Latest / The Vault: The Epstein Files / Virginia Robert's Rejects Ghislaine Maxwell's Summary Judgement Push (Part 4) (6/9/26)

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Virginia Robert's Rejects Ghislaine Maxwell's Summary Judgement Push (Part 4) (6/9/26) · The Vault: The Epstein Files

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Speaker 1: What's up everyone, and welcome back to the Epstein Chronicles.
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In this episode, we're going to continue looking at Virginia
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Roberts response to Khlai Maxwell's motion for a summary Judgment
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number seven, The Black Book. Palm Beach police confiscated an
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extensive list of contacts with their phone numbers from defendant
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and Epstein's residents. Kallaie Maxwell maintained a contact list in
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an approximately one hundred page long hard copy which was
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openly available to other house employees. It consisted primarily of
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telephone numbers, addresses, or email addresses for various personal friends, associates, employees,
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or personal or business connections of Epstein or the defendant.
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Prior to being terminated by defendant, the Palm Beach House
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butler Alfredo Rodriguez printed a copy of this document and
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ultimately provided it to the FBI. This document reflects the
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new or as phone numbers of defendant Epstein, as well
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as staff phone numbers. Additionally, and importantly, there are several
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sections entitled massage alongside a geographical designation with names of
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females and corresponding telephone numbers. These numbers included those of
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underage females with no training in massage therapy including redacted,
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redacted and redacted identified during the criminal investigation of Epstein.
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This document is an authentic reflection of the people who
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are associated with Epstein, defendant and the management of their
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properties and the knowledge each had of the contents of
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the document. Number eight Sex Slave Amazon dot Com book
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receipt Detective Recarry authenticated an Amazon dot Com receipt that
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the Palm Beach Police collected from Jeffrey Epstein's trash. The
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books he ordered are titled one SM one oh one
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A Realistic introduction by Jay Wiseman, Number two slave Craft
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road Maps for Erotic Servitude Principles, Skills and Tools by
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Guy Baldwin. And three Training with Miss Abernathy, a workbook
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for Erotic Slaves and their Owners by Christian Abernathy. As
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shown below, this disturbing two thousand and five purchase corroborates
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Miss Roberts account of being sexually abused and exploited by
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defendant and Epstein, not to mention the dozens of underage
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girls in the Palm Beach police report. Additionally, defendant testified
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that she was not with Jeffrey Epstein in two thousand
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and five. In two thousand and six when he was
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ordering books on how to use sex slaves. However, record
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evidence contradicts that Testimony number nine Thailand folder with defendant's
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phone number. Defendant also was integral in arranging to have
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Virginia go to Thailand. While Epstein had paid for a
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massage therapy session in Thailand, there was a catch. Defendant
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told Virginia she had to meet young girls in Thailand
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and bring her back to the US for Epstein and defendant. Indeed,
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on the travel records and tickets, defendant gave two Virginia
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defendant road on the back the name of the girl
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of Virginia was supposed to meet, and she was also
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instructed to check in frequently with defendant, as it was
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further signified by the words call miss Maxwell nine one
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seven redacted on Virginia's travel documents. In this case, Virginia
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also produced the hard copy records from her hotel stay
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in Thailand paid for by Epstein. See McCauley's declaration at
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exhibit number one, number ten. It is undisputed fact that
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the FBI report and the Churchery emails referenced Miss Roberts
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accounts of sexual activity with Prince Andrew that she made
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in twenty eleven, contrary to the defendant's argument that Miss
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Roberts has never made such claims until twenty fourteen. Based
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on the FBI's interview of Miss Roberts in twenty eleven,
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they wrote a report reflecting Miss roberts claims concerning her
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sexual encounters with Prince Andrew. Additionally, twenty eleven correspondents with
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Sharon Churcher shows that Miss Roberts disclosed her sexual encounters
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with Prince Andrew, but Churcher had to check with the
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publisher's lawyers on how much can be published. From Sharon
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Churcher mail on Sunday to Virginia Roberts, Hi, there been
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up all night writing. Won't have an opinion from our
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lawyer on how much can be published until London wakes up.
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The lawyers wanted internal FBI documents, but I think the
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Justice Department letter is all you have from the Feds. Anyway,
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I can give you a call early afternoon, maybe have
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a late lunch. See McAuley declaration at Exhibit thirty four
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Roberts zero zero three six seven eight. Accordingly, there is
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documentary evidence that refutes defendants meritless argument that Miss Roberts
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did not allege she had sex with Prince Andrew until
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twenty fourteen. To the contrary, two sources, including the FBI,
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show Miss Roberts made these claims in twenty eleven. See
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defendant has not produced no documents whatsoever that tend to
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show that she did not procure underage girls for Jeffrey Epstein.
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Defendant has produced no documents that even tend to show
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that she did not procure underage girls for sex with Epstein,
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and no documents that tend to show that she did
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not participate in the abuse. Indeed, defendant refused to produce
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any documents dated prior to two thousand and nine, which
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includes the two thousand through two thousand and two period
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during which she abused Miss Roberts. Against this backdrop of
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an avalanche of evidence showing the defendant sexually trafficked Miss Roberts.
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Summary judgment on any of the issues advanced by defendant
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is in a p apropriate. While we discuss the particulars
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of the individual claim below, the larger picture is important too.
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Miss Roberts will prove that trial that Epstein and defendant
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sexually trafficked her. And yet, when Miss Roberts had the
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courage to come forward and expose what defendant had done
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to the world in a court pleading trying to hold
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Epstein accountable, defendant responded by calling her a liar in
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a press release intended for a worldwide publication. Such hainous
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conduct is not a mere opinion, but rather a defamation
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executed deliberately and with actual malice. The jury should hear
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all of the evidence and then render its verdict on
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Miss Roberts's complaint. Part three Legal Standard. Rule fifty six
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of the Federal Rules of Civil Procedure provides that emotion
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for some rejudgment may be granted only when there is
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no genuine issue as to any material fact, and that
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all moving parties is entitled to a judgment as a
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map of law. The Second Circuit has repeatedly held that
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all ambiguities and inferences to be drawn from the underlying
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facts should be resolved in favor of the party opposing
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the motion, and all doubts as to the existence of
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a genuine issue for trial should be resolved against the
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moving party. Swan Brewery Company Limited versus US Trust Company
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of New York eight thirty two f dot supp seven
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fourteen seven seventeen, sdn Y nineteen ninety three, Sweet Jay
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citing Brady Burst, Town of Colchester, eight sixty three, f
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dot two, D two five two ten, Second Circuit, nineteen
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eighty eight. In other words, in deciding a motion for
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some rejudgment, the court must construe the evidence in the
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light most favorable to the non moving party, and draw
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all reasonable inferences in the non moving parties favor in
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agent Orange product lab Littig five dot one seven f
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dot three d seventy six eighty seven, Second Circuit, two
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thousand and eight. Stern versus Cosby six forty five F
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dot su pp two d two fifty eight two sixty nine,
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SDNY two thousand and nine. Some rejudgment should be denied
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if the evidence is such that a reasonable jerry could
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return a verdict in favor of the non moving party.
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See net Jets Aviation Incorporated. Versus LHC LLC. Five thirty seven,
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f dot three, d one sixty eight, one seventy eight
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and seventy nine, Second Circuit, two thousand and eight, Part four.
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Legal argument. A defendant is liable for the publication of
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the defamatory statement and damages for its publication. Defendant's lead
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argument is that when she issued a press release attacking
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Miss Roberts to members of the media, she somehow was
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not responsible when the media quickly published her attacks. If accepted,
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this remarkable claim would eviscerate defamation law, as it would
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permit a defamer to send a defamatory statement to the
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media and then stand back and watch immune from liability when,
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as in this case, the defamatory statements are published around
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the world. This absurd position is not the law, particularly
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given that the defendant released the statement to the media
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asking them to police find attached and quotable statements on
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behalf of Glenn Maxwell. To make her claim seem plausible.
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Defend incites older cases, some dating back as far as
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nineteen oh six. This presents a distorted picture of the
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case law on these issues, as a leading authority on
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defamation explains. With regard to liability for republication by another
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of statement by defendant, two standards have evolved. The older
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one is that the person making the defamatory statements is
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liable for a republication only if it occurs with his
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or her express or implied authorization of consent the more
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modern formulation as responsibility for all republication that can reasonably
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be anticipated or that is the natural and probable consequence
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of the publication. Sack on defamation Section two dot seven
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dot two at two DASH one thirteen and two DASH
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one fourteen, fourth Edition, twenty sixteen. In this case, however,
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the nuances of the applicable legal standards make little difference,
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because defendants so clearly authorized, indeed desired, and did everything
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possible to obtain publication of her defamatory statements attacking Miss
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Roberts one. Under New York law, defendant is liable for
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the media's publication of her press release. Given the obvious
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purposes of defamation law, New York law unsurprisingly assigns liability
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to individuals for the media's publication of press releases. Indeed,
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New York appellate courts have repeatedly held that an individual
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is liable for media publishing that individual's defamatory press release.
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C Levy versus Smith, eighteen NYS dot three D four
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thirty eight four to thirty nine one thirty two a
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dot d dot three s D nine sixty one, nine
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sixty two, and nine sixty three, NYAD second Department, twenty fifteen. Generally,
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one who makes a defamatory statement is not responsible for
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its recommunication without his authority or request to another over
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whom he has no control. Here, however, the appellan intended
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and authorized the republication of the allegedly defamatory content of
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the press releases in the news articles National Puerto Rican
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Day Parade Incorporated versus Cost of Publications Incorporated, nine fourteen,
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nys DOT two D one twenty one, twenty three, seventy
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nine a dot d DOT three d D five ninety two,
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five ninety five NYAD one Department twenty ten, affirming the
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refusal to dismiss defamation counts against a defendant who submitted
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an open letter that was published in a newspaper, and
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that the defendant paid to have the open letter published,
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and finding that the defendant authorized the newspaper to recommunicate
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his statements. See also restatement second of Torts, Section five
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seventy six, nineteen seventy seven. The publication of a libel
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or slander is a legal cause of any special harm
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resulting from its repetition by a third person, if the
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repetition was authorized or intended by the original defamer, or
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the repetition was reasonably to be expected. Defendant deliberately sent
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her defamatory statement to major news media publishers for worldwide circulation.
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Because defendant wanted the public at large to believe Miss
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Roberts was lying about her abuse. Defendant even hired a
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public relations media specialist to ensure the media would publish
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her statement. Her efforts succeeded. Her public relations agent instructed
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dozens of media outlets to publish her quotable defamatory statements,
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and they did. Despite this deliberate campaign to widely publicize
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her defamatory statement, defendant now claims any responsibility for the
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media publishing her press release. If we understand Defendant's position correctly,
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because she somehow lacked control over what major newspapers and
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other media finally put in their stories, she escapes liability
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for defamation. This nonsensical position would let a defamer send
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a false defamatory letter to major media, and then, when
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they published the accusation, escape any liability. Such an argument
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is not only an affrontal logic, but is contrary to
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prevailing New York case law cited above. Perhaps even more important,
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in the context of the pending summary judgment motion, it
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would have required defendant to convince the jury that she
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did not authorize or intend for the major media to
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publish her press release. Obviously, the disputed facts on this
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point are legion and smary. Judgment is accordingly inappropriate. Even
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the cases defendant sites contradict her argument. She first cites
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Geraci versus Props, in which a defendant sent a letter
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to the Board of Fire Commissioners and years later a
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newspaper published the letter. The court held that the defendant
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was not liable for the belated publication made years later
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without his knowledge or participation idea three p. Forty. By contrast,
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defendant not only authorized the defamatory statement, but paid money
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to her publicists to convince media outlets to publish it promptly,
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actions taken with both her knowledge and consent. Defendant statements
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was thus not published without her authority or request as
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in Jerachi, but by her express authority already mbuyer express request.
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Defendant's publicist testimony and documents produced by defendants publicist unambiguously
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established that the media published her press release with Defendant's
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authority and buyer request. Question when you sent that email.
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Were you acting pursuant to Miss Maxwell's retention of your services? Answer? Yes,
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I was. Question the subject line does have FW, which
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to me indicates it's a forward. Do you know where
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the rest of this email chain is? Answer? My understanding
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of this is it was a holiday in the UK,
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but mister Barton was not necessarily accessible at some point
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in time, so this had to be sent to him
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originally by Miss Maxwell, and because he was unavailable, she
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forwarded it to me for immediate action. I therefore responded, Okay, Glane,
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I'll go with this. It is my understanding that this
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is the agreed statement. Because the subject of the second
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one is urgent, this is the statement, so I take
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that as an instruction to send it out as a
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positive command. This is the statement. Similarly, another case cited
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by defendant Davis versus Costa Gavrus involved a libel claim
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against a book author who wrote an account of the
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nineteen seventy two military coup in Chile. Years later. The
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plaintiff attempted to ascribe defamation liability to a third party
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publishing house decision to republish the book in paperback form,
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and a third party filmmaker who released a movie based
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on the book. The court held that a party who
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was innocent of all complicity in the publication of a
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libel cannot be held accountable, but that a deliberate decision
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to republish or active participation in implementing the republication resurrects
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the liability five eighty f. Dot supp. Ten eighty two,
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ten ninety four SDNY, nineteen eighty four. Here, defendant made
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a deliberate decision to publish or press release and actively
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participated in that process. At the very least, the jury
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must make a determination of whether the defendant was innocent
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of all complicity for a libelist statement contained in her
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press release. Finally, defendant sites Caradouman First Newsday Incorporated. Four
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sixteen and dot E dot two D five fifty seven,
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nineteen eighty which held that reporters of a series of
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articles on narcotics trade cannot be held personally liable for
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injuries arising from its subsequent republication in book form absent
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a showing that they approved or participated in some other
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manner in the activities of the third party republisher ID
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four sixteen and dot E dot two D at five
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point fifty nine and five sixty. Again, the injury could
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reasonably find that defendant both approved of and even participated
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in the media's publication of her press release. Indeed, it
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is hard to understand how any jury could find anything
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else was obviously active in influencing the media to publish
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her defamatory press release. She both approved of and pushed
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for the publication of the press release. Accordingly, she is
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liable for its publication. Therefore, disclaiming responsibility for the media's
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publication of a statement for which she hired a publicist
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for the purpose of influencing the media to publish that
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statement is contrary to both prevailing case law and the
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case is cited by the defendant. All right, folks, we're
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going to wrap up there. In the next episode, we'll
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pick up where we left off with the defendant is
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liable for the media's publication of the defamatory statement. All
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of the information that goes with this episode can be
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found in the description box.