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Ghislaine Maxwell's Undisputed Statement Of Facts Pursuant To Virginia's Allegations (Part 5) · 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 taking a look
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at Klaine Maxwell's response to Virginia's response about the undisputed facts.
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Forty five Plaintiff and Figeroa shared a vehicle during two
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thousand and one and two thousand and two. Plaintiff in
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Figaroa shared a nineteen ninety three Pontiac in two thousand
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and one and two thousand and two. Plaintiff freely traveled
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around the Palm Beach area in that vehicle. In August
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of two thousand and two, Plaintiff acquired a Dodge Dakota
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pickup truck from her father example p At sixty seven
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and sixty eight. Figaroa used that vehicle in a series
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of crimes before and after plaintiff left for Thailand. Reply again,
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the response has nothing to do with the fact stated,
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as plaintiff concedes, she and mister Figaroa had one car
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that they both used. In fact, they traveled to and
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from school together example p At sixty seven and sixty eight.
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She does not dispute that she traveled freely around the
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Palm Beach area in that vehicle or that her car
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was used in a series of thefts while she was
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in Thailand. All that should be deemed admitted forty six
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undisputed fact forty six. Plaintiff held a number of jobs
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in two thousand and one and two thousand and two.
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During two thousand and one and two thousand and two,
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plaintiff was gainfully employed at several jobs. She worked as
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a waitress at Menino's Restaurant, at TGIF's Friday's Restaurant, and
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at Roadhouse Grill. She also was employed at Courtyard Animal Hospital.
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Reply plaintiff admits all of the facts that fourth above,
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aside from the use of the word gainfully, they should
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be deemed admitted forty seven. In September two thousand and two,
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plaintiff traveled to Thailand to receive massage training, and while
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there met her future husband and a lope with them.
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Plaintiff traveled to Thailand and said September of two thousand
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and two to receive formal training as a massuse Figaroa
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drove her to the airport. While there, she initially contacted
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Figaroa frequently, incurring a phone bill of four thousand dollars.
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She met her husband while in Thailand and decided to
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marry him. She thereafter ceased all contact with Figaroa from
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October two thousand and two until two days before mister
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Figaroa's deposition in this matter in May of twenty sixteen.
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Reply again, Plaintiff does not refute the facts set forth.
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She simply offers her own interpretation of those facts. In
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the absence of any country evidence, they should be deemed
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admitted forty eight undisputed Fact Number forty eight Detective Ricarrey's
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investigation of Epstein fel to uncover any evidence that Miss
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Maxwell was involved in sexual abuse of miners, sexual trafficking,
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or production or possession of child pornography. Joseph Riccari served
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as the lead detective from the Palm Beach Place Police
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Department charged with investigating Jeffrey Epstein example GG at ten.
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That investigation commenced in two thousand and five. Riccari worked
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only on the Epstein case for an entire year. He
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reviewed previous officer's reports and interviews, conducted numerous interviews of
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witnesses and alleged victims. Himself, reviewed surveillance footage of the
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Epstein home, participated in and had knowledge of the search
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warrant executed on the Epstein home and testified regarding the
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case before the Florida State grand jury against Epstein. Detective
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Rickerrey's investigation revealed that not one of the alleged Epstein
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victims ever mentioned Miss Maxwell's name, and she was never
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considered a suspect by the government. None of Epstein's alleged
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victims said they had seen Miss Maxwell at Epstein's house,
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nor said they had been recruited by her, nor paid
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any money buyer, nor told what to wear or how
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to act buyer. Indeed, none of Epstein's alleged victims ever
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reported to the government they had ever met or spoken
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to Miss Maxwell. Maxwell was not seen coming or going
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from the house during the law enforcement surveillance of Epstein's home.
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The arrest warrant did not mention Miss Maxwell, and her
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name was never mentioned before the grand jury. No property
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belonging to Maxwell, including sex toys or child pornography, was
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seized from Epstein's home during execution of the search warrant.
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IDEA two fifty seven, Detective Roccary, when asked to describe
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everything that you believe you know about Glinne Maxwell's sexual
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trafficking conduct, replied, I don't idea two seventy eight. He
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confirmed that he had no knowledge about Miss Maxwell's sexually
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trafficking anybody. Detective Roccary also has no knowledge of Plaintiff's
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conduct that is subject of this lawsuit. Reply, Plaintiff offers
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several misleading contrary facts, none of which actually address the
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facts presented herein namely, whether missis Maxwell was ever mentioned
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by any of Epstein's alleged victims, whether she was the
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target of their investigation, and whether any of her property
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was seized from Epstein's home. Plaintiff cites to numerous inadmissible
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pieces of evidence on facts other than those. Mister Rodriguez,
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a convicted felon for obstructing justice related to the Epstein case,
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is dead and his deposition testimony is the subject of
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emotion in le mean because Miss Maxwell has never had
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the opportunity to cross examine them Document five point sixty
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seven at fourteen. Miss Rebello, likewise, is not a witness
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who has been deposed in this case, and therefore her
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testimony is not admissible against Miss Maxwell. The message bads
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are not authenticated by anyone, as will be the subject
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of a forthcoming motion in le mean and there is
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not one shred of evidence that any child pornography, as
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opposed to a topless photo of a very adult Miss
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Maxwell wherever found in Epstein's home. The fact should be
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deemed admitted, as those proffered by defendant are based on
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admissible evidence. Number forty nine undisputed fact forty nine No
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nude photograph of plaintiff was displayed in Epstein's home. Epstein's housekeeper,
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Juana Lessi, never saw any photographs of Virginia Roberts in
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mister Epstein's house. Detective Raccari entered Epstein's home in two
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thousand and two to install security cameras to catch a
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thief and did not observe any child pornography within the home,
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including on Epstein's desk in his office. Reply, Plaintiff offered
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no evidence that a nude photograph of her was displayed
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in Epstein's home. All of the testimony she submits has
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nothing to do with the nude photograph of herself. The
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fact should be deemed admitted. Fifty undisputed fact fifty. Plaintiff
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intentionally destroyed her journal and dream journal regarding her memories
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of this case. In twenty eleven, while represented by Council,
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Plaintiff after a journal describing individuals to whom she claimed
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she was sexually trafficked, as well as her memories and
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thoughts about her experiences with Epstein. In twenty thirteen, she
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and her husband created a bonfire in her backyard in
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Florida and burned the journal, together with other documents in
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her possession. Plaintiff also kept a dream journal regarding her
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thoughts and memories that she possessed in January twenty sixteen.
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To date, plaintiff cannot locate the dream journal. Reply Plaintiff
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offers no contrary admissible evidence regarding her destruction of her journal,
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and it should be deemed admitted. Fifty one undisputed fact
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Number fifty one. Plaintiff publicly peddled her story Beginning in
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two thousand and one. Plaintiff granted journalist Sharon Churchier extensive
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interviews that resulted in seven widely distributed articles. From March
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twenty eleven through January twenty fifteen, Churcher regularly commute municated
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with plaintiff under attorneys or other agents. From early twenty
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eleven to the present day. Plaintiff received approximately one hundred
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and sixty thousand dollars for her stories and pictures that
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were published by many news organizations. Reply, Plaintiff offers no
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evidence to contradict the facts asserted, and they should therefore
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be deemed admitted. Plaintiff's unsupported spin of those facts should
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be stricken undisputed. Fact fifty two Plaintiff drafted a one
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hundred and forty four page purportedly autobiographical book manuscript in
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twenty eleven, which she actively sought to publish. In twenty eleven,
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contemporaneous with her Churcher interviews, Plaintiff drafted a book manuscript
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which purported to document Plaintiff's experiences as a teenager in Florida,
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including her interactions with Epstein and Maxwell. Plaintiff communicated with
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literary agents, ghostwriters, and potential independent blas publishers in an
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effort to get her book published. She generated marketing materials
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and circulated those, along with book chapters, to numerous individuals
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associated with publishing and the media. Reply Plaintiff sites in
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admissible evidence and attorney argument in contradiction of these facts.
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They should be ignored. The victim notification letter is inadmissible
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hearsay the psychologist's record likewise or inadmissible hearsay. The FBI
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interview is inadmissible hearsay. Plaintiff's council then flatly misrepresents to
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the court her own client's characterizations of the book manuscript,
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calling it a fictionalized account. Plaintiff, contradicting her council, testified
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that the book manuscript is ninety nine percent true. Question
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is there anything Well, first of all, did you author
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the entire manuscript? Answer? Yes, I did. Question did anyone
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else author a part of that manuscript? Answer? Do you
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mean did anyone else write this with me? Question? Right? Answer? No, question,
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that's all you're writing. Answer this is my writing. Question, okay,
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to the best of your recollection as you sit here today.
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Is there anything in that manuscript about Glainne Maxwell that
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is untrue? Answer? I don't believe so. Like I said,
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there is a lot of stuff that I actually left
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out of here. Question mm hmm. Answer, so there is
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a lot more information I could put in there, but
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as far as Galainne Maxwell goes, I would say that
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there is ninety nine percent of it would be the
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correct knowledge. Question all right, is there anything that you
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and I understand that you're doing this from memory. Is
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there anything that you recall as you're sitting here today
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about Glayne Maxwell that is contained in the manuscript that
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is not true? Answer? You know, I haven't read this
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in a very long time. I don't believe that there's
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anything in there about Glayne Maxwell that is not true.
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Plaintiff clearly now would like to spin the book manuscript
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as fictionalized, because she is well aware that the facts
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presented by her in that manuscript are contradicted by many
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other documentary and testimonial records. Yet she offers no admissible
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evidence that plaintiff intended the manuscript to be fictional. Citations
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the social scientists, who have not testified in this case
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and whose work has not been cited by any expert
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in this case is wholly improper and should be stricken.
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Number fifty three. Plaintiff publicly filed Lurid cvra Pleadings, initiated
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a media frenzy and generated highly publicized litigation between her
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lawyers and Alan Dershowitz. On December thirtieth, twenty fourteen, Plaintiff,
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through Council, publicly filed a joined her motion that contained
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her Lurid allegations about miss Maxwell and many others, including
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Alan Dershowitz, Prince Andrew, and Jean Luke Brunel. The joint
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her motion was followed by a corrected motion and two
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further declarations in January and February twenty fifteen, which repeated
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many of Plaintiff's climas. These CVRA pleadings generated a media
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maelstrom and spawned highly publicized litigation between plaintiff's lawyers Edwards
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En Cassel, and Alan Dershowitz. After plaintiff publicly alleged mister
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Dershowitz of sexual misconduct, mister Dershowitz vigorously defended himself in
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the media. He called plaintiff a liar and accused her
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lawyers of unethical conduct. In response, attorneys Edwards and Cassel
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sued Dershowitz, who counterclaimed. This litigation in turn caused additional
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media attention by national and international media organizations. Reply, plaintiff
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offers no contrary facts and so they should be deemed admitted.
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Number fifty four undisputed Fact fifty four Plaintiff formed non
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profit victims refused silence to attract publicity and speak out
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on a public controversy. In twenty fifteen, Plaintiff, with the
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assistance of the same council, formed a nonprofit organization Victims
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Refused len According to plaintiff, the purpose of the organization
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is to promote Plaintiff's profess cause against sex slavery. The
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stated goal of her organization is to help survivors surmount
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the shame, silence, and intimidation typically experienced by victims of
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sexual abuse. Plaintiff's attempts to promote Victims Refuse Silence at
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every opportunity. For example, plaintiff participated in an interview in
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New York with ABC to promote the charity and to
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get our mission out to the public. Reply Plaintiff offers
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no contrary evidence and the facts should be deemed admitted. Two,
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the court should strike Plaintiff's statement of undisputed facts. The
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summary judgment procedure is well established. When the summary judgment
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non movement bears the burden of proof at trial, as
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in the case at Bar, the movement may show a
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prima facie entitlement for summary judgment in one of two ways.
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The movement may point to evidence that negates the non
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movement's claims, or two, the movement may identify those portions
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of its opponent's evidence that demonstrate the absence of a
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genuine issue of material fact salahudin versus Gored four sixty
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seven f Dot three D two sixty three, two seventy
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two and seventy three Second Circuit, two thousand and six.
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If the movement makes the showing in either manner, the
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burden shifts to the non movement to identify record evidence
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creating a genuine issue of material fact. Local Civil Rule
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fifty six dot one A carries out this summary judgment
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procedure by requiring the summary judgment movement to set forth
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material facts as to which she contends that there is
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no genuine issue to be tried. Subsection B of the
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rule requires the party opposing some rejudgment to set forth
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the statement of additional material facts as to which it
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is contended that there exists a genuine issue to be tried.
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Miss Maxwell has moved for some rejudgment, plaintiff has not
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as movement. Miss Maxwell is required under Local Civil Rule
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fifty six to one to enumerate the facts she is
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asserting as undisputed as the party opposing some rejudgment. Plaintiff
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is permitted if she can to introduce admissible evidence creating
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a genuine issue of material fact see fed R. Siev
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fifty six C and one. Plaintiff is confused. Plaintiff believes she,
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the party opposing some rejudgment, must enumerate facts she is
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asserting as undisputed, and so she has submitted her own
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rule fifty six to one statement of undisputed facts that
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gets a sumary judgment procedure exactly backwards. Plaintiff's undisputed facts
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are irrelevant. Plaintiff cannot avoid some rejudgment by proposing undisputed facts.
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She may only do so by creating a genuine issue
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of material fact. As to Miss Maxwell's statement of undisputed facts, Accordingly,
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this Court should strike Plaintiff's statement of under disputed facts.
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Although Miss Maxwell, as a summary judgment movement, has no
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duty to respond to plaintiffs alleged undisputed facts, we hasten
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to add that Miss Maxwell in fact opposes and disputes
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most of Plaintiff's alleged undisputed facts. For example, Defendant's undisputed
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fact forty includes the statement Miss Roberts is hired as
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a seasonal SPA attendant to work at the mar Alago
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Club in the fall of two thousand, after she had
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turned seventeen. Yet Plaintiffs sets forth in our own undisputed
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fact fifty eight that Virginia got a job at Mar
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A Lago in two thousand, either months before or just
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after her seventeenth birthday. Plaintiff has done nothing more than
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set forth her dispute with defendant undisputed fact forty as
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her own undisputed fact. It makes no sense See also
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Plaintiff's unisputed fact sixty three. The other alleged undisputed facts
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are simply Plaintiff's assertion of her deposition testimony and hearsay
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of her statements to other witnesses. Coach does undisputed facts.
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Miss Maxwell strenuously disputes almost all of the alleged undisputed facts,
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claiming that she engaged in any sort of sexual acts, misconduct,
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or communication with plaintiff or others. Indeed, over the course
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of two days and thirteen hours of deposition, Miss Maxwell
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disputed all such allegations. Because none of Plaintiff's undisputed facts
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have anything to do with the issues raised by Defendant's
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motion for some rejudgment, Miss Maxwell moves to strike plaintiff's
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statement of undisputed Facts conclusion for the foregoing reasons. Miss
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Maxwell requests that the Court deem her undisputed facts admitted,
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and that the Court strikes plaintiff statement of undisputed facts.
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This was signed on February tenth of twenty seventeen, and
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it was signed by Laura Meninger. All Right, folks, that's
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going to do it for this one. All of the
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information that goes with this episode can be found in
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the description box.