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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 8 of 27 18. Mr. Cassell was present at my October 2015 deposition in the Edwards case, and he is aware of Tatiana Kovylina’s actual age. Yet, in his Declaration to this Court, he continues to suggest that her presence on Mr. Epstein’s airplane in 2005 supports the inference that I was aware of Mr. Epstein’s alleged abuse of Ms. Giuffre in 2000-2002, and that I participated in such conduct. Cassell Decl., § 21(g). While Mr. Cassell cloaks this suggestion in language concerning “information [he and Mr. Edwards] relied upon in believing the truth of Ms. Giuffre’s allegations,” that is too clever by half. Jd. at 21. The inference that he asks this Court to draw is that the presence of Ms. Kovylina supports the allegations against me. That is simply false. Ms. Giuttre’_s Civil Complaint and Her Claim of Abuse by “Academicians” 19. In his Declaration, Mr. Cassell states that he believed Ms. Giuffre’s allegations that I sexually abused her, in part, because Bob Josefsberg, ““a very well regarded Florida lawyer,” apparently believed her, having filed a civil complaint against Mr. Epstein on her behalf. Cassell Decl., {21(e). The Josefsberg-filed civil complaint did not name me. 20. Mr. Cassell was not relieved of his professional obligation to investigate the bona fides of Ms. Giuffre’s claims simply because a different lawyer had already decided to file a case on her behalf. Mr. Casssell’s reliance on the case filed by Mr. Josefsberg is particularly inappropriate because the Josefberg-drafted case does not name me as an abuser. Moreover, Mr. Josefsberg has continued to maintain a personal and professional relationship with me, something he would not have done if he believed I had abused his client—a fact that Mr. Cassell and the other lawyers could have readily ascertained. 21. Nor was it reasonable to accuse me of pedophila based on the fact that Ms. Giuffre alleged in the Josefsberg-drafted civil complaint that she had been trafficked by Jeffrey