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Case 1:20-cr-00330-PAE Document 643-1 Filed 03/11/22 Page4of6 “None of that relates to traumatic memory,” he said. Loftus said herself that she had never conducted a study on whether these tactics would work with memories of sexual abuse, David recalled. Since the trial, there has been speculation that the fact a juror had been a victim of sexual abuse could be used by Maxwell as grounds for appeal. Speaking separately to MailOnline, David said he could not remember the details of the 50 question pre-trial questionnaire each potential juror was asked about whether they were a victim of sexual abuse or a relative or a friend of a victim, but felt he had answered all questions honestly. David told The Independent that the accusers’ testimony was corroborated by a significant amount of evidence. He specifically mentioned Kate - an accuser who testified but was not allowed to be considered for the actual charges because she was over the age of consent in the UK when she was abused — and said her testimony powerfully corroborated the other accusers’ stories. “She was able to show us that this was a pattern.” David said. “We knew we couldn't use her testimony to convict Maxwell, but she showed the pattern of how those girls were groomed. “She showed us the pattern that happened to all of these girls. “It was about confusing their boundaries,” he said. “For Jane, it started with seeing Maxwell topless. For Annie Farmer, it started with Maxwell showing her how to give Epstein a foot massage. “The pattern is that Ghislaine talks to you like she is also a teenager. Then it moves into massage. She tries to make you comfortable, to see what they can get away with. “What she did was wrong.” Annie Farmer’s story was backed up by her teenage diary, as well as her high school boyfriend. That was important to the jury, he said. Carolyn’s story was backed up by Shawn, her ex-boyfriend who testified that he used to drive her to Epstein’s Palm Beach mansion. DOJ-OGR-00009851