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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 6 of 27 13. As the record demonstrates, I could not have abused Virginia Roberts Giuffre because, as the records establish, I was never in Mr. Epstein’s Palm Beach home, private island, ranch or airplane during the two years that she was associated with Mr. Epstein. The Palm Beach Police Department Report neither corroborates Ms. Giuffre’s false accusation, nor supports the decision by Mr. Cassell, Mr. Edwards and the other lawyers for Ms. Giuffre to publicly accuse me of such pedophila. The Flight Logs 14. In his Declaration, Mr. Cassell suggests that the flight logs of Mr. Epstein’s private jet showing Ms. Giuffre travelling to New York support the conclusion that I abused Ms. Giuffre in New York, because I was a visiting scholar at N.Y.U. and lived in N.Y.U. housing during the 2000-2001 academic year. See Cassell Decl., ] 21(c). This allegation, and the string of inferences necessary to make it “work,” is patently absurd. Millions of people were present in the New York City area when Ms. Giuffre travelled there; it is simply not reasonable to infer from my presence in New York at the same time, apparently, as Ms. Giuffre that I sexually abused her—there or anywhere else. 15. In his deposition in the defamation case against me, Mr. Cassell acknowledged that my name did not appear in the aircraft flight logs during the time period in which Ms. Giuffre was associated with Mr. Epstein: [CASSELL]: The face of the flight logs for the relevant period of time, we can call it the hot period of time or whatever you want, did not reveal the presence of Mr. Dershowitz on those flights, yes. Q: Okay. So during the period—well, actually, there’s no flight log that shows Virginia Roberts and Professor Dershowitz on the same airplane, correct? A: That’s my understanding, yes. Ex. O at 205.