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10 et, i 138 14 15 16 ey 18 a 20 21 aD. 23 24 25 Case 1:20-cr-00330-PAE Document 212-2 App.-081 GALMGIUC four individuals had sexually abused he Mr « Epstein. If she has evidence that she a from depression or some type of mental meeting our client, Ms. Maxwell, or Mr. could be relat flashbacks, if you will, that she has put out in the press. And she, Filed 04/16/21 6 12 r prior to ever meeting lready was suffering health disorder before then her Epstein, ed to other incidents I believe, has also told the press that she was in a drug rehabilitation facility at the time that she met Mr. EF Obviously, to the extent she w which is what she has told th of drugs, met him, she persisted in being addicte time that she knew Mr. and it Epstein, I believe she has of her requests for, damages, your Honor, not just from the harkening back to what she claims were victim. THI What's the basis o Tl COURT: will call it the flashback? MS. MENNINGER: Yeur Henoer, THI! Gad COURT: Because, quite fra that. Is that my error? Are you telli not quite right? MS. MENNINGER: Your Honer, I plaintiff has alleged in her complaint. pstein. as under the influence e press, at the time she d to drugs during the certainly relates to all requested $30 million in defamation, but also her years as a sex abuse f your statement that we believe -- nkly, I was unaware of ng me something that's believe that is what If you can give me a SOUTHERN DISTRICT REPORT ERS, 2IC. (212) 805-0500 Page 13 of 30 DOJ-OGR-00003815