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PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS
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meeting. they primarily focused on three victims: and
First, they highlighted a number of inconsistencies within account, including
prior accounts of abuse that has since admitted to fabricating in her memoir. They also
pointed out that account of being forced to have sex with other men differs
dramatically from that of other victims of Epstein's abuse. Second, they noted that
was an adult when she met Epstein and that she had admitted to lying and saying that
she had video evidence of her abuse, when she did not. Finally, they noted that flight lo show
that Maxwell was "never" in New Mexico in , which is when says
Maxwell engaged in inappropriate behavior with her. Maxwell denies allegations.
b. Counsel for Leslie Groff
Leslie Groff worked as Epstein's primary New York-based assistant from at least in or
about 2001 through the summer of 2019. Her responsibilities included, among other things,
scheduling Epstein's massages at the New York residence. Generally, Groff would call victims
to schedule massage appointments, but she had limited interactions with the victims beyond
scheduling. In addition to scheduling massage appointments, Groff would also book flights for
girls who travelled to meet Epstein at his various residences. Groff made these arrangements by
phone from the New York office where she worked for Epstein. She spent little time in
Epstein's residence and thus had few in-person interactions with victims.
in or around 2000. She also described acting as his employee and being tasked with running his
various properties. She claimed to have spent very little time with Epstein in the 2000s.
Throughout the deposition. Maxwell took virtually every opportunity she could to call'. a
liar and to accuse both and her attorneys of feeding "vicious lies" to the press. e
denied any awareness that any minors other than ever massaged Epstein, and she denied
any knowledge of any sexual contact between Epstein and any minors. She also denied knowing
that Epstein engaged in sexual activity durin the course of massages. Maxwell admitted during
herde position to meeting both and but denied any awareness that
Epstein had sexual contact with t em. S e claim not to reca 1 age and claimed that
she only saw at Epstein's Palm Beach residence and that was with her mother on
all of those visits. Maxwell also claimed that she had never given anyone. including Epstein, a
massage, though she admitted to showing people where "pressure points" are located on a hand
and foot. She denied ever showing anyone how to massage Epstein. She also denied ever
having sexual contact with-
60It is true that the flight lo s for Epstein's private jet do not show Maxwell flying on his plane
to New Mexico in ; however, it is still possible that Maxwell took a commercial
flight to New Mexico. Given e passage of time, it has not been possible to obtain records of
such travel.
In any event, Maxwell admitted during her 2016 deposition that she met at
Epstein's New Mexico residence. Although that admission does not inc. te, s e has
admitted under oath to meeting
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