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Case 1:15-cv-07433-LAP Document 1331-4 Filed 01/05/24 Page 14 of 21 psychologist, Judith Lightfoot. Ms. Lightfoot’s own records, written in 2011, describe Defendant as Ms. Giuffre’s abuser: . .. was approached by Ghislaine Maxwell who said she could help her get a job as a massage therapist . . . seemed respectable . .. was shown how to massage, etc., Geoff [sic] Epstein. Told to undress and perform sexual acts on person. Miss Maxwell promised her $200 a job. See Schultz Decl. at Exhibit 4, June 9, 2011 Lightfoot Records at GIUFFRE005437. As the Court can see, the same year Ms. Giuffre wrote in her journal about the abuse she endured, she wrote a manuscript detailing that abuse, and confided in her treating psychologist that Maxwell recruited her for sex with Epstein. Therefore, the contemporaneous records evidence Defendant’s guilt, and indicate that similar statements would be in Ms. Giuffre’s journal. Accordingly, this journal would merely be cumulative with the volumes of other evidence showing Defendant’s involvement in the sexual abuse of Ms. Giuffre. Indeed, contemporaneous with Defendant’s abuse in the 2000-2002 time period, Tony Figueroa testified that Virginia confided in him that Defendant required her to participate in threesomes with Defendant and Epstein during the time it happened: Q. I guess my question is: Did she ever tell you that she had started as a regular masseuse for him and then transitioned to something other than a masseuse? A. No. She never said that it transitioned. But she ended up explaining to me what had happened before, so... Q. What has -- what is that? A. That her and Ms. Maxwell and Jeffrey would obviously be doing stuff, all three of them together. Like I said, that they would all go out to clubs to pick up girls and try and find them to bring back for Jeffrey. And then she told me about how, like I said, her and Ms. Maxwell and Jeffrey were all intimate together on multiple occasions. Q. When did she tell you this? A. I'm not exactly sure on the dates. 11