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Ms. Giuffre has said there was a conspiracy involving all of

these individuals. They're all going to say no, there wasn't.

We'll have a trial on that and hear th vidence. But the

compatibility of interests is, that team is against

Ms. Giuffre. Those co-conspirators are all working together to

try to undercut the credibility of Ms. Giuffre. And of course

they're all hoping that she will lose this trial, which they

will then celebrate as a victory. Of course if Ms. Giuffre

wins the trial, they will all suffer a defeat because her

credibility in making these allegations will have been

established.

The final factor LiButti directs you to consider is

the role in the underlying aspects of the litigation, and again, it's hard to imagine. I won't say they are the most

important members of the conspiracy. Epstein is the most

important member of the conspiracy, but the next most

important, after Maxwell, who's the number two position, the

next most important conspirator is Kellen and Marcinkova. I've used the expression before, it's kind of playing Hamlet without

the ghost. We're going to be talking about a conspiracy

without the conspirators in the case. We are trying to bring

the conspirators here in front of the jury so that they can hear what the conspirators have to say when asked questions about what they were doing to Ms. Giuffre and what they were

doing to similarly situated young girls.

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

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