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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 22 of 27 51. At no point did Mr. Edwards, Mr. Scarola, or any of their associates tell me that Ms. Giuffre had accused me of sexual abuse, because, at that point, she had not. Had I been accused at that time, I would have provided records demonstrating the falsity of any such allegations. Other Facts That Show that Ms. Giuffre Lacks Credibility 52. Inasmuch as Mr. Cassell is inviting this Court to accept Virginia Roberts Giuffre’s assertions about me, other examples of her lack of credibility are relevant. 53. In the first place, Ms. Giuffre has been demonstrated to have made up wildly implausible tales for financial gain. In 2011, for example, Ms. Giuffre was interviewed by Sharon Churcher at The Daily Mail, and provided detailed accounts of an alleged encounter with Bill Clinton on Jeffrey Epstein’s private island in the Caribbean. In exchange for that interview, Ms. Giuffre was paid $160,000. Ms. Giuffre’s account of meeting Clinton is both completely unbelievable on its face, and demonstrably untrue. For example, she claims that: “Ghislaine Maxwell went to pick up Bill [Clinton] in a huge black helicopter that Jeffrey had bought her. She’d always wanted to fly and Jeffrey paid for her to take lessons, and I remember she was very excited because she got her license around the first year we met. I used to get frightened flying with her but Bill had the Secret Service with him and I remember him talking about what a good job she did.” Ex. T at 2-3 (Daily Mail Article, March 5, 2011). Ms. Giuffre then described, in detail, a dinner with President Clinton, Jeffrey Epstein and others on Little St. James Island, which Mr. Epstein owned.” ° Further demonstrating her ability to weave a vivid, yet utterly false tale, Ms. Giuffre also recounts that: “We all dined together that night. Jeffrey was at the head of the table. Bill was at his left. I sat across from him. Emmy Tayler, Ghislaine’s blonde British assistant sat at my right. Ghislaine was at Bill’s left and at the left of Ghislaine there were two olive-skinned brunettes who’d flown in with us from New York.... Maybe Jeffrey thought they would entertain Bill, but I saw no evidence that he was interested in them. He and Jeffrey and Ghislaine seemed to have a very good relationship. Bill was very funny.” Ex. T at 3-4. 22