jets with over Defendant 23 times while she was a minor. Defendant makes much ado that she recruited a 16 or 17 year old for sex with Epstein rather than a 15 year old, and makes much ado over Ms. Giuffre’s mistaken memory. Ms. Giuffre did not attend middle school or high school in a linear fashion, nor did she have any continuity of residence during those years. Instead, Ms. Giuffre’s middle school and high school years were tumultuous. Based on her Palm Beach County, Florida records, it appears that, according to those records, for the 1993-1994 school year, when Ms. Giuffre’s was 10, Ms. 26