Giuffre_Maxwell_Batch5_p00096.png

Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 16 of 27 there. It was not, as Mr. Cassell misleadingly suggests, an affirmation that Ms. Giuffre and I were present at Mr. Epstein’s house at the same time. 37. In fact, Mr. Alessi has since provided an affidavit flatly denying that he saw both Ms. Giuffre and I at the Palm Beach mansion at the same time. “T was never asked by any attorneys if Virginia Roberts came to the house when Mr. Dershowitz was there. If I had been asked, I would have answered that I never saw Virginia Roberts at the house when Mr. Dershowitz was there.” Ex. Q at ¥ 19 (Affidavit of Juan P. Alessi, January 13, 2016). Indeed, in his affidavit, Mr. Alessi goes on to say, “I never saw Mr. Dershowitz do anything improper or be present while anyone else was being improper.” Jd. 38. Juan Alessi’s affidavit also confirms that Mr. Cassell and Edwards failed to interview him as part of their supposed “investigation” into Ms. Giuffre’s claims, and consequently grossly misrepresented the statements he made in his deposition: The following statement made by Virginia Roberts’s attorneys and their own attorney in a filing on December 4, 2015 is not accurate and is a misrepresentation of what I said in my deposition: “Alessi was able to identify a photograph of Ms. Giuffre as someone who was at the mansion as [sic] the same time as Dershowitz. As far as I can recall, since I gave my deposition in 2009, I have never been asked by Brad Edwards or Paul Cassell about my knowledge regarding Virginia Roberts or Alan Dershowitz or about my 2009 deposition testimony. Id. at 9§ 20-21. 39, In an effort to “place” me in proximity to “sex toys” at the Palm Beach mansion, Mr. Cassell and Mr. Edwards also misrepresented other aspects of Juan Alessi’s testimony. For example, in an affidavit, Mr. Alessi states that: 16