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Case 1:15-cv-07433-LAP Document 1328-35 Filed 01/05/24 Page 4 of 10
Q. Do you know what happened during the massage appointments with Jeffrey
Epstein and Virginia Roberts?
A. No.
Q. Were you ever present to view a massage between Jeffrey Epstein and Virginia
Roberts?
A. I don't recollect ever seeing Virginia and Jeffrey in a massage situation.
Q. Do you ever recollect seeing them in a sexual situation?
A. Inever saw them in a sexual situation.
Q. Did you ever participate in sex with Virginia Roberts and Jeffrey Epstein?
A. I never ever at any single time at any point ever at all participated in anything
with Virginia and Jeffrey. And for the record, she is an absolute total liar and you
all know she lied on multiple things and that is just one other disgusting thing she
added.
(4/22/16 Tr. at 75-76). The Palm Beach State’s Attorney’s Office, the Palm Beach Police
Department and the Royal Palm Beach Police Departments all likewise have never concluded
that Plaintiff was a “child victim of sexual abuse.” Rather their reports reflect Plaintiff's false
allegations of being a “child victim of sexual abuse” in situations such as getting in trouble for
running away from home, getting in trouble for not attending school, getting in trouble for using
alcohol and marijuana. There is absolutely nothing “undisputed” about Plaintiff's claim of
victimhood.
Furthermore, Plaintiff left unredacted her assertion that it is “undisputed” that Ms.
Roberts was the child victim of sexual abuse, leaving the mis-impression with the public that Ms.
Maxwell has in some way conceded that to be true. She has not.
3. “Detective Joseph Recarey ... testified that Defendant procured underage girls
for Epstein” (Reply at 3, n.4). In fact, Detective Recarey testified that none of the underage girls
interviewed in connection with his investigation into Epstein claimed to have been hired by
Maxwell; in fact, none of them mentioned Ms. Maxwell at all. The two women he interviewed
who were hired by Ms. Maxwell both said they gave professional, adult massages to Epstein.