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VOL00012

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PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS
CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e)
In or around was in her early 20s, she met Epstein through the modeling
community. Around , Epstein offered a job working as an
assistant. Around early began working as an assistant for Epstein, and she remained
his employee until early reported to who reported to Ghislaine
Maxwell.
responsibilities included running errands and scheduling appointments. As a
result, scheduled numerous massages for Epstein. According to Epstein expected to
have two massages every day: one in the morning and one in the afternoon. and-
were responsible for ensuring that these massages were confirmed when Epstein was in Palm
Beach. Leslie Groff was responsible for scheduling the massages when Epstein was in New
York.
At some point, Epstein began forcingM to engage in sexual encounters, which were
coercive and nonconsensual. was very distressed when discussing these incidents and did
not want to describe them in detail during our first meeting. At least some of these encounters
involved providing Epstein with his massages while at his Virgin Islands residence. As a
result, was aware that Epstein's massages were usually sexual. described how Epstein
had two groups of girls who provided massages in his Palm Beach and New York homes: one
group was of professional masseuses who gave actual massages to Epstein's friends, and the
second group consisted of younger girls who were not professional masseuses and who only
gave massages to Epstein.. explained that she implicitly understood at the time, and now
realizes fully that Epstein was engaging in sexual contact with the second group of girls.
When scheduling massage appointments, either or Epstein would provide
with the names of girls to call for massages, but for the most part called to confirm
massage appointments. • also recalled that would sometimes ask to call some of
the masseuses and ask if they have another girl to bring.. would occasionally show girls to
the massage room and set up the massage table. • believed it was possible Epstein had asked
to pay the girls, but she cannot recall for certain. typed up a list of girls to call in
Palm Beach and printed copies.
recalled certain details that signaled to her, in retrospect, that girls in this second
group were minors. For example, she was asked to help find SAT prep courses for one girl, and
she recalled girls mentioning school and their parents. That said,M was
-
was not at the time familiar with the SAT or the fact
that it is typically taken by high school students. explained that, at the time of the relevant
conduct, she never consciously realized that any of the girls involved in sexualized massages
were underage. She now realizes in retrospect, that she should have known that at least some of
these girls were minors.
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