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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 4 of 27 associated with Mr. Epstein of abusing her; (iv) the testimony of Juan Alessi and Alfredo Rodriguez, two household employees of Mr. Epstein; and (v) what Mr. Cassell alleges is a “pattern of deception” by me to keep the “truth” from coming out. I will address each of these, in detail, in turn. As will immediately become clear, the information presented by Mr. Cassell in no way substantiates Ms. Giuffre’s claims. To the contrary, much of the evidence contradicts Ms. Giuffre’s version of events. In addition, I offer a few final points about matters that demonstrate clearly that Ms. Giuffre is not a credible witness. The Palm Beach Police Department Report 8. The Cassell Declaration cites a July 2006 Palm Beach Police Department Report, which identified Jeffrey Epstein’s home in Palm Beach as a location at which Mr. Epstein allegedly abused minor victims. Mr. Cassell contends that this Report supports Ms. Giuffre’s account that I abused her at the Palm Beach home. See Cassell Decl., § 21(a)-(b). But, as Mr. Cassell conceded in his deposition in the Edwards defamation case, my name does not even appear in the Palm Beach Police Department Report—much less does the Report contain an allegation that I sexually abused someone. See Ex. O at 31 (Deposition Transcript of Paul G. Cassell, October 16-17, 2015). 9. Mr. Cassell asserts that the Palm Beach Police Report “showed the sexual abuse was occurring on a daily basis” at the Epstein mansion, and thus “that [it] would have made it obvious to a visiting guest that young girls were coming to the home for sexual purposes.” Cassell Decl., § 21(b). Putting aside the conclusory nature of the inference (For example, by what means would it be “obvious,” and to which “guests?” I would think that if someone were doing something illegal, such as arranging trysts with underage girls, they would take measures to conceal their conduct), the statement is entirely irrelevant to me. First, I was not present in that home—or on Mr. Epstein’s private island, or at his New Mexico ranch, or on