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Oo O DN OO FF WwW NY = NO RO PRP LP PNMO NO | S| S| |S FS FS S| S| | | no Bb WO NO F- ODO OO WDNnN DO OT BP WO NYO — 32 December 30th, 2014, that every massage given to anybody at Mr. Epstein's residence was a code word for sexual abuse? A. It was my understanding that the term "massage" was frequently, if not almost invariably, used as a code word for sexual abuse, or at least sexual activity, if the girl happened to be over the age of 18. But in most cases at least, or in many cases depending on exactly what universe you're looking at, these were underage girls, under the age of consent in the State of Florida, they were under the age of 18. Sometimes as young as -- I think it went all the way down to, gosh, I'm trying to remember now, I think 13 or 14 was was the youngest age in the police report. Q. Is it your position that as of December 30th, 2014, you had a sufficient basis under the Federal Rules of Procedure and applicable ethical rules to allege that anyone who got a massage at Mr. Epstein's residence had abused minors? A. No. Q. What -- back up now. With respect again to other minors as of December 30th, 2014, had anyone -- had any young woman, other than -- we will put -- I'm going to ask about Virginia Roberts separately. ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021855