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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 7 of 27 16. Desperate to draw some connection between me and young girls on the airplane, Mr. Cassell also states that the flight logs show me and “an apparently young woman named ‘Tatiana’ who did not appear to serve any business purpose for Epstein” flying together on Mr. Epstein’s plane with Mr. Epstein and other individuals. See Cassell Decl. {| 21(g) (internal parentheses omitted). What his declaration conveniently fails to mention is that the flight in question took place on November 17, 2005, years after Ms. Giuffre’s association with Mr. Epstein concededly ended. See McCawley Decl., Ex. 2 at GIUFFRE007135. The connection between a flight in 2005 and Ms. Giuffre’s alleged abuse is, of course, non-existent: by 2005, Ms. Giuffre was living in Australia. 17. But that is just a detail. As Mr. Cassell well knows, Tatiana Kovylina, the woman who flew on Mr. Epstein’s plane with us and several other people in 2005, was 24 years old at the time of the flight. During my deposition in the Edwards case, | was asked about and shown photos of “Tatiana”; I said that I thought she appeared to “about 25” years old. It turned out that my estimate was correct. This exchange followed: [DERSHOWITZ]: ... I must say that during the recess, my wife Googled Tatiana and found out that she was, in fact, 24 years old in 1995 [sic - 2005)’, at the time she flew on that airplane. So that my characterization of her as about 25 years old is absolutely correct. And the implication that you sought to draw by showing me those pictures was not only demonstrably false, but you could have easily discovered that the implication you were drawing was demonstrably false by simply taking one second and Googling her name as my wife did.” Ex. P at 216-17 (Deposition Transcript of Alan M. Dershowitz, October 16, 2015). > In fact, I meant the year 2005. According to Wikipedia, Ms. Kovylina was born on November 4, 1981. See https://en.wikipedia.org/wiki/Tatiana_Kovylina.

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Filename Giuffre_Maxwell_Batch5_p00087.png
File Size 320.5 KB
OCR Confidence 94.6%
Has Readable Text Yes
Text Length 2,030 characters
Indexed 2026-02-04 12:44:05.098630