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Ghislaine Maxwell's Undisputed Statement Of Facts Pursuant To Virginia's Allegations (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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  We're going to pick back up with Glan Maxwell's response
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  to Virginia Roberts response to Glan Maxwell's undisputed facts number twelve.
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  Undisputed fact number twelve. In the joint her motion, plaintiff
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  also alleged she was forced to have sex with the
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  Harvard professor Alan Dershowitz, model scout Jean Luke Brunel, and
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  many many other powerful men, including numerous prominent American politicians,
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  powerful business executives, foreign presidents, a well known prime minister,
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  and other world leaders. A reply, again, plaintiff offers no
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  evidence that these lurid details were included in the joint
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  her motion, as indeed they were, and thus the fact
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  that they were should be deemed admitted thirteen. Undisputed fact
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  number thirteen. Plaintiff said, after serving for four years as
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  a sex slave, she managed to escape to a foreign
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  country and hide out from Epstein and his co conspirators
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  for years. Reply, Plaintiff does not dispute that she made
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  the statement in her joint or motion, and it is
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  admitted Number fourteen. Undisputed fact number fourteen. Plaintiff suggested the
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  government was part of Epstein's conspiracy when it secretly negotiated
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  a non prosecution agreement with Epstein precluding federal prosecution of
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  Abstein and his co conspirators. The government secrecy plaintiff alleged
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  was motivated by its fear that plaintiff would raise powerful
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  objections to the agreement that would have shed tremendous public
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  light on Epstein and other powerful individuals. Reply. Plaintiff does
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  not contest the quoted contents of the joint or motion,
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  but rather offers argument regarding Plaintiff's purported belief. Plaintiff did
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  not submit an affidavit attesting to such belief, and therefore
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  no admissible evidence was cited or offered. The fact should
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  therefore be deemed admitted fifteen undisputed Fact Number fifteen. The
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  other Jane Doe, who joined plaintiff's motion, who alleged she
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  was sexually abused on many occasions by Epstein, was unable
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  to corroborate any of Plaintiff's allegations Ideas seven and eight.
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  Reply Plaintiff states the facts are untrue, but offers no
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  admissible evidence to support that statement. She has no avidavid
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  or other statement from the other Jane Doe, who was
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  represented by Plaintiff's council and therefore had the ability to
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  furnish such an Avidavid. Indeed, Plaintiff acknowledges that the other
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  Jane Doe does not know Miss Roberts. These facts must
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  be deemed admitted redacted, who is not the other Jane Doe,
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  is irrelevant to the undisputed fact asserted. She also offers
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  no corroboration of the same pattern of abuse, and in
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  fact does not remember any such facts as already briefed
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  see Document five sixty seven at twelve through fourteen sixteen
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  Undisputed Facts sixteen. Also, notably, in our multiple and lengthy
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  consensual interviews with Miss Churcher three years earlier, Plaintiff told
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  Miss Churcher of virtually none of the details she described
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  in the Jointerer motion. A reply Plaintiff's protestations, aside the
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  Churcher articles attached to Miss Churchers sworn Affidavid filed in
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  this case at document two sixteen and two sixteen one
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  through two sixteen and two eighteen failed to include the
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  vast majority of details included in Plaintiff's CVR Joinder motion
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  as any side by side comparison will reveal. Plaintiff's simple
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  facile responses is that she did reveal details in twenty
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  eleven consistent with those in the jointer motion. She offers
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  no admissible evidence of these details she revealed to Miss Churcher, instead,
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  citing to a heavily redacted interview she purportedly gave to
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  the FBI, not Miss Churcher. The purported FBI report in
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  itself is hearsay, not to mention, redacted and prepared years
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  after any supposed interview of plaintiff Callei Declaration Example thirty one.
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  Because plaintiff offers no admissible evidence to contradict the discrepancies
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  between the church Or articles and the joint Door motion,
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  these facts should be deemed admitted. Number seventeen undisputed Fact seventeen.
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  Miss Maxwell's response to Plaintiff's lurid accusations. The January twenty
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  fifteen statement, as plaintiff and her lawyers expected before District
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  Judge Mara in the CVRA action, could strike the lurid
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  details of Plaintiff's allegation in the joint Or motion. Members
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  of the media obtain copies of the motion. Example g
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  A reply plaintiff cites no country evidence and therefore the
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  fact should be deemed admitted eighteen undisputed Fact Number eighteen.
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  At mister Barden's direction, on January two, twenty fifteen, mister
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  Gal sent to numerous representatives of British media organizations an
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  email containing a quotable statement on behalf of Miss Maxwell.
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  The email was sent to more than six and probably
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  less than thirty media representatives. It was not sent to
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  non media representatives. A reply plaintiff disputes as blaine falsehood
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  without admissible evidence, that it was mister Barden who directed
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  that the January second emails be sent to media organizations.
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  She then goes on to quote the very section of
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  mister Gal's deposition in which he surmises but does not
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  know indicated by his statement, it was his understanding that
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  it was something that had been sent to Maxwell by Barden. Indeed,
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  mister Barden clears up this confusion in his declaration, in
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  which he unequivocally swore number ten. In liaison with mister
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  Gow and my client, on January second, twenty fifteen, I
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  prepared a further statement denying the allegations, and I instructed
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  mister Goo to transmit it via email to members of
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  the British media who had made inquiry about Plaintiff's allegations
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  about Miss Maxwell. Attached as Exhibit A one is an
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  email containing a true and correct copy of this statement.
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  The statement was issued on my authority, although it is
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  possible others suggested or contributed content. I prepared the vast
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  majority of the statement and ultimately approved and adopted all
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  of the statement as my work. Ten. Mister Goal surmises
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  as to how the statement was forwarded to him and
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  by whom does not controvert the sworn testimony of mister
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  Bardon himself. Again, without admissible evidence to the contrary, the
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  facts must be deemed admitted. With regard to the number
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  of media representatives to whom he sent the email, mister
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  Gal testified it was between six and thirty. His further
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  testimony offered by plaintiff that he spoke to over thirty
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  journalists does not contradict that statement. Nowhere does plaintiff offer
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  testimony that he read the statement to over thirty journalists. Instead,
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  mister Gal acknowledged it was very possible that he had
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  ever read the statement to press or media over the phone,
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  not that he read it to over thirty journalists. Plaintiff's
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  selective cutting and pasting undercuts her so called evidence that
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  the facts in paragraph eighteen are false and thus they
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  ought to be deemed admissible nineteen undisputed fact number nineteen.
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  Among the media representatives were Martin Robinson of The Daily Mail,
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  p Peachey of The Independent, Nick Summerland of The Mirror,
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  David Brown of The Times and Nick Always and Joe
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  Anne Pew of the BBC, and David Mercer of the
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  Press Association. These representatives were selected based on their request
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  after the jointer motion was filed for a response from
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  miss Maxwell to Plaintiff's allegations in the motion a reply.
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  While plaintiff decries the second sentence is false, her cited
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  evidence contradicts her conclusion. Mister Gal testified that anytime there
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  was an incoming query, it was either dealt with on
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  the telephone by referring them back to the two statements,
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  or someone would email them the statement, so no one
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  was left unanswered mcauleay Declaration example six. As his testimony
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  makes clear, mister Gow sent the statement to those journalists
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  who made inquiry. He did not send it to anyone
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  who did not based on the admissible evidence. This fact
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  remains undisputed Number twenty. Undisputed fact number twenty. The email
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  to the media members read please find detached a quotable
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  statement on behalf of Mis Maxwell. No further communication will
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  be provided by her on this matter. Thanks for your understanding,
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  Best Ross Jane Doe three is Virginia Roberts, so not
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  a new individual. The allegations made by Victoria Roberts against
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  Klain Maxwell are untrue. The original allegations are not new
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  and have been fully responded to and shown to be untrue.
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  Each time the story is retold, it changes with new
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  salacious details about public figures and world leaders. And now
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  it is alleged by miss Roberts that Alan Dershowitz is
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  involved in having sexual relations with her, which he denies.
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  Miss roberts claims are obvious lies and should be treated
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  as such and not publicized as news as they are defamatory.
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  Glenn Maxwell's original response to the lives and defamatory claims
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  remains the same. Maxwell strongly denies allegations of an unsavory
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  nature which have appeared in the British press and elsewhere,
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  and reserves her right to seek redress at the repetition
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  of such old defamatory claims. Reply Plaintiff does not dispute
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  the contents of the email, and therefore it should be
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  deemed admitted twenty one undisputed fact number twenty one. Mister Barden,
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  who prepared the January twenty fifteen statement, did not intend
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  it as a traditional press release solely to disseminate information
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  to the media, so he intentionally did not pass it
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  through a public relations firm such as mister Gal's firm
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  Acuity Reputation. Reply Plaintiff makes two responses. As to the
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  first sentence, she asserts, without evidentiary support, the court should
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  not consider the bardon declaration. This argument is frivolous for
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  the reasons given on pages eight, eleven, twelve, eighteen, nineteen
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  of reply brief in support of motion for some rey judgment.
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  It is a declaration provided by an attorney with knowledge
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  of the facts mister Barden disclosed by defendant in a
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  rule twenty six witnesses whom Plaintiff chose not to depose.
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  As to the second sentence, Plaintiff offers two pieces of evidence,
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  which she argues disputes the facts in question. They do
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  not that mister Gal forwarded this statement prepared by mister
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  Barden to the media is not disputed. Rather, as mister
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  Barden asserted in his declaration and Plaintiff failed to cite
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  contradictory evidence, he was the one who prepared the vast
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  majority of the statement and instructed mister Goll to transmit
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  it via email to members of the British media. He
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  likewise averse that he did not intend the January twenty
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  fifteen statement as a traditional press release solely to disseminate
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  information to the media. This is why I intentionally did
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  not request that mister Gow or any other public relations
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  specialists prepare or participate in preparing the statement. Plaintiff fails
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  to contradict mister Barden' sworn statement undisputed Fact number twenty two.
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  The January twenty fifteen statement served two purposes. First, mister
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  Bardon intended that it mitigate the harm to Miss Maxwell's
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  reputation from the press republication of Plaintiff's false allegations. He
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  believed these ends could be accomplished by suggesting to the
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  media that, among other things, they should subject plaintiff's allegations
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  to inquiry and scrutiny. For example, he noted in the
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  statement that Plaintiff's allegations change dramatically over time, suggesting that
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  their obvious lies and therefore should not be publicized as news. Reply,
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  this paragraph, eliciting mister Barden's intent, is uncontroverted by plaintiff.
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  She fails to cite any contradictory admissible evidence, instead making
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  legal arguments. Her arguments are not admissible evidence e g.
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  It is her statement, and she directed that it be
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  sent to the media in public lacks any citation to
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  record evidence. Plaintiff's list of evidence, she contends corroborates. Plaintiff's
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  claims should be ignored as they do not pertain to
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  mister Barden's purposes. In drafting the January second statement, all right, folks,
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  we're going to wrap up right here, and in the
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  next episode we'll pick up where we left off. All
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  of the information that goes with this episode can be
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  found in the description box.