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Ghislaine Maxwell's Undisputed Statement Of Facts Pursuant To Virginia's Allegations (Part 3) · 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 diving right back into the court
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  documents and we're going to continue taking a look Glad
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  Maxwell's reply to Virginia Robert's Statement of contested Facts and
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  the Plaintiff's undisputed Facts Number twenty one. Undisputed Fact Number
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  twenty one. Mister Barden, who prepared the January twenty fifteen statement,
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  did not intend it as a traditional press release solely
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  to disseminate information to the media, so he intentionally did
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  not pass it through the public relations firm, such as
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  mister Gal's firm Acuity Reputation reply Plaintiff makes two responses
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  as to the first sentence. She asserts, without evidentiary support,
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  that the court should not consider the Barden declaration. This
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  argument is frivolous for the reasons given on page eight, eleven, twelve, eighteen,
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  and nineteen of the reply brief in support of motion
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  for a summary judgment. It is a declaration provided by
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  an attorney with knowledge of the facts mister Barden disclosed
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  by the defendant in her rule. Twenty six witnesses whom
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  Plaintiff chose not to depose As to the second sentence,
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  Plaintiff offers two pieces of evidence which she argues disputes
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  the facts in question. They do not that mister Gall
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  forwarded the statement prepared by mister Barton to the media
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  is not disputed. Rather, as mister Barden asserted in his
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  declaration and Plaintiff felt to cite contradictory evidence, he was
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  the one who prepared the vast majority of the statement
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  and instructed mister Gall to transmit it via email to
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  members of the British media example at ten. He likewise
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  avers that he did not intend the January twenty fifteen
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  statement as a traditional press release solely to disseminate information
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  to the media, and this is why I intentionally did
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  not request that mister Gal or any other public relations
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  specialist prepare or or participate in preparing the statement. Plaintiff
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  fails to contradict mister Barden's Swarren statement number twenty two
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  undisputed fact number twenty two. The January twenty fifteen statement
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  served two purposes. First, mister Bardon intended that it mitigate
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  the harm to Miss Maxwell's reputation from the press's republication
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  of Plaintiff's false allegations. He believed these ends could be
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  accomplished by suggesting to the media that, among other things,
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  they should subject plaintiff's allegations to inquiry and scrutiny. For example,
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  he noted in the statement that plaintiff's allegations change dramatically
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  over time, suggesting that their obvious lies and therefore should
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  not be publicized as news. Reply this paragraph, eliciting mister
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  Bardon's intent, is uncontroverted by plaintiff. She fails to cite
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  any contradictory admissible evidence, instead making legal arguments. Her arguments
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  are not admissible evidence e g. It is their statement,
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  and she directed that it be sent to the media
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  and public lacks any citation to record evidence. Plaintiff's list
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  of evidence, she contends corroborates Plaintiff's claims, should be ignored
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  as they do not pertain to mister Barden's purposes. In
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  drafting the January second statement Undisputed Fact Number twenty three second,
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  mister Barden intended the January twenty fifteen statement to be
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  a shot across the bow of the media, which he
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  believed had been unduly eager to publish plaintiff's allegations. Without
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  conducting an inquiry of their own Accordingly, the statement, he
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  repeatedly noted that Plaintiff's allegations were defamatory in this sense.
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  The statement was intended as a cease and assist letter
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  to the media recipients, letting the media recipients understand the
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  seriousness with which Miss Maxwell considered the publication of plaintiffs
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  obviously false allegations and the legal indefensibility of their own conduct.
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  Reply Again, Plaintiff disputes mister Barton's intent without citation to
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  record evidence. Plaintiff claims that Barden did not note anything
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  in the statement, but the statement itself contains the phrase
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  Miss Roberts claims or 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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  Plaintiff's unsupported arguments should be ignored and these facts pertaining
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  to mister Barden's intent deemed admitted Fact number twenty four
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  consistent with two purposes. Mister Gal's emails preface the statement
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  with the following language Please find attached to quotable statement
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  on behalf of Miss Maxwell. The statement was intended to
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  be a single, one time only, comprehensive response quoted in
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  full to Plaintiff's December thirtieth, twenty fourteen, allegations that would
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  give the media. Miss Maxwell's response, the purpose of the
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  preparatory statement was to inform the media recipients of this intent.
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  Reply if again disputes any statement related to mister Bardon's
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  purpose or intent, but offers no evidence contradicting his purpose
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  or intent. She simply points out that miss Maxwell retained
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  mister Gow in early twenty fifteen and that he works
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  for a public relations firm which is non responsive to
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  the fact that issue mister Barton's intent with respect to
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  language included in the statement. No one has contested that
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  it was mister Gow who actually forwarded this statement to
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  select members of the media who had requested a response.
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  The facts that fourth should be deemed admitted undisputed. Fact
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  Number twenty five Plaintiff's activities bring light to the rights
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  of victims of sexual abuse. Plaintiff has engaged in numerous
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  activities to bring attention to herself, to the prosecution and
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  punishment of wealthy individuals such as Epstein, and to her
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  claimed interest of bringing light to the rights of victims
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  of sexual abuse. Reply Plaintiff offers no evidence to dispute
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  the facts cited, and so they should be deemed admitted.
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  Undisputed Fact twenty six. Plaintiff created an organization, Victims Refuse Silence, Incorporated,
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  a Florida corporation, directly related to her alleged experience as
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  a victim of sexual abuse. Reply Plaintiff does not dispute
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  this statement. Twenty seven Undisputed fact number twenty seven. The
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  goal of Victims Refuse Silence was and continues to be,
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  to help survivors surmount the shame, silence, and intimidation typically
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  experienced by victims of sexual abuse. Towards this end, Plaintiff
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  has dedicated her professional life to helping victims of sexual trafficking.
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  Reply Plaintiff agrees twenty eight Undisputed fact number twenty eight.
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  Plaintiff repeatedly has sought out media organizations to discuss her
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  alleged experience as a victim of sexual abuse. This reply
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  statement at fifty one through fifty four and two through eleven,
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  and referenced and exhibits Document two sixty one to two
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  sixteen and example n kk LLL and MM. Reply Plaintiff
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  denies this contention points to an email from Sharon Churcher
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  seeking to interviewer, and asserts that it was the media
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  that sought her out. The weight of evidence cited by
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  defendant at paragraphs fifty one through fifty four, in addition
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  to plaintiff's own documents, belie this assertion. She through her attorneys,
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  sought out a videotaped interview with ABC News. She sent
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  her book manuscript to publishers and literary agents, and expressed
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  anticipation and frustration that her exclusive contract with the Mail
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  prevented her for a period of time from marketing her book.
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  Plaintiff disputed none of these activities she freely engaged in
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  for years, and thus these facts should be admitted. Twenty nine.
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  On December thirtieth, twenty fourteen, plaintiff publicly filed an entirely
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  un necessary joint or motion laden with unnecessary lurid details
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  about being sexually abused as a minor victim by wealthy
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  and famous men and being trafficked all over the world
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  as a sex slave. Reply. Plaintiff argues that her lurid
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  details were necessarily legal. Judge Mara, however, has already held
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  that they were not, and her legal arguments unsupported by
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  any actual evidence in this case cannot serve to controvert
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  his findings. As quoted thirty the plaintiff's alleged purpose in
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  filing the joint motion was to vintigate her rights under
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  the CVRA. Exposed the government secretly negotiated non prosecution agreement
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  with Epstein, shed tremendous public light on Epstein and other
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  powerful individuals that would undermine the agreement and support the
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  cvra's plaintiff's request for documents that would show how Epstein
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  used as powerful political and social connections to secure a
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  favorable plea deal and the government's motive to aid NX
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  Epstein and his co conspirators example d at one, six
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  and seven, and ten. Reply Plaintiff fails to offer any
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  evidence to controvert the contents of her CVRA joined her motion,
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  and thus the fact should be deemed admitted. Number thirty
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  one undisputed Fact Number thirty one Plaintiff's written the manuscript
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  of a book she has been trying to publish, detailing
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  her alleged experience as a victim of sexual abuse and
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  sex trafficking in Epstein's alleged scheme. Reply, Plaintiff directs the
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  court to her response to paragraph fifty two and suggests
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  the factual statement is misleading. She, however, offers no contradictory
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  admissible evidence, and thus the fact should be deemed admitted
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  thirty two undisputed fact thirty two republication alleged by plaintiff.
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  Plaintiff was required by interrogatory number six to identify any
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  false statements attributed to miss Maxwell that republished globally, including
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  within the Southern District of New York, as Plaintiff alleged
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  and paragraphed nine of count one of her complaint. In response,
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  Plaintiff identified the January twenty fifteen statement and nine instances
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  in which various news media published portions of the January
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  twenty fifteen statement in news articles or broadcast stories. Reply
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  her arguments aside, plaintiff offers no admissible evidence to controvert
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  the interrogatory request und a response which was limited to
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  nine instances in which the press published portions of the
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  January twenty fifteen statement. For example, plaintiff does not point
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  to one single news story that published the entirety of
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  the January twenty fifteen statement. In the absence of contrary evidence,
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  the fact should be deemed admitted thirty three. In none
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  of the nine instances was there any publication of the
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  entire January twenty fifteen statement. Reply. Plaintiff does not and
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  cannot point to any of the nine publications she disclosed
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  or any of the other publications that published the entire
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  January twenty fifteen statement, and this fact thus must be
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  deemed admitted. Thirty four. Miss Maxwell and her agents exercised
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  no control or authority over any media organization, including the
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  media identified in Plaintiff's response to interrogatory number six, in
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  connection with the media's publication of portions of the January
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  twenty fifteen statement. Reply. Plaintiff profited evidence testimony from mister
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  Gal fails to support her argument and fails to controvert
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  the Bardon declaration as cited by the defendant. Nothing in
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  the testimony establishes as plaintiff argues that the defendant hired
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  Gal because his position allowed him to influence the press
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  to publish her defamatory statement. The testimony is irrelevant to
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  the factual point. Gal's testimony at most relates to why
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  Miss Maxwell engaged mister Gal. It does not bear on
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  the factual point ie that Miss Maxwell mister gal or
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  mister Bardon did not exercise any control or authority over
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  the media in the media's republication of portions of the statement.
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  On this point, Plaintiff has failed to introduce any contrary evidence. Accordingly,
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  the fact should be deemed admitted. Thirty five Plaintiff's defamation
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  action against miss Maxwell. Eight years after Epstein's guilty plea.
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  Plaintiff brought this action, repeating many of the allegations she
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  made in her CVR. Joined her motion reply Plaintiff agrees
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  thirty six. The complaint alleged that the January twenty fifteen
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  statement contained the following deliberate falsehoods. A that Roberts sworn
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  allegations against Maxwell are untrue. B that the allegations have
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  been shown to be untrue. C that Robert's claims or
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  obvious laws us A reply Plaintiff agreed thirty seven. Plaintiff
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  lived independently from her parents with her fiance long before
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  meeting Epstein or Maxwell. After leaving the Growing Together Drug
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  rehabilitation facility in nineteen ninety nine, plaintiff moved in with
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  the family of a fellow patient, example l At seven
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  and eight and twelve through fourteen. There she met and
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  became engaged to her friend's brother, James Michael Ostrich id
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  At nineteen. She and Ostrich thereafter rented an apartment in
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  the Fort Lauderdale area with another friend and both worked
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  at various jobs in the area. Later, they stayed briefly
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  with plaintiff's parents in the Palm Beach Locksahatchie, Florida area,
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  before Ostrich rented an apartment for the couple on ben
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  Oak Drive in Royal Palm Beach id at seventeen, nineteen
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  twenty five through twenty seven. Although plaintiff agreed to marry Ostrich,
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  she never had any intention of doing so. Example n
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  at one twenty seven and one twenty eight reply Plaintiff
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  offers argument without an affidavid or any other contradictory evidence
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  regarding whether a plaintiff voluntarily lived independently or whether a
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  reasonable person could assert that she was engaged. Mister Ostrich
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  and plaintiff agreed that they were engaged and testified accordingly
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  as cited. In the absence of admissible evidence to the contrary,
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  the facts as described by her fiance in his deposition
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  should be deemed admitted. All right, folks, we're going to
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  wrap up this episode right here, and in the next episode,
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  we're going to 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.