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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 25 of 27 claims that Mr. Epstein trafficked her. It is much more likely, in light of when she actually met Jeffrey Epstein and when she says she began to have sex with his acquaintances, that she was not a minor when she claimed to have had sex with any such people. 59. Moreover, Ms. Giuffre has perjured herself by claiming that she was 15 when she met Ms. Maxwell and Mr. Epstein, most notably by submitting an untruthful declaration in the Edwards defamation lawsuit. On November 20, 2015 Ms. Giuffre executed an affidavit in which she alleged that: “In approximately 1999, when I was 15 years old, I met Ghislaine Maxwell . . . Soon after that I went to Epstein’s home in Palm Beach on El Brillo Way. From the first time I was taken to Epstein’s mansion that day, his motivations and actions were sexual, as were Maxwell’s.... Epstein and Maxwell forced me into sexual activity with Epstein. I was 15 years old at the time.” Ex. W at § 4-5 (Declaration of Virginia Roberts, January 21, 2015). 60. She also asserted that when she “was approximately 15 or 16 years old” when Mr. Epstein and Ms. Maxwell began trafficking her to Epstein’s acquaintances. These statements are disproven by documentary evidence, and Ms. Giuffre has herself admitted that they are not true. Conclusion 61. In his Declaration before this Court, Paul Cassell has provided an accounting of the “evidence” that he claims supports the truth of Virginia Roberts Giuffre’s accusations against me. It is a woefully inadequate presentation, as the preceding paragraphs demonstrate. The irony, of course, is that Mr. Cassell’s accounting is in service to his and his client’s goal of keeping sealed far more compelling evidence—namely, the Requested Documents—that undercuts the accusations against me and shows them to be a recent 25