EFTA00029847.pdf

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pdf

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data-set-8

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denial. . ."). A properly instructed jury could conclude after hearing all of the evidence at trial 
that the defendant intended the natural meaning of the words she used, not the allegedly truthful 
answer she suggests now, and therefore that she lied. In sum, the defendant's post-hoc efforts to 
inject confusion into clear questioning are unavailing and should be rejected, and the jury should 
decide whether the defendant's answers were false. 
2. 
July 2016 Deposition 
Count Six charges the defendant with perjury arising from three colloquies at the second 
deposition. 
act 
at 5 
de 
Following that line of questioning, the following 
colloquy occurred: 
When you and Mr. Epstein were engaged in sexual activity that 
included these other women, were any devices or sex toys used as 
part of the sexual activity? 
A. No. 
Q. Were you ever involved in sexual activities in Mr. Epstein's Palm 
Beach house that included the use of sex toys or any kind of 
mechanical or other device? 
MR. PAGLIUCA: Objection to form and foundation. 
A. No. 
Q. Were you ever involved in sexual activities in any of Mr. 
Epstein's properties other than Palm Beach that included the use of 
sex toys or any kind of mechanical or other device? 
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EFTA00029847


Q. Were you aware of the presence of sex toys or devices used in 
sexual activities in Mr. Epstein's Palm Beach house? 
MR. PAGLIUCA: Objection to form and foundation. 
A. No, not that I recall. 
question: 
awyer asked the following 
Q. Do you know whether Mr. Epstein possessed sex toys or devices 
used in sexual activities? 
MR. PAGLIUCA: Obiection to form adation, 
A. No. 
The defendant now argues that these questions are ambiguous because they contain 
"numerous undefined terms," such as "sex toy or device" and "sexual activities." (Def. Mot. 4 at 
14). She asks, for instance, whether "bath oil" would count as a sex toy or device. (Id.). Yet this 
argument is simply another attempt to imbue ambiguity after the fact into commonly use…

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