Latest / The Vault: The Epstein Files / The Expert Witness Report Of Bernard J. Jansen In Support Of Virginia Roberts (Part 2)

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The Expert Witness Report Of Bernard J. Jansen In Support Of Virginia Roberts (Part 2) · 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 right back in
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to that expert witness testimony that we were talking about
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in the last episode, So let's get back to it.
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Part six. Methodology sixteen. I was asked to determine the
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dissemination of articles containing the statements made against Miss Roberts seventeen.
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In forming my opinion, I utilized accepted web analytics and
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related methodologies in developing my assessment eighteen. To that end,
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I employed various publicly available online analytics services as well
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as some subscription based services in conducting my research, including Alexa,
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an online service that provides web traffic data and analysis,
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Compete an online service that provides web traffic data and analysis.
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Google Keyword Tool and online service that provides the number
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of searches for a given set of keywords in a
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given month on the Google search engine. Google Trends an
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online service that shows how often a particular term is
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relatively searched on the Google Search Engine in a given period.
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Similar web an online service that provides web traffic data
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and analysis. Spyfu an online service providing search data and analytics,
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including for both paid IE advertisements and organic IE, natural
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or algorithmic channels. W three snoop an online service that
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provides web traffic data and analysis nineteen. These tools offer
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a variety of data and analysis services, and they are
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frequently utilized by industry professionals in the search engine optimization,
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web analytics, and search engine marketing fields for market customer
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and competitive analysis. Furthermore, where possible, I did my own
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assessments as outlined below. In order to validate the data
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and analysis results Number twenty I utilize search engines, primarily Google,
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ending to assess the dissemination of articles containing the statements
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made against Miss Roberts twenty one. Whenever possible, I use
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multiple data sources, which is a data verification technique known
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as triangulation, where one uses multiple and disparate sources of
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analysis and then compare the results from the separate analysis.
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If the results are similar, it reinforces the conclusion that
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the overall data analysis is valid. Number twenty two. In
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all of my assessments, I have used the most conservative numbers,
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meaning that I use the smallest value In arriving at
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the dissemination of articles containing the statements made against Miss Roberts.
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If I had employed this conservative estimate, the number of
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potential dissemination of articles containing the statements made against Miss
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Roberts would be one hundred and two million, seven hundred
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and forty thousand, eight hundred and sixteen daily unique visitors
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number twenty four. My analysis is based on my experience, training, knowledge,
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and education is formed through the application of that experience, training, knowledge,
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and education in the principles of web data collection, web analytics,
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web search, search engines, websites, and related areas number seven.
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Dissemination of the statements made against Miss Roberts twenty five.
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My opinion is that the articles containing the statements made
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against Miss Roberts have been disseminated to at least one
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hundred and fifteen online media and other sites in one
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hundred and seventy eight separate stories or articles with a
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combine sixty six million, nine hundred and nine thousand, nine
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hundred and sixty five unique daily visitors twenty six. This
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is a conservative estimate, and it's more likely than not
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the statements have received wider dissemination due to the actors
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such as A. I used a set of online websites
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one hundred and fifteen to calculate the dissemination of the articles,
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and it's reasonable that I have not located all references
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to the statements made against Miss Roberts by the time
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of the submission of this report, so there may be
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more sites with articles containing the statements made against Miss
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Roberts that are not included in my calculations. B. My
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focus of analysis was the online dissemination of the statements
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made against Miss Roberts. Therefore I examined only online sources
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and not dissemination of the statements made against Miss Roberts
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via print or broadcast media. It is reasonable to assume
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that the statements made against Miss Roberts were disseminated via
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these other channels. See. I have not attempted to measure
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face to face dissemination of the statements made against Miss Roberts. Therefore,
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these sources of dissemination are not included in the account
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of Daily Unique Visits D. I did not have access
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to certain online sources where the statements against Miss Roberts
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may have been disseminated e g. Email messages, social media messages,
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articles behind firewalls, etc. Therefore, these sources are not included
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in the account of Daily Unique visitors. E. There may be
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sites that hosted articles containing the statements made against Miss
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Roberts where the articles have been removed. Therefore, I did
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not include these sites in my calculation of the unique
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daily visitors. F. There are sites where the visitor data
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is not accessible or where I couldnot reasonably check the
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number of visitors. In these cases, even though I had
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confirmed the site had posted one or more articles containing
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statements made against Miss Roberts, I did not include these
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sites in my calculation of the unique daily visitors. G.
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I did not consider the dissemination via social media platforms
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of articles containing the statements against Miss robert H. Many
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sites publish multiple articles on multiple days that contain or
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reference the statements made against Miss Roberts. However, I did
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not use these multiple articles from the same site with
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different publication dates in my calculations. In determining the number
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of Daily Unique visitors who have been exposed to the
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articles containing the statements made against Miss Roberts, I I
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did not include articles that link to one or more
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of the articles containing the statements made against Miss Roberts,
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unless the article directly referenced the statements made against Miss Roberts.
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I did not include it in my analysis. Jay. Finally,
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I did not include people who may have been searching
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and may have seen the statements made against Miss Roberts
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in the search results without needing to visit the actual
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articles posted on the websites. Number eight Methodology to determine
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the dissemination of the statements made against Miss Roberts twenty seven.
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I have been in that the statements made against Miss
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Roberts were originally contained in an email message from Ross
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GAO of Acuity Reputation, acting on behalf of Miss Maxwell,
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that was sent on January TEWOD twenty fifteen at eight
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thirty eight pm to based on the email addresses people
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at The Mail Online, The Independent, The Mirror, The Times
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and the BBC, the email message from mister gu contained
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the statements made against Miss Roberts. A screenshot of the
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email message is shown in Figure one twenty eight. Figure
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one email message from Ross Gal containing the statements made
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against Miss Roberts. Thirty Additionally, on January eighth, twenty fifteen,
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agents reportedly acting on behalf of Miss Maxwell made statements
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that the allegations against her were a web of lies
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and deceit which are similar to the statements made against
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Miss Roberts in the message from mister Goo thirty one. Similarly,
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on February first, twenty fifteen, agents reportedly acting on behalf
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of Miss Maxwell made statements that the allegations against her
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were a web of lies and deceit, which are similar
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to the statements made against Miss Roberts in the message
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from mister Gal thirty one. Similarly, on February first, twenty fifteen,
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like statements were quoted as these allegations are untrue and defamatory,
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which are similar to the statements made against Miss Roberts
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in the message from mister Gal thirty two. Based on
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my investigation and research, news stories, articles and postings containing
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direct reference to or quotes from the statements made against
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Miss Roberts appeared the same day, January two, twenty fifteen
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as the email from mister Go, with several news organizations
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and other sites publishing other articles containing direct reference to
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or quotes from the statements made against Miss Roberts in
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the immediate following days. News articles containing direct reference to
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or quotes of the statements made against Miss Roberts have
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continued to appear in news articles and other postings nearly
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up to the date that I submitted this report Number
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thirty three. A timeline of events relating to the dissemination
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of the statements made against Miss Roberts is shown in Fig.
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Two thirty four. Fig. Two Timeline of events relating to
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the dissemination of the statements made against Miss Roberts from
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January two, twenty fifteen onwards. Number thirty five concerning the
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procedure employed in determining the dissemination of the statements made
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against Miss Roberts. Nearly every major news site that I investigated,
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along with other specific news sites in the United States,
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the United Kingdom, Canada, and Australia, as well as other countries,
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have carried some aspects of the overall story related to
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Miss Roberts and door Maxwell or other parties that are
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involved thirty six. In fact, there are tens of dooulls
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and news articles and postings concerning the general story from
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news outlets worldwide, with combined potential viewership in the multimillions
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as searches on the major search engines such as Google
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and Bing's show thirty seven. However, I was not interested
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in news articles that just discussed the story in general.
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Or other aspects of the story. Also, I was not
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interested in those articles where Miss Maxwell or those acting
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on her behalf such as mister Gao, would just generally
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deny the allegations in the complaint. I was specifically interested
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in only those articles that reference directly or quoted the
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statements made against Miss Roberts in the January TEWOD twenty
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fifteen email message from mister Goo to Miss Maxwell's subsequent
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confirmation of the statements, or similar statements as those in
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the message from mister Gal. Naturally, this narrow focus is
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a smaller subset of news articles than are the articles
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addressing the overall story number thirty eight. To isolate these
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articles of interest, I generated a series of ten queries
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that specifically targeted news articles from the case that addressed
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the statements made against Miss Maxwell e g. Glenn Maxwell's
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obvious lies. To retrieve a set of articles that directly
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related to the statements made against Miss Roberts, I employed
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a modified snowball technique, starting with one seed query, adding
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and modifying terms until I was not receiving new results.
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I also located some articles via navigating from the set
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of retrieved articles thirty nine. I set the search rage
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down from January second, twenty fifteen onward, so articles prior
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to that date were not included in the search results.
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For each article used in my analysis, I also verified
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the date that the article was published to ensure it
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was published on or after January second, twenty fifteen, and
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that the articles directly referenced in some way the statements
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made against Miss Roberts forty An example of search engine
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results in response to one of those queries is shown
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in Fig. Three forty one. Figure three Google News search
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results for the search Glenn Maxwell's obvious lies with the
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date delimiter beginning on January two, twenty fifteen. Forty two.
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I then personally verified that each article by reviewing each
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article used in my analysis directly referenced in some way
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the statements made against Miss Roberts forty three, So articles
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relating to the overall story that did not mention Miss
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Maxwell's statements made against Miss Roberts were not included in
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the analysis. Articles relating to the overall story that referred
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to Miss Maxwell simply denying the charges were not included
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forty four. I also personally performed a site search of
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the top fifteen online media sites worldwide of articles related
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to the case, and I reviewed the results to identifi
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if any of these articles referred to the statements against
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Miss Roberts. I also did the same for many countries,
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specific news sites in the United States, United Kingdom, Canada,
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and Australia forty five. In the end, I had a
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set of one hundred and seventy eight online news and
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other articles from January twod twenty fifteen to the date
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that I filed the report that specifically referenced the statements
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made against Miss Roberts. To conduct my analysis, as outlined below,
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each of these one hundred and seventy eight online articles
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was posted online. The one hundred and seventy eight online
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articles were distributed among one hundred and fifteen unique domain
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websites i e. Some websites posted multiple articles that contained
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the statements made against Miss Roberts forty seven. As seen
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from the list of domains that have published articles or
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stories containing references to the statement made against Miss Roberts,
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many of these domains are those of major news organizations
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or sources, including AOL News, BBC, Hutington Boast, International, Business Time,
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Irish Times, MSN News, National Inquirer, New York Daily News,
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New Zealand Herald, Page six, Radar Online, Reuters, The Daily Beast,
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The Daily Mail, The Express, The Guardian, The Mirror, The Sun,
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The Telegraph, Yahoo News, etc. Forty eight. I then used
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a variety of web analytics, traffic services, and other sources
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to get the unique daily visitor traffic for each of
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these domains. I use multiple services when available to verify
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the unique daily visitor traffic for each of these domains,
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as the traffic services may use different techniques to arrive
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at their traffic numbers. Forty nine. In some cases conflicting
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unique daily visitor traffic numbers, I utilize the most conservative,
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ie smallest number fifty. In cases where I determined I
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cannot get unique daily visitor traffic numbers or the unique
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day daily visitor traffic was not reliable in my opinion,
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I did not include the unique daily visitor traffic numbers
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for that domain in the numbers. This usually occurred for
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the sites with a smaller number of daily visitors or
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sites with an extremely large number of daily visitors. Fifty one.
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Unique daily visitors measures as an industry standard web analytic
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metric for measuring people that visit a website in a
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given period such as a week, a month, as there
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are normal daily fluctuations. Fifty two Table I shows the
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unique visitors traffic for the listed domains that posted articles
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or stories referencing the statements made against Miss Roberts, and
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the associated unique daily visitor traffic for each of those domains,
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along with a number of articles containing the statements made
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against Miss Roberts posted on that site. All right, folks,
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we're going to wrap up this episode here and in
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the next episode we're gonna pick up where we left off.
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All of the information that goes with this episode can
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be found in the description box.