minor females that the United States Attorney's Office recognized as a victim. L.M.’s swom
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minor females that the United States Attorney's Office recognized as a victim. L.M.’s swom
deposition testimony and the adverse inference drawn from Epstein’s refusal to testify confirm
that Epstein began sexually assaulting L.M. when she was 13 years old and continued to molest
— on more than fifty (50) occasions over three (3) years. Epstein Depo., Attachment #1, at 17
(“Q: Did you... ever engage in any sexual conduct with L.M.?” A: [invocation of the Fifth
Amendment.) see also Epstein Depo., April 14, 2010, Attachment #6, at 456 ("Q: LM was an
underage female that you first abused when she was 13 years old; is that correct?" A: [Invocation
of Fifth Amendment].) .
8. Epstein was also given ample opportunity to explain why he engaged in sexual
activity with L.M. beginning when L.M. was 13 years old and why he has molested minors on an
everyday basis for years, and he invoked his Sth amendment right rather than provide
explanation. See Epstein Deposition, February 17, 2010, at 11-12, 30-31 (Deposition
Attachment # 7). | .
. 9. Epstein also sexually assaulted E.W., beginning when she was 14 years old and
did so on numerous occasions. See E.W. Depo., Attachment #4 at 215-216.
10. Another of the minor sits Epstein sexually assaulted was Jane Doe; the abuse
began when Jane Doe was 14 years old. Rather than incriminate himself, Epstein invoked the
5th amendment to questions about him digitally penetrating Doe's vagina, using vibrators on her
vagina and masturbating and ejaculating in her presence. Epstein Depo., April 14, 2010,
Attachment #6, at 420, 464, 468.
11. When Edwards’s clients L.M., E.W., and Jane Doe were 13 or 14 years old, each
was brought to Epstein’s home multiple times by another underage victim. Epstein engaged in
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