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Case 1:15-cv-07433-LAP Document 1328-35 Filed 01/05/24 Page 3 of 10 (Tr. at 57:5-13). Q. The women with whom you engaged in sexual activities with Mr. Epstein and yourself and the other women, were they older or younger than you? A. Same age as me. (Tr. at 62:10-14). It is an outright misrepresentation to this Court that Ms. Maxwell admitted to any sexual contact with a “multiple different girls.” A “girl” is a female child. See, e.g., Cambridge University Dictionary, “Girl: a female child or young woman, especially one still at school” (http://dictionary.cambridge.org/dictionary/english/girl) (last accessed August 25, 2016). Ms. Maxwell described these few occasions as occurring in the late 1990s when she was in her late 30s, with women who were the “same age as me.” Plaintiff well knows that it is irrelevant to this lawsuit whether Ms. Maxwell engaged in consensual, adult sexual activities with women. There is no allegedly defamatory statement that has anything to do with Ms. Maxwell’s private adult sex life. It is an abuse of this litigation process to even ask Ms. Maxwell such questions. Instead, Plaintiff's flagrant misrepresentation is designed to support her false assertion that Ms. Maxwell participated in sexual activities with underage girls, which she did not and indeed, no witness other than Plaintiff has claimed that she has. Plaintiff intentionally omitted the deposition pages from Ms. Maxwell’s testimony which clarified the age and misstated in her Reply that she “admitted” to “threesomes with multiple girls.” This was an intentional misrepresentation of fact. 2. “Ms. Giuffre was the child victim of sexual abuse, which is undisputed.” (Reply at 9) If there is one thing this litigation makes clear, it is heavily disputed that Ms. Giuffre was the child victim of sexual abuse. Ms. Maxwell has absolutely no evidence whatsoever that Ms. Giuffre was the child victim of any sexual abuse. As she testified at her deposition: