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Ghislaine Maxwell's Undisputed Statement Of Facts Pursuant To Virginia's Allegations (Part 1) · 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 dive into some more
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court documents and we're going to start taking a look
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at Laine Maxwell's reply to Virginia Roberts disputing her soul
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called undisputed facts. So let's get busy. Case number fifteen
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DASH CV DASH zero seven four three three DASH RWs
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Virginia Roberts versus Glaiinne Maxwell. The defendants replied a plaintiff
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statement of contested facts and Plaintiff's undisputed facts pursuing to
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Local Civil Rule fifty six dot one. Pursuing to Rule
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fifty six point one of the local Civil Rules of
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this Court, Dependent Gallain Maxwell submits this reply to a
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plaintiff Statement of contested Facts and Plaintiff's undisputed facts Response
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Document five eighty six DASH one Introduction. Plaintiff's response fails
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under both the federal rules of evidence and the local
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civil rules of procedures. First, plaintiff largely failed to provide
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any citation to evidence which would be admissible to challenge
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defendant statement of material undisputed facts, and therefore miss Maxwell's
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undisputed facts should be deemed admitted. Second, rather than set
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forth additional material facts as to which it is contended
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that there exists a genuine issue to be tried Local
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Civil Rule fifty six Dot one B, Plaintiff instead set
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forth her own purportedly undisputed facts. Because plaintiff did not
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cross move for some rejudgment, her supposedly undisputed facts are
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not permitted by the rules and should be stricken Section one.
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Miss Maxwell's reply in supportive statement of undisputed facts one
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undisputed fact number one. In early twenty eleven, plaintiff, in
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two British tabloid interviews, made numerous false and defamatory allegations
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against Miss Maxwell. In the articles, plaintiff made no direct
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allegations that missus Maxwell was involved in any improper conduct
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with Jeffrey Epstein, who had pleaded guilty in two thousand
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and seven to procuring a minor for prostitution. Nonetheless, plaintiff
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suggested that miss Maxwell work with Epstein and may have
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known about the crime for which he was convicted Examples
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A and B. Reply Plaintiff cites no admissible evidence to
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contest these undisputed facts. McAuley Example thirty four. In an
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email from Sharon Churchyard, a plaintiff. It is Miss Churcher's
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hearsay and therefore inadmissible in any event. It does not
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speak to the contents of Plaintiff's interviews with Churcher. McAuley declaration.
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Example thirty one is an FBI interview, also in admissible hearsay,
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which again does not describe Plaintiff's interviews in news articles.
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In the absence of contrary evidence, undisputed fact one should
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be deemed admitted. Two undisputed fact number two. In the articles,
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plaintiff alleged she had sex with Prince Andrew, a well
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known businessman, a world renowned scientist, a respected liberal politician,
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and a foreign head of state. Examples A through B
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at five a reply. Plaintiff does not contest these facts,
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and they therefore should be deemed admitted. Three undisputed fact three.
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In response to the allegation, Miss Maxwell's British attorney, working
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with mister Gow, issued a statement on March ninth, twenty eleven,
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denying the various allegations about Miss Maxwell that have appeared
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recently in the media. These allegations are entirely false. Example
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C A reply Plaintiff denies that mister Barden issued a
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statement but offers no admissible evidence to refute this point. Further,
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she acknowledged that the statement was issued by Devonshire solicitors
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mister Barden's law firm four undisputed fact four. The statement
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read and full, London, March tenth, twenty eleven. Gallaiine Maxwell
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denies the various allegations about her that have appeared recently
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in the media. These allegations are entirely false. It is
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unacceptable that letters sent by Miss Maxwell's legal representatives to
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certain newspapers pointing out the truth and asking for the
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allegations to be withdrawn have simply been ignored. In the circumstances,
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Miss Maxwell is now proceeding to take legal action against
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those newspapers. I understand that newspapers need to sell copies.
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It is well known that certain newspapers live by the
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adage why let truth get in the way of a
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good story. However, the allegations made against me are abhorrent
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and are entirely untrue, and I ask that they stop,
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said Glainne Maxwell. A number of newspapers have shown a
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complete lack of accuracy in their reporting of this story,
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and a failure to carry out the most elementary investigation
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or any real due diligence. I am now taking action
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to clear my name, she said a reply, Plaintiff does
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not dispute the contents of the twenty eleven statement, and
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therefore it should be deemed admitted five undisputed fact number
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five Plaintiff's gratuitous and lurid accusations. In an unrelated action.
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In two thousand and eight, to alleged victims of Epstein
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brought an action under the Crime Victim's Rights Act against
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the United States Government purporting to challenge Epstein's plea agreement.
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They alleged that the government violated their CVR rights by
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entering into an agreement example d at two. A reply
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Plaintiff stipulates to the facts contained in paragraph five, and
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therefore they should be deemed admitted number six undisputed fact
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number six. Seven years later, on December thirtieth, twenty fourteen,
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Miss Roberts moved to join the CVR action, claiming she
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too had her CVR rights violated by the government. On
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January first, twenty fifteen, Miss Roberts filed the corrected joinder
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motion example d at one to nine. Reply plaintiff agreed
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to this paragraph seven Undisputed Fact number seven. The issue
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presented in her joint her motion was narrow whether she
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should be permitted to join the CVRA action as a
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party under Federal Rule of Civil Procedure twenty one, specifically
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whether she was a known victim of mister Epstein and
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the government owed them CVRA duties. Yet, the bulk of
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emotion consists of copious factual details that plaintiff and her
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co movement would prove if allowed to join. Miss Roberts
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gratuitously included provocative and lurid details of her alleged sexual
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activities as an alleged victim of sexual trafficking. A reply,
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plaintiff does not dispute that Judge Marra made the findings
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detailed in Undisputed Fact seven. Further, she admits that the
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government refused to stipulate that she had been sexually abused
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by Jeffrey Epstein and his co conspirators, including co conspirator
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Alan Dershowitz, which would make her a victim of a
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broad set trafficking conspiracy. Although she now admits there were
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other reasons for inclusion of such lurid details, those reasons
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were rejected by Judge Mara, as she does not offer
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any admissible evidence to contradict the findings made by Judge Marra.
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This fact, specifically, Judge Mara's findings should be deemed admitted.
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In any event, we request under Federal rule evid. Two
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one c two that the Court take judicial notice of
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the contents of Judge Mara's ruling and disorder number eight
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undisputed fact number eight. At the time they filed the motion,
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Miss Roberts and her lawyers knew that the media had
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been following the Epstein criminal case and the CVRA action.
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While they deliberately filed the motion without disclosing Miss Roberts's name,
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claiming the need for privacy and secrecy, they made no
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attempt to file the motion under seal. Quite the contrary,
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they filed the motion publicly example d at one and one.
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A reply. Plaintiff offers no admissible evidence to refute these facts,
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and they therefore should be deemed admitted. Specifically, she does
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not offer any evidence to dispute that she knew the
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media had been following Epstein and the CVRA action, nor
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does she dispute that her attorneys made no attempt to
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file the motion under seal rather filing it publicly. The
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facts are thus admitted number nine undisputed Fact number nine.
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As the District Court noted in ruling on the joint
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or motion, miss Roberts names several individuals, and she offers
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details about the type of sex acts performed and where
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they took place. The Court ruled that these lurried details
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are unnecessary. The factual details regarding whom and where the
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jane those engaged in sexual activities are immaterial and impertinent,
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especially considering that these details involved non parties who were
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not related to the respond in government. Accordingly, these unnecessary
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details shall be stricken struck all of Miss Roberts's factual
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allegations relating to her alleged sexual activities and her allegations
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of misconduct by non parties. The Court said the striking
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of the lurid details was a sanction for Miss Roberts
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in proper inclusion of them in the motion. A reply
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plaintiff offers no admissible evidence to refute these facts, and
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they therefore should be deemed admitted. See Reply to Undisputed
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Fact seven, Supra. In any event, we request under Federal
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rule of evidence two one c two, that the Court
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take judicial notice of the contents of Judge Marra's ruling
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and disorder number ten undisputed Fact number ten. The District
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Court found not only that the lurid details were unnecessary,
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but also that the entire joinder motion was entirely unnecessary.
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Miss Roberts and her lawyers knew the motion, with all
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its lurid details was unnecessary because the motion itself recognized
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that she would be able to participate as a fact
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witness to achieve the same result she sought as a party.
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The Court denied Plaintiff's joined or motion id at seven
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through ten number eleven undisputed Fact number eleven. One of
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the non parties Miss Roberts named repeatedly in the joinder
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motion was Miss Maxwell. According to the lurid details of
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Miss Roberts included in the motion, Miss Maxwell personally was
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involved in a sexual abuse and a sex trafficking scheme
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created by Epstein. Miss Maxwell approached plaintiff in nineteen ninety nine,
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when plaintiff was fifteen years old, to a recruiter into
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the scheme. Miss Maxwell was one of the main women
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Epstein used to procure underage girls for sexual activities. Miss
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Maxwell was a primary co conspirator with Epstein in his scheme.
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She persuaded plaintiff to go to Ebstein's mansion in a
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fashion very similar to the manner in which Epstein and
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his other co conspirators coerced dozens of other children at
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the mansion. When plaintiff began to giving Epstein a massage,
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he and Miss Maxwell turned it into a sexual encounter. Epstein,
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with the assistance of Miss Maxwell, converted plaintiff into a
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sex slave. Plaintiff was a sex slave from about nineteen
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ninety nine through two thousand and two. Miss Maxwell also
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was a co conspirator in Epstein's sexual abuse. Miss Maxwell
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appreciated the immunity she acquired under Epstein's plea agreement because
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the immunity protected her from prosecution from the crimes she committed.
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In Florida, Miss Maxwell participated in the sexual abuse of
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plaintiff and others. Miss Maxwell took numerous sexually explicit pictures
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of underage girls involved in sexual activities, including the plaintiff.
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She shared those photos with Epstein as part of her
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role in Epstein's sexual abuse ring. Miss Maxwell connected Epstein
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with powerful individuals so that Epstein could traffick Plaintiff to
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these persons. Plaintiff was forced to have sexual relations with
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Prince Andrew in Miss Maxwell's apartment in London. Miss Maxwell
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fillitated Plaintiff sex with Prince Andrew by acting as a
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madam for Epstein. Miss Maxwell assisted in internationally trafficking Plaintiff
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and numerous other young girls for sexual purposes. Plaintiff was
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forced to watch Epstein, Miss Maxwell, and others engage in
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illegal sexual acts with dozens of underage girls. Reply, Plaintiff
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offers no admissible evidence to refute the facts actually stated
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in the paragraph ie the lurid details as coined by
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Judge Marra were included in her CVRA jointerer motion. Plaintiff
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claims to offer admissible evidence to corroborate the statements she
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made in the joint motion. Setting aside for the moment
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that most of the cited documents are inadmissible hearsay. As
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addressed later, such evidence should be disregarded because none of
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the offered documents speak to fact that these lurid details
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were actually included in the jointer motion, as a simple
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reading of example D reveals, because plaintiff does not refute
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that point. The fact that the details were in the
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joinder motion should be deemed admitted. In any event, we
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request under Federal Rules of Evidence Tool one c two
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that the Court take judicial notice of the contents of
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plaintiffs CVR. Joinder Motion. All right, folks, we're gonna wrap
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up right there, and in the next episode we'll pick
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up where we left off.