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32
December 30th, 2014, that every massage given to anybody
at Mr. Epstein's residence was a code word for sexual
abuse?
A. It was my understanding that the term
"massage" was frequently, if not almost invariably, used
as a code word for sexual abuse, or at least sexual
activity, if the girl happened to be over the age of 18.
But in most cases at least, or in many cases depending
on exactly what universe you're looking at, these were
underage girls, under the age of consent in the State of
Florida, they were under the age of 18.
Sometimes as young as -- I think it went all
the way down to, gosh, I'm trying to remember now, I
think 13 or 14 was was the youngest age in the police
report.
Q. Is it your position that as of December 30th,
2014, you had a sufficient basis under the Federal Rules
of Procedure and applicable ethical rules to allege that
anyone who got a massage at Mr. Epstein's residence had
abused minors?
A. No.
Q. What -- back up now. With respect again to
other minors as of December 30th, 2014, had anyone --
had any young woman, other than -- we will put -- I'm
going to ask about Virginia Roberts separately.
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