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EFTA01116345

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NOTES OF QUOTES AND STATEMENTS FROM DEPOSITION TRANSCRIPTS I. Deposition of L.M. Although L.M. has sought in her civil case against Epstein to portray herself as an innocent, who was damaged by her interactions with Epstein, both her behavior and her own sworn statements during the course of her deposition in her civil case belie her claims. Repeatedly throughout the course of her deposition, L.M. engaged in the frequent use of profanity and personal attacks on Epstein's counsel. For example, during her deposition, L.M. made the following comments: A: You're an asshole. Q: You were a - A: You're a fucking asshole. (see Depo Transcript 130:10-19) A: You are just fucking sitting here making money. (see Depo Transcript 132:9-10) Q: Ok, you were partying, right? A: Yeah, like normal people do like you're going to probably do after this with all your fucking money. (see Depo Transcript 133:3-5) Q: ... Let's be honest A: Okay. Lees be honest. Q: Did you ever send? A: Yeah Jackass. You're a fucking asshole. (see Depo Transcript 225:19-23) In fact, L.M.'s use of profanity was so egregious and disruptive during her deposition that the court agreed to extend her deposition for six hours and ordered her attorney to caution L.M. against engaging in such further inappropriate behavior: But the witness should be warned that the Court will not tolerate any further vulgarities, any further accusations without merit relative to counsel, any further attacks on counsel, any references to counsel's children or anything of that nature. I will allow the deposition ... without interruptions of the same type that we witnessed by virtue of my reading of this transcript on several occasions now, to last another six hours, total. Period. 1 EFTA01116345

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