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Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 154 of 239

A. I interviewed people for jobs for professional things and I am not aware of anyone aside from now Virginia who clearly was a masseuse aged 17 but that’s, at least that’s how far we know that I can think of that fulfilled any professional capacity for Jeffrey.

Q. List all the people under the age of 18 that you interacted with at any of Jeffrey’s properties?

A. I'm not aware of anybody that I interacted with, other than obviously Virginia who was 17 at this point?

(Ex. 10 at 382:4-384:20).

The defendant argues that this question was “grossly ambiguous: who was ‘Jeffrey’; what were ‘Jeffrey’s properties;’ to what time frame did the question apply; what was the basis for Ms. Maxwell to determine who may or may not have been ‘under the age of 18’; and what did ‘interact with’ mean?” (Def. Mot. 4 at 11). These arguments only underscore the principle that perjury prosecutions are an inquiry into “the natural meaning in the context in which words were used,” Bonacorsa, 528 F.2d at 1221, and not an opportunity for defense counsel to “plumb[] a question for post hoc ambiguity,” Strohm, 671 F.3d at 1178. A reasonable jury, after hearing the evidence, could readily conclude that the natural meaning of those words in context is abundantly clear. For instance, at the end of trial, a jury could conclude that “Jeffrey” is Jeffrey Epstein; “Jeffrey’s properties” are Jeffrey Epstein’s properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 10 at 248:17-20 (naming those properties)); and “interact” is an expansive word aimed at capturing any encounter, that was used after the defendant resisted words like “met,” “found,” and “hired” in the prior questions, see Interact, Oxford English Dictionary Online, https://oed.com/view/Entry/97518 (last visited February 25, 2021) (“To act reciprocally, to act on each other.”). Such inferences will be particularly easy for a jury to reach after hearing multiple victims testify about their own

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