Latest / The Epstein Chronicles / Mega Edition: The Long Legal Battle Between Ghislaine Maxwell And Virginia Roberts (8/19/26)

Transcript

Mega Edition: The Long Legal Battle Between Ghislaine Maxwell And Virginia Roberts (8/19/26) · The Epstein Chronicles

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Speaker 1: What's up everyone, and welcome back to the Epstein Chronicles.
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Speaker 1: In this episode, we're going to take a look at
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Speaker 1: the original complaint made by Virginia Roberts against Golaine Maxwell,
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Speaker 1: United States District Court, Southern District of New York, Virginia
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Speaker 1: Roberts versus Glayne Maxwell. Nature of the action. One. This
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Speaker 1: suit arises out of defendant Maxwell's defamatory statements against plaintiff Roberts.
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Speaker 1: As described below, Roberts was a victim of sexual trafficking
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Speaker 1: and abuse while she was a minor child. Defendant Maxwell
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Speaker 1: not only facilitated that sexual abuse, but most recently wrongfully
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Speaker 1: subjected Roberts to a public ridicule, contempt, and disgrace by,
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Speaker 1: among other things, calling Roberts a liar and published statements
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Speaker 1: with malicious intent of discrediting and further damaging Roberts. Worldwide
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Speaker 1: jurisdiction and venue. Two. This is an action for damages
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Speaker 1: in an amount and excess of the minimum jurisdictional limits
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Speaker 1: of this court. Three, The Court has jurisdiction over this
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Speaker 1: dispute pursuant to us CO twenty eight Section thirteen thirty
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Speaker 1: two Diversity jurisdiction. As Roberts and Maxwell are citizens of
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Speaker 1: different states, and the amount in controversy exceeds seventy five
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Speaker 1: thousand dollars exclusive of interests and costs. Four This Court
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Speaker 1: has personal jurisdiction over Maxwell. Maxwell resides in New York City,
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Speaker 1: and this action arose and defamatory statements were made within
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Speaker 1: the Southern District of New York. Five Venue is proper
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Speaker 1: in this court as the cause of action arose within
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Speaker 1: the jurisdiction of this court. Parties. Six. Plaintiff Roberts is
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Speaker 1: an individual who is a citizen of the state of Colorado. Seven.
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Speaker 1: Defendant Maxwell, who is domiciled in the Southern District of
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Speaker 1: New York, is not a citizen of the state of Colorado.
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Speaker 1: Factual allegations eight Virginia Roberts became a victim of sex
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Speaker 1: trafficking and repeated sexual abuse after being recruited by Glen
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Speaker 1: Maxwell and jis for Epstein when Roberts was under the
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Speaker 1: age of eighteen nine. Between nineteen ninety nine and two
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Speaker 1: thousand and two, with the assistance and participation of Maxwell,
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Speaker 1: Epstein sexually abused Roberts at numerous locations, including his mansions
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Speaker 1: in West Palm Beach, Florida. And in this district. Between
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Speaker 1: two thousand and one and two thousand and seven, with
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Speaker 1: the assistance of numerous co conspirators, Epstein abused more than
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Speaker 1: thirty minor underage girls, a fact confirmed by state and
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Speaker 1: federal law enforcement. Ten. As part of their sex trafficking efforts,
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Speaker 1: Epstein and Maxwell intimidated Roberts into remaining silent about what
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Speaker 1: had happened to her eleven. In September two thousand and seven,
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Speaker 1: Epstein entered into a non prosecution agreement that barred his
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Speaker 1: prosecution for numerous federal sex crimes in the Southern District
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Speaker 1: of Florida twelve in the NPA, The United States additionally
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Speaker 1: agreed that it would not institute any federal criminal charges
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Speaker 1: against potential co conspirators of Epstein. Thirteen. As a co
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Speaker 1: conspirator of Epstein, Deen Maxwell was consequently granted immunity in
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Speaker 1: the Southern District of Florida through the NPA. Fourteen. Epstein
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Speaker 1: ultimately pled to procuring a minor for prostitution and is
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Speaker 1: now a registered sex offender. Fifteen. Rather than confer with
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Speaker 1: the victims about the NPA, the U s Attorney's Office
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Speaker 1: in Epstein agreed to a confidentiality provision in the agreement
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Speaker 1: barring its disclosure to anyone, including Epstein's victims. As a consequence,
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Speaker 1: the victims were not told about the NPA sixteen. On
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Speaker 1: July seventh, two thousand and eight, a young woman identified
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Speaker 1: as Jane do Ie, one of Epstein's victims other than Roberts,
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Speaker 1: filed a petition to enforce her rights under the Crime
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Speaker 1: Victims Rights Act CVRA, US Code eighteen, section thirty seven
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Speaker 1: seventy one, alleging that the government failed to provide her
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Speaker 1: the rights promised in the CVRA with regard to the
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Speaker 1: plea arrangement with Epstein. The litigations remain ongoing seventeen honor.
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Speaker 1: About May fourth, two thousand and nine, Virginia Roberts, identified
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Speaker 1: then as Jane Doe number one O two, filed a
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Speaker 1: complaint against Jeffrey Epstein in the United States District Court
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Speaker 1: for the Southern District of Florida. The complaint included allegations
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Speaker 1: made by Roberts that pertained to Maxwell eighteen. In pertinent part,
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Speaker 1: the Jane Doe number one O two complaint described in
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Speaker 1: detail how Maxwell recruited Roberts, who was then a minor girl,
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Speaker 1: to become a victim of sex trafficking by introducing Roberts
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Speaker 1: to Jeffrey Epstein. With the assistance of Maxwell, Epstein was
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Speaker 1: able to sexually abuse Roberts for years until Roberts eventually escaped. Nineteen.
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Speaker 1: The Jane Doe Number one O two complaint contained the
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Speaker 1: first public allegations made on behalf of Roberts regarding Maxwell.
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Speaker 1: Twenty as civil litigation against Epstein moved forward on behalf
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Speaker 1: of Roberts and many other similarly situated victims, Maxwell was
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Speaker 1: served with the subpoena for a deposition. Her testimony was
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Speaker 1: sought concerning her personal knowledge and role in Epstein's abuse
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Speaker 1: of Roberts and others. Twenty one. To avoid her deposition,
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Speaker 1: Maxwell claimed that her mother fell ill, deathly ill, and
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Speaker 1: that consequently she was leaving the United States for London,
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Speaker 1: with no plans of ever returning. In fact, however, within
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Speaker 1: weeks of using that excuse to avoid testifying, Maxwell had
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Speaker 1: returned to New York twenty two. In twenty eleven, two
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Speaker 1: FBI agents located Roberts in Australia, where she had been
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Speaker 1: hiding from Epstein and Maxwell for several years, and arranged
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Speaker 1: to meet with her at the US Consulate in Sydney.
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Speaker 1: Roberts provided truthful and accurate information to the FBI about
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Speaker 1: Epstein and Maxwell's sexual abuse twenty three. Ultimately, as a
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Speaker 1: mother in one of Epstein's many victims, Roberts believed that
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Speaker 1: she should speak out about her sexual abuse experiences in
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Speaker 1: hopes of helping others who had also suffered from sexual
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Speaker 1: trafficking and abuse twenty four. On December twenty three, twenty fourteen,
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Speaker 1: Roberts incorporated an organization called Victims Refused Silence Incorporated of
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Speaker 1: Florida Not for Profit Corporation twenty five. Roberts intended Victims
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Speaker 1: Refused Silence to change and improve the fight against sexual
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Speaker 1: abuse and human trafficking. The goal of her organization was
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Speaker 1: and continues to be, to help survivors surmount the shame, silence,
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Speaker 1: and intimidation typically experienced by victims of sexual abuse. Roberts
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Speaker 1: is now dedicated her professional life to helping victims of
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Speaker 1: sex trafficking twenty six. On December thirtieth, twenty fourteen, Roberts
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Speaker 1: moved to join the ongoing litigation previously filed by Jane
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Speaker 1: do I in the Southern District of Florida challenging Epstein's
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Speaker 1: non prosecution agreement by filing her own joinder motion twenty seven.
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Speaker 1: Roberts motion described Maxwell's role as one of the main
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Speaker 1: women who Epstein used to procure underage girls for sexual
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Speaker 1: activities and the primary co conspirator and participant in his
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Speaker 1: sexual abuse in sex trafficking scheme twenty eight. In January
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Speaker 1: twenty fifteen, Maxwell undertook a concerted and malicious campaign to
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Speaker 1: discredit Roberts and to sow damage your reputation that Robert's
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Speaker 1: factual reporting of what had happened to her would not
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Speaker 1: be credited twenty nine. As part of Maxwell's campaign, she
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Speaker 1: directed her agent Ross Gaw to attack Robert's honesty and
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Speaker 1: truthfulness and to accuse Roberts of lying thirty honor. About
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Speaker 1: January third, twenty fifteen, speaking through her authorized agent, Maxwell
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Speaker 1: issued an additional false statement to the media and public
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Speaker 1: designed to maliciously discredit Roberts. That statement contained the following
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Speaker 1: deliberate falsees. A that roberts Worn allegations against Glaid Maxwell
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Speaker 1: are untrue. B that the allegations have been shown to
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Speaker 1: be untrue. C That Roberts claims or obvious lies thirty
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Speaker 1: one Maxwell's January third, twenty fifteen statement incorporated by reference Glaid.
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Speaker 1: Maxwell's original response to the lies and defamatory claims remains
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Speaker 1: the same an earlier statement that had falsely described Robert's
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Speaker 1: factualist as entirely false and entirely untrue. Thirty two. Maxwell
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Speaker 1: made the same false and defamatory statements is set forth
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Speaker 1: above in the Southern District of New York and elsewhere
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Speaker 1: in a deliberate effort to maliciously discredit Roberts and silence
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Speaker 1: her efforts to expose sex crimes committed around the world
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Speaker 1: by Maxwell, Epstein and other powerful persons. Maxwell did so
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Speaker 1: with the purpose an effect of having others repeat such
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Speaker 1: false and defamatory statements and thereby further damage Robert's reputation.
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Speaker 1: Thirty three Maxwell made her statements to discredit Roberts in
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Speaker 1: close consultation with Epstein. Maxwell made her statements knowing full
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Speaker 1: well that they were false. Thirty four Maxwell made her
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Speaker 1: statements maliciously as part of an effort to conceal sex
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Speaker 1: trafficking crimes committed around the world by Maxwell, Epstein and
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Speaker 1: other powerful persons. Thirty six Maxwell intended her false statements
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Speaker 1: to be specific statements of fact, including a statement that
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Speaker 1: she had not recruited and under Roberts for Epstein's abuse.
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Speaker 1: Maxwell's false statements were broadcast around the world and were
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Speaker 1: reasonably understood by those who heard them to be specific
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Speaker 1: factual claims by Maxwell that she had not held Epstein
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Speaker 1: recruit or sexually abuse Roberts, or that Roberts was a
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Speaker 1: liar thirty seven Honor. About January fourth, twenty fifteen, Maxwell
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Speaker 1: continued her campaign to falsely and maliciously discredit Roberts won.
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Speaker 1: A reporter on Manhattan Street asked Maxwell about Robert's allegations
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Speaker 1: against Maxwell. She responded by saying, I am referring to
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Speaker 1: that statement that was made. The New York Deli News
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Speaker 1: published the video of this response by Maxwell, indicating that
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Speaker 1: she had made her false statements on East sixty fifth
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Speaker 1: Street in Manhattan, New York, within the Southern District of
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Speaker 1: New York count Number one Defamation one Plaintiff Roberts re
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Speaker 1: alleges paragraphs one through thirty seven, as if the same
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Speaker 1: were fully set forth here in. Maxwell made her false
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Speaker 1: intfamatory statements deliberately and deliciously, with the intent to intimidate, discredit,
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Speaker 1: and defame Roberts. Two. In January twenty fifteen, and thereafter,
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Speaker 1: Maxwell intentionally and maliciously released to the press her false
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Speaker 1: statements about Roberts in an attempt to destroy Robert's reputation
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Speaker 1: and to cause her to lose all credibility in her
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Speaker 1: efforts to help victims of sex trafficking. Three. Maxwell additionally
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Speaker 1: released to the press or false statements with knowledge that
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Speaker 1: her words would dilute, discredit, and neutralize Robert's public and
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Speaker 1: private messages to sexual abuse victims and ultimately prevent Roberts
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Speaker 1: from effectively providing assistance and advocacy on behalf of other
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Speaker 1: victims of sex trafficking, or to expose her abusers. Four.
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Speaker 1: Using her role as a powerful figure with powerful friends,
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Speaker 1: Maxwell's statements were published internationally for the malicious purpose of
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Speaker 1: further damaging a sexual abuse and sexual trafficking victim, to
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Speaker 1: destroy Robert's reputation and credibility, to cause the world to
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Speaker 1: disbelieve Roberts, and to destroy by Robert's efforts to use
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Speaker 1: her experience to help others suffering as sex trafficking victims. Five.
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Speaker 1: Maxwell personally and through her authorized agent Ross gu intentionally
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Speaker 1: and maliciously made false and damaging statements of fact concerning Roberts,
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Speaker 1: as detailed above, in the Southern District of New York
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Speaker 1: and elsewhere. Six the false statements made by Ross Gu
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Speaker 1: were all made by him as Maxwell's authorized agent, and
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Speaker 1: were made with direct and actual authority from Maxwell as
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Speaker 1: the principal. Seven. The false statements that Maxwell made personally
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Speaker 1: and through her authorized agent Gu not only called Robert's
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Speaker 1: truthfulness and integrity into question, but also exposed Roberts to
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Speaker 1: public hatred, content, ridicule, and disgrace. Eight. Maxwell made her
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Speaker 1: false statements knowing full well that they were completely false. Accordingly,
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Speaker 1: she made her statements with actual and deliberate malice, the
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Speaker 1: highest degree of awareness of falsity. Nine. Maxwell's false statements
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Speaker 1: constitute libel as she knew that they were going to
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Speaker 1: be transmitted in writing, widely disseminated on the Internet and
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Speaker 1: in print. Maxwell intended her false statements to be published
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Speaker 1: by newspaper and other media outlets internationally, and they were
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Speaker 1: in fact published globally, including within the Southern District of
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Speaker 1: New York. Ten. Maxwell's false statements constitute libel per se
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Speaker 1: inasmuch as they exposed Roberts the public intempt, ridicule, aversion
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Speaker 1: and disgrace, and induced an evil opinion of her in
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Speaker 1: the minds of right thinking persons. Eleven. Maxwell's false statements
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Speaker 1: also constitute libel per inasmuch as they tended to injure
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Speaker 1: Roberts in her professional capacity as the president of a
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Speaker 1: nonprofit corporation designed to help victims of sex trafficking, and
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Speaker 1: inasmuch as they destroyed her credibility and reputation among members
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Speaker 1: of the community that seeks her help and that she
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Speaker 1: seeks to help serve. Twelve Maxwell's false statements directly stated
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Speaker 1: and also implied that, in speaking out against sex trafficking,
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Speaker 1: Roberts acted with fraud to de dishonesty and unfitness for
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Speaker 1: the task. Maxwell's false statements directly and indirectly indicate that
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Speaker 1: Roberts lied about being recruited by Maxwell and sexually abused
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Speaker 1: by Epstein and Maxwell. Maxwell's false statements were reasonably understood
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Speaker 1: by many persons who read her statements as conveying that
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Speaker 1: specific intention and meaning. Thirteen Maxwell's false statements were reasonably
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Speaker 1: understood by many persons who read those statements as making
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Speaker 1: specific factual claims that Roberts was lying about specific facts. Fourteen.
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Speaker 1: Maxwell's specifically directed her false statements at Robert's true public
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Speaker 1: description of factual events, and many persons who read Maxwell's
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Speaker 1: statements reasonably understood that those statements referred directly to Robert's
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Speaker 1: account of her life as a young teenager. With Maxwell
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Speaker 1: and Epstein fifteen, Maxwell intended her false statements to be
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Speaker 1: widely published and disseminated on television, through newspapers, by word
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Speaker 1: of mouth, and on the Internet. As intended by Maxwell,
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Speaker 1: her statements were published and disseminated around the world. Sixteen.
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Speaker 1: Maxwell coordinated her false statements with other media efforts made
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Speaker 1: by Epstein and other powerful persons. Acting as Epstein's representatives
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Speaker 1: and surrogates. Maxwell made her coordinated statements in the Southern
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Speaker 1: District of New York and elsewhere, with the specific intent
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Speaker 1: to amplify the defamatory effect those statements would have on
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Speaker 1: Robert's reputation and credibility. Seventeen, Maxwell made her false statements
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Speaker 1: both directly and through agents who, with their general and
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Speaker 1: specific authorization, adopted, distributed, and published the false statements on
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Speaker 1: Maxwell's behalf. In addition, Maxwell and her authorized agents made
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Speaker 1: false statements and reckless disregard of their truth or falsity,
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Speaker 1: and with malicious intent to destroy Robert's reputation and credibility,
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Speaker 1: to prevent her from further disseminating her life story, and
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Speaker 1: to cause persons hearing or reading Robert's descriptions of truthful
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Speaker 1: facts to disbelieve her entirely. Maxwell made her false statement
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Speaker 1: Mints wantonly and with the specific intent to maliciously damage
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Speaker 1: Robert's good name and reputation in a way that would
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Speaker 1: destroy her efforts to administer her nonprofit foundation or share
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Speaker 1: her life story and thereby help others who have suffered
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Speaker 1: sexual abuse. Eighteen. As a result of Maxwell's campaign to
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Speaker 1: spread false, discrediting, and defamatory statements about Roberts, Roberts suffered
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Speaker 1: substantial damages in an amount to be proven at trial. Nineteen.
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Speaker 1: Maxwell's false statements have caused and continue to cause Roberts
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Speaker 1: economic damage, psychological pain and suffering, and mental anguish and
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Speaker 1: emotional distress, and other direct and consequential damage and losses.
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Speaker 1: Twenty Maxwell's campaign to spread our false statements internationally was
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Speaker 1: unusually and particularly egregious conduct. Maxwell sexually abused Roberts and
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Speaker 1: helped Epstein to sexually abuse Roberts, and then, in order
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Speaker 1: to avoid having these crimes discovered, Maxwell wantonly and maliciously
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Speaker 1: set out the falsely accused of fame and discredit Roberts.
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Speaker 1: In doing so, Maxwell's efforts constituted a public wrong by deterring, damaging,
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Speaker 1: and setting back Robert's efforts to help victims of sex trafficking. Accordingly,
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Speaker 1: this is the case in which exemplary and punitive damages
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Speaker 1: are appropriate. Twenty one. Punitive and exemplary damages are necessary
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Speaker 1: in this case to deter Maxwell and others from wantonly
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Speaker 1: and maliciously using a campaign of lies to discredit Roberts
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Speaker 1: and other victims of sex trafficking. Prayer for relief. Wherefore,
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Speaker 1: Plaintiff Roberts respectfully requests judgment against Defendant Maxwell, awarding competentory, consequential,
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Speaker 1: exemplary and punitive damages in an amount to be determined
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Speaker 1: at trial, but in excess of the seventy five thousand
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Speaker 1: dollars jurisdictional requirement, cost of suit attorney's fees, and such others,
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Speaker 1: and further relief as the Court may deem just and
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Speaker 1: proper jury demand. Plaintiff hereby demands a trial by jury
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Speaker 1: on all causes of action assert within this pleading. This
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Speaker 1: was signed on September twenty one, twenty fifteen, and it
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Speaker 1: was signed by David Boys. All of the information that
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Speaker 1: goes with this episode can be found in the description box.
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Speaker 1: What's up everyone, and welcome back to the Epstein Chronicles.
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Speaker 1: Things are really heating up for Gallaine Maxwell, Prince Andrew
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Speaker 1: and all of the people who are associating with them. Now.
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Speaker 1: Virginia Roberts is demanding that eight names be unsealed and
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Speaker 1: released to the public. These are names that were uncovered,
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Speaker 1: if you will, during the lawsuit with Gallaiine Maxwell during
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Speaker 1: the civil lawsuit, and Virginia Roberts lawyers want these names
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Speaker 1: to be brought to the public light. And me personally,
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Speaker 1: you all know how I feel about transparency. Let it
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Speaker 1: all out, all of these people, and I'm guessing the
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Speaker 1: people who are named here the eight are all of
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Speaker 1: the people that have been directly accused by Virginia Roberts,
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Speaker 1: you know, George Mitchell, Bill Richardson, Les Wexner, Jeffrey Ebstein,
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Speaker 1: Glenn Dubin, you know. And I'm guessing she wants to
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Speaker 1: continue to put a spotlight on the fact that these
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Speaker 1: people were not only enablers, but they were also participants
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Speaker 1: in the abuse. And I think that's a big deal,
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Speaker 1: right because a lot of people seem to be confused,
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Speaker 1: a lot of people seem to not understand the scope
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Speaker 1: of what went on here. And I've seen people say, well,
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Speaker 1: who are the people that these girls were trafficked to?
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Speaker 1: If you've been following the case, then you know a
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Speaker 1: lot of the names, George Mitchell, Glenn Dubin, Bill Richardson,
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Speaker 1: the names. I just named a bunch of other people.
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Speaker 1: So for those who were like, well, nobody's name and
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Speaker 1: names people are naming names, it's just not you know,
18:59
Speaker 1: in a court of law setting. Yet the deposition, however,
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Speaker 1: was in a court of law, So what was said
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Speaker 1: during this deposition will carry a lot more weight with
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Speaker 1: certain people, for sure. And when we're talking about this
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Speaker 1: case especially, we need as much transparency as possible because
19:23
Speaker 1: people don't believe the official narrative, and that's because the
19:26
Speaker 1: official narrative has been bogus pretty much the whole entire time.
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Speaker 1: So now that the band aid has been completely pulled
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Speaker 1: off and people are getting a good look at what's
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Speaker 1: really going on, people are no longer going to just
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Speaker 1: accept Oh, it was just Epstein and Maxwell and that
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Speaker 1: was the end of it. People aren't going to accept that.
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Speaker 1: And the sooner that these prosecutors and our politicians realize that,
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Speaker 1: the better off they are going to be, this is
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Speaker 1: going to become an issue. This is going to become
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Speaker 1: a hinge voting issue in the future, mark my words,
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Speaker 1: stuff like this, because people are fed up. Nobody wants
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Speaker 1: to look at these gross ass, disgusting, crusty old men
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Speaker 1: and think about them molesting kids and trafficking children. Nobody
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Speaker 1: wants to deal with it. So all of these names
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Speaker 1: need to be released. We need to put all of
20:21
Speaker 1: these dudes on blast, and then they should have the
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Speaker 1: chance to answer what the accusations are against them. But
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Speaker 1: the problem is, and here's where my big problem comes
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Speaker 1: up with all of these people. They don't want to
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Speaker 1: answer for it because they know they don't have a
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Speaker 1: good answer. They know that they don't have an alibi,
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Speaker 1: so they try to avoid it. They try to act
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Speaker 1: like it never happened, and then they're not pursued by
20:46
Speaker 1: the legacy media or they're called the socialite. You know,
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Speaker 1: they still give them cover. But all of these people
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Speaker 1: who have been named and pointed to by Virginia and
20:59
Speaker 1: other survivors. They should all be put on blast. So
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Speaker 1: let's hope that Judge Presca continues her streak of releasing
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Speaker 1: information in this case, and let's hope that she unseals
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Speaker 1: all of this and we get ourselves a huge tranch
21:14
Speaker 1: of information to go through until we get to that point. However,
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Speaker 1: why don't we dive into this article from the Daily
21:21
Speaker 1: Deli Mail And this is an article that was authored
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Speaker 1: by Daniel Bates. Headline, Prince Andrew accuser Virginia Roberts demands
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Speaker 1: identities of eight high profile john does named in civil
21:35
Speaker 1: lawsuit she filed against Glaine Maxwell be unsealed. Now, I
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Speaker 1: don't see why they wouldn't unseal it. Maxwell's case is over,
21:44
Speaker 1: she's convicted. She can't cry that this is going to,
21:48
Speaker 1: you know, be detrimental to her at this point. So
21:51
Speaker 1: let's get these names out there and let's put all
21:54
Speaker 1: these dudes on blast. And then what you can do
21:57
Speaker 1: is go back and listen to some of the older
21:59
Speaker 1: episodes and see that we've been miles ahead of the
22:02
Speaker 1: legacy media the whole entire time. Here. Lawyers for Prince
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Speaker 1: Andrew's accuser have asked a judge to unsealed documents and
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Speaker 1: vast swaths of information about Jeffrey Epstein and Glenn Maxwell's
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Speaker 1: sex trafficking operation. Attorneys for Virginia Roberts said Judge Loretta
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Speaker 1: Presca should publicly release material from the civil lawsuit she
22:26
Speaker 1: filed against Maxwell containing references to eight anonymous John does
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Speaker 1: absolutely no more anonymous in this case. Enough is enough.
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Speaker 1: They haven't earned the right to be anonymous. These people
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Speaker 1: are again just wielding influence, wielding power, and that's why
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Speaker 1: they're able to keep this stuff sealed. Do you think
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Speaker 1: if it was you or me that it would be sealed.
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Speaker 1: Do you think if it was you or me that
22:51
Speaker 1: our names wouldn't be all over the media. But because
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Speaker 1: these people are business tycoons or politicians or whatever it
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Speaker 1: might be, they should be protected. Their image is more
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Speaker 1: important than anybody else's. Huh, it's all a joke. And
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Speaker 1: all of the pro clutching blue check marks that cry
23:10
Speaker 1: on Twitter about how terrible journalism is now for us,
23:13
Speaker 1: Oh we don't get paid it off, body, Well, that's
23:15
Speaker 1: because your work is garbage, point blank period. If you're
23:18
Speaker 1: not good at your job, You're not gonna make any money,
23:21
Speaker 1: all right, So stop with the tribalism as a journalist.
23:25
Speaker 1: I don't want to click on somebody's profile on Twitter
23:28
Speaker 1: and see who your political affiliations are. How about just
23:31
Speaker 1: giving us the news. Is that too difficult for you,
23:34
Speaker 1: because if it is, you're gonna be a dinosaur, a relic,
23:38
Speaker 1: And you're already starting to move that way, meaning the
23:41
Speaker 1: legacy media. But they'll continue to cry about it, and
23:44
Speaker 1: then at the same time they won't do their jobs
23:47
Speaker 1: to dig deeper in cases such as this to give
23:49
Speaker 1: you folks the information you deserve. So whose fault is
23:52
Speaker 1: it when they aren't profitable anymore? Whose fault is it
23:56
Speaker 1: when newsrooms are getting fired? Enough with the app activism,
24:00
Speaker 1: enough with the political tribalism as a journalist, and how
24:04
Speaker 1: about you start digging into the stories. The individuals are
24:11
Speaker 1: identified in core documents only as non parties seventeen fifty three,
24:16
Speaker 1: fifty four, fifty five, fifty six, seventy three, ninety three,
24:20
Speaker 1: and one fifty one. It is not clear if one
24:23
Speaker 1: of them is the Duke of York. I'm guessing it is.
24:26
Speaker 1: Like I said, I'm guessing all of those people are
24:29
Speaker 1: the people that have been pointed to by Virginia Roberts
24:33
Speaker 1: as to people who took part in her abuse, and
24:37
Speaker 1: that certainly seems the likeliest scenario for me. Obviously, we
24:41
Speaker 1: won't know until it's unsealed, but that's my guess. When
24:45
Speaker 1: and if it's unsealed, we'll come back to this episode
24:48
Speaker 1: and we'll revisit if my prognostication here was right. All
24:53
Speaker 1: eight parties have objected to the unsealing. According to the filings.
24:57
Speaker 1: John Doe seventeen can plain that being associate, he added
25:00
Speaker 1: with the case would cause them annoyance and embarrassment. Imagine
25:03
Speaker 1: imagine not being able to read the room and think
25:06
Speaker 1: that your annoyance and your embarrassment is worth more than justice,
25:11
Speaker 1: is worth more than these ladies getting the justice they deserve.
25:15
Speaker 1: Imagine being this John Doe seventeen, jerk off. I really
25:20
Speaker 1: hope that these people are outed, and when they are,
25:23
Speaker 1: we're gonna do an episode on each of them. Considering
25:26
Speaker 1: all of them want to keep their anonymity so much,
25:29
Speaker 1: we're gonna help them air themselves out. That's what we're
25:33
Speaker 1: gonna do when these names are released. Another John Doe
25:38
Speaker 1: number one fifty one claimed that they were trying to
25:41
Speaker 1: live a private life and that disclosure meant they would
25:44
Speaker 1: be hounded by the media. Well, I'm pretty sure that
25:47
Speaker 1: the survivors were just trying to live a nice, young
25:49
Speaker 1: teenage life too. How'd that work out for them? Now,
25:52
Speaker 1: you think we should respect your privacy. You're a public figure, homie,
25:57
Speaker 1: You have no expectation of private life. And if you
26:01
Speaker 1: were hanging out with Jeffrey Epstein and you were partaking
26:04
Speaker 1: in the abuse, especially, zero chance you're ever going to
26:08
Speaker 1: be left alone from here on out. If law enforcement
26:12
Speaker 1: won't hold you accountable, it's up to society to make
26:15
Speaker 1: sure you are not welcome ever again. The request came
26:21
Speaker 1: on the day that Judge Lewis Caplan ruled out that
26:23
Speaker 1: Robert's battery lawsuit against Andrew, a separate case also filed
26:27
Speaker 1: that the federal court in New York can move forward.
26:30
Speaker 1: If Judge presca decides to unseal the documents in Robert's case,
26:34
Speaker 1: they could shed new light on the Duke's dealings with
26:36
Speaker 1: Maxwell and Epstein. Look, why would anyone be against transparency
26:41
Speaker 1: at this point unless you have something to hide? And well,
26:44
Speaker 1: we all know that Uncle Touchy has something to hide.
26:48
Speaker 1: But Galan Maxwell, what does she have to care at
26:50
Speaker 1: this point? Let it loose, let it go, tell your
26:54
Speaker 1: lawyers you don't care if it's unsealed. What more embarrassment
26:57
Speaker 1: can you possibly suffer? Galan Maxwell are a human trafficker.
27:02
Speaker 1: So let's hope that she doesn't dispute them trying to
27:05
Speaker 1: get this unsealed. Presca is the judge who presided over
27:09
Speaker 1: a defamation lawsuit that Roberts filed against Maxwell in twenty
27:14
Speaker 1: sixteen for calling her a liar. The case was settled
27:17
Speaker 1: with confidential terms, but the judge has slowly been approving
27:21
Speaker 1: the release of hundreds of documents in the case after
27:24
Speaker 1: applications from media organizations. Well, what do you know, the
27:27
Speaker 1: legacy media finally doing something. If they would have covered
27:31
Speaker 1: this from the beginning, they wouldn't have to file these
27:33
Speaker 1: applications to get things unsealed, because they would have already
27:37
Speaker 1: known what was going on. But Judge Presca has been
27:40
Speaker 1: very consistent with releasing documentation in this case, and I
27:45
Speaker 1: don't expect her to deviate from that course moving forward. Here.
27:48
Speaker 1: I would expect, and again this is just my guest, folks,
27:52
Speaker 1: that this documentation is going to see the light of day.
27:58
Speaker 1: In her letter to the judge, Robert's lawyer, Sigurd McAuley
28:02
Speaker 1: said that they were following the court's instructions to streamline
28:04
Speaker 1: the process of making the documents public. The numerous parties
28:08
Speaker 1: mentioned in the documents met in October and agreed to
28:12
Speaker 1: split the objecting non parties into groups and address the
28:15
Speaker 1: objections of the eight john Does first, But upon review,
28:19
Speaker 1: McCauley said, it is apparent that their objections essentially mirror
28:24
Speaker 1: objections to unceiling that this Court has already rejected. That
28:28
Speaker 1: unsealing certain documents might be embarrassing, would expose non parties
28:32
Speaker 1: to media attention, and could result in some unfortunate association
28:37
Speaker 1: between the non parties and Jeffrey Epstein or Glen Maxwell.
28:41
Speaker 1: See that's how it always starts out, right, Oh, it's
28:43
Speaker 1: a non party. Oh he's just a person of interest
28:46
Speaker 1: in the case. He's not a suspect. Yeah, okay, So
28:50
Speaker 1: again non parties, we know what that means. We just
28:53
Speaker 1: mean that it means that they're not indicted, right, they're
28:56
Speaker 1: not under criminal investigation. But we know that Virginia has
29:01
Speaker 1: named names, and she has done it many times and
29:05
Speaker 1: even in court in the face of extensive prior briefing
29:09
Speaker 1: on objections just like these. The court's unsealing process has
29:13
Speaker 1: been quite consistent, with the exception of a narrow set
29:16
Speaker 1: of circumstances which are generally not present here. Documents have
29:20
Speaker 1: been unsealed, and that's for sure. Judge Presca has been
29:23
Speaker 1: very consistent, like I said, with unsealing this documentation. She
29:26
Speaker 1: has really wanted to get to the bottom of this,
29:28
Speaker 1: it seems like, and she's not the type it would
29:31
Speaker 1: seem that wants to might mess around and play games.
29:34
Speaker 1: Get this information out there, Let the people see it.
29:36
Speaker 1: The people deserve to have transparency. McCauley added that generalized
29:43
Speaker 1: aversion to embarrassment and negativity from being associated with the case,
29:47
Speaker 1: it was not enough to keep the documents private. That
29:51
Speaker 1: was especially true given the great public interest in the
29:53
Speaker 1: fact that Maxwell's trial for recruiting and trafficking underage girls
29:57
Speaker 1: has now finished. She was found guilty in fai is
30:00
Speaker 1: sixty five years in jail. McCaulay wrote, now that Maxwell's
30:04
Speaker 1: criminal trial has come and gone, there's little reason to
30:07
Speaker 1: retain protection over the vast amounts of information about Epstein
30:11
Speaker 1: and Maxwell's sex trafficking operation that were originally filed under
30:15
Speaker 1: seal in this case, and she's one hundred percent right.
30:18
Speaker 1: What purpose does it serve to keep things sealed at
30:20
Speaker 1: this point unless you're trying to protect the reputation of
30:23
Speaker 1: some of your friends or something. But personally, I don't
30:27
Speaker 1: really care about any of these people. I want an
30:30
Speaker 1: absolute neutron bomb right dropped on all of them, meaning
30:35
Speaker 1: they all have to come in, they all have to
30:37
Speaker 1: sit down for interrogations. Just how's it so different than
30:41
Speaker 1: what happened at the Capitol. They sure went out and
30:43
Speaker 1: rounded up all those people quick enough, didn't they. But
30:46
Speaker 1: they can't bring in Glenn Maxwell's associates. Huh. It shows
30:49
Speaker 1: you where the priorities are at. The letter stated that
30:54
Speaker 1: people testified in court about matters which are under seal
30:58
Speaker 1: in the case at issue the matter. McCauley wrote that
31:02
Speaker 1: the abundance of public information now widely available about Epstein
31:05
Speaker 1: and Maxwell's scheme through the thousands of pages of publicly
31:09
Speaker 1: available trial transcripts cuts against any continued ceiling in this case.
31:15
Speaker 1: Turning to each of the John does, the letter states
31:17
Speaker 1: that John Doe seventeen is mentioned in four documents and
31:21
Speaker 1: objects to his name being made public. She's not wrong.
31:24
Speaker 1: All of this stuff, for the most part, is out
31:26
Speaker 1: there already. It's just cataloging it and putting it in
31:30
Speaker 1: a manner that is digestible because a lot of people
31:34
Speaker 1: don't know where to start, right. There's so much that
31:36
Speaker 1: goes on here. Finding a jump off point is very difficult.
31:40
Speaker 1: But the information is out there, and all of this
31:42
Speaker 1: needs to be unsealed. McCauley wrote that his objection is
31:48
Speaker 1: that if the material is allowed to be made public,
31:51
Speaker 1: it will cause them to say the least annoyance and embarrassment. Again,
31:55
Speaker 1: I don't care about your annoyance or your embarrassment. I
31:58
Speaker 1: care about just as being fulfilled. I care about these
32:01
Speaker 1: survivors being able to wake up in the morning, look
32:04
Speaker 1: in the mirror and say, you know what, things haven't
32:07
Speaker 1: been great. You know, there's been all this trauma that
32:10
Speaker 1: I've suffered earlier in my life. But it's a new
32:12
Speaker 1: start for me because justice is being pursued because Maxwell's
32:16
Speaker 1: in prison. That's what I want. But it doesn't stop there, right,
32:20
Speaker 1: all of these co conspirators again, just listen to what
32:23
Speaker 1: the survivors are saying themselves, and then that's where the
32:26
Speaker 1: playbook should be. We should be following that playbook. Meaning,
32:31
Speaker 1: if the survivors say that there's still people out there
32:33
Speaker 1: that were involved, what are we waiting for? Indict them
32:36
Speaker 1: and let's get some trials going. It would also cause
32:41
Speaker 1: the individual severe anxiety and distress, an extreme personal, physical,
32:46
Speaker 1: and reputational harm. Severe anxiety and distress. Huh, try being
32:49
Speaker 1: poor homie. Try waking up every morning and not knowing
32:52
Speaker 1: where your next meal's coming from or how you're going
32:55
Speaker 1: to buy your kid that pair of Jordan's so he can,
32:57
Speaker 1: you know, be part of the in crowd and tell
33:00
Speaker 1: me about severe anxiety and distress as you're swimming around
33:04
Speaker 1: in your vault like Scrooge McDuck. McCauley said that that
33:09
Speaker 1: Doe did not cite any legal authority and the documents
33:12
Speaker 1: should be unsealed. Those fifty three and fifty four do
33:15
Speaker 1: not oppose unsealing the documents relating to them, and they
33:18
Speaker 1: should be released. The letter stated. Those fifty five and
33:21
Speaker 1: fifty six object to their names being made public because
33:25
Speaker 1: they claim a deposition in which they are mentioned is unreliable.
33:28
Speaker 1: The letter states, Yeah, you know, court documents really unreliable.
33:31
Speaker 1: Because nobody's ever been arrested for perjury for lying during
33:35
Speaker 1: a deposition. Is that what you're saying here, is that
33:38
Speaker 1: what you're putting forth that this is going to be
33:41
Speaker 1: a lie. Because if that's the case, then the person
33:44
Speaker 1: who was giving the deposition, meaning Virginia, well then she
33:48
Speaker 1: should get arrested for perjury like Maxwell. Right, But we
33:51
Speaker 1: know that's not gonna happen because Virginia is telling the truth.
33:59
Speaker 1: McCauley argued if this was not grounds to keep the
34:01
Speaker 1: material private, John Doe's seventy three argues against unsealing because
34:05
Speaker 1: of a general aversion to being associated with Maxwell and
34:08
Speaker 1: Epstein and disclosure could cause substantial embarrassment. Well, here's an idea.
34:13
Speaker 1: Don't associate with Epstein and Maxwell and then you don't
34:15
Speaker 1: have to worry about being aired out by the media
34:18
Speaker 1: when the walls close in. Are these people for real? Like,
34:22
Speaker 1: I mean really, well, I was friends with them, but
34:24
Speaker 1: I don't want you to know. That's basically what he's saying.
34:28
Speaker 1: Dough ninety three claims that the documents which mention them
34:31
Speaker 1: have no relevance to the matters at hand and could
34:34
Speaker 1: be seen as silacious. Dough one forty one is mentioned
34:37
Speaker 1: the most of all and appears in forty seven documents.
34:41
Speaker 1: According to McCauley's letter, Doe claims they're trying to live
34:44
Speaker 1: a private life and do not want any attention stemming
34:47
Speaker 1: from disclosure. Ah, you know, that's pretty pretty sad that
34:51
Speaker 1: you don't want any attention, But guess what you're gonna
34:53
Speaker 1: get it? Mark my words, folks, the second these names
34:57
Speaker 1: are released, expect a closer look episode on all of
35:00
Speaker 1: these people. Obviously we've already covered all of them at
35:04
Speaker 1: some point, but we'll dive right back in and we'll
35:06
Speaker 1: get an updated version going. Because enough is enough with
35:10
Speaker 1: the secrecy, enough is enough with the transparency. Haven't we
35:14
Speaker 1: had enough of that in this case? And in fact,
35:16
Speaker 1: haven't we had enough of that overall from our government?
35:21
Speaker 1: They claim it will be hounded and pursued. He but
35:24
Speaker 1: the media for by the media for comment and elaboration.
35:28
Speaker 1: McCauley says this is not grounds for keeping the document sealed,
35:31
Speaker 1: and notes that the material has already been widely reported
35:34
Speaker 1: in the media and part has been unsealed. The individual's
35:38
Speaker 1: involvement in the case has also been reported already, and
35:41
Speaker 1: they have already been contacted by the media and declined
35:44
Speaker 1: to comment. Oh, I'm sure it's one of those lovely
35:47
Speaker 1: folks that Virginia has pointed to. Maybe it's a George Mitchell.
35:51
Speaker 1: Maybe it's a Glenn Dubin. Now you know who knows
35:54
Speaker 1: one of them types. In her battery lawsuit against Andrew,
35:59
Speaker 1: Roberts that she was forced to have sex with him
36:02
Speaker 1: meaning Prince, meaning the individual, three times when she was seventeen,
36:07
Speaker 1: after Epstein told her to do so. So it's obviously Andrew.
36:10
Speaker 1: Andrew was strongly and repeatedly denied the claims, calling them
36:13
Speaker 1: baseless in his response and that they are designed to
36:16
Speaker 1: get a payday from him. So how about if Virginia
36:20
Speaker 1: foregoes the payday, then what's everybody going to attach their
36:24
Speaker 1: horse and cart to at that point? Oh, well, she's
36:27
Speaker 1: a money hungry person. Well no, she's not trying to
36:29
Speaker 1: get paid here, So what is it then? What are
36:31
Speaker 1: you going to say then, detractors? In his ruling allowing
36:36
Speaker 1: the case to continue, Judge Kaplan rejected Andrew's argument that
36:39
Speaker 1: a settlement Robert signed with Epstein in two thousand and
36:42
Speaker 1: nine to settle a civil case against him should be
36:45
Speaker 1: grounds for dismissal. The case now moves into the discovery phase,
36:49
Speaker 1: where each side exchanges documents and depositions are taken, including
36:54
Speaker 1: that of the Duke himself. And this is what we
36:56
Speaker 1: always talk about discovery phase. These people are terrified of it,
37:00
Speaker 1: of airing themselves out, of having to expose themselves to
37:03
Speaker 1: the public. Now, obviously, I'm sure a lot of it
37:06
Speaker 1: will be sealed like they love to do in the courts,
37:09
Speaker 1: but the fact that this clown is going to have
37:11
Speaker 1: to get up there and be deposed is making me
37:15
Speaker 1: almost giddy. At this point. Judge Presca has been unsealing
37:20
Speaker 1: such material in the defamation case, and it gives an
37:23
Speaker 1: insight into what is in store for the Duke in
37:25
Speaker 1: the coming months. The documents include a deposition from Roberts
37:30
Speaker 1: and Joanna Schuberg, who claims she was in the room
37:33
Speaker 1: when Andrew groped Robert's breast at Epstein's New York mansion
37:36
Speaker 1: in two thousand and one. The documents have also included
37:40
Speaker 1: emails that Andrew sent to Maxwell in January twenty fifteen,
37:44
Speaker 1: after Roberts claimed for the first time that she had
37:47
Speaker 1: sex with them. The Duke messaged Maxwell, let me know
37:50
Speaker 1: when we can talk. Got some specific questions to ask
37:53
Speaker 1: you about Virginia. Roberts, referring to Virginia Maxwell responded, have
37:58
Speaker 1: some info call me when you have a moment. So
38:01
Speaker 1: can we get those phone records? We know the emails here,
38:04
Speaker 1: and this is the email that I've talked about in
38:06
Speaker 1: the past that establishes that he knew who Virginia was.
38:09
Speaker 1: He says he has no idea who she was, but
38:11
Speaker 1: he's emailing Glen Maxwell and asking her by name. Come on, now,
38:18
Speaker 1: who's gonna believe that bs Not me, not you. I
38:21
Speaker 1: don't know who's buying it. Maybe Mummy, but the rest
38:24
Speaker 1: of us are sitting here like bro Come on. So
38:28
Speaker 1: we're looking at some really interesting information possibly coming down
38:34
Speaker 1: the pipe, folks. And this is going to be a
38:37
Speaker 1: lot of context for people who might not really have
38:41
Speaker 1: a full grasp of what's going on yet. And if
38:44
Speaker 1: you know anything about me yet, you should know I
38:46
Speaker 1: love context. Prince Andrew is up against it. All of
38:52
Speaker 1: his friends are about to get outed. Nobody wants him
38:55
Speaker 1: in the public eye, and all that's left now is
38:59
Speaker 1: for the Justice trained to pull up to the station
39:04
Speaker 1: that's gonna do it for me. Tonight, folks. Obviously, some
39:07
Speaker 1: more context episodes come in your way tomorrow, same schedule
39:11
Speaker 1: as usual. Hope that all of you folks have a
39:13
Speaker 1: great day today, and as for me, I'll be back later.
39:17
Speaker 1: If you want to contact me, you can do that
39:19
Speaker 1: at Bobby Kapuchi at ProtonMail dot com. That's bo bb
39:23
Speaker 1: Y c ap u c Ci at ProtonMail dot com.
39:27
Speaker 1: You can also find me on Twitter at Bobby Underscore
39:32
Speaker 1: c A p U c CI. The link that we
39:35
Speaker 1: discussed can be found in the description box. What's up everyone,
39:39
Speaker 1: and welcome back to the Epstein Chronicles. In this episode,
39:42
Speaker 1: we're gonna dive right back into the core documents and
39:45
Speaker 1: we're gonna take a look at the plaintiff's motion to
39:48
Speaker 1: compel the defendant to answer deposition questions filed under seal
39:54
Speaker 1: case number fifteen DASH CV DASH zero seven four three
39:58
Speaker 1: three DASH RWs Virginia roberts versus Glenn Maxwell. The Plaintiff's
40:04
Speaker 1: motion to compel Defendant to answer deposition questions filed under
40:08
Speaker 1: seal Plaintiff Virginia Roberts by and through her undersigned Council
40:13
Speaker 1: hereby files this motion to compel Defendant to answer deposition questions.
40:18
Speaker 1: During her recent deposition, Defendant refused to answer numerous questions
40:22
Speaker 1: about allegedly adult sexual activity related to Jeffrey Epstein. Because
40:27
Speaker 1: this activity is highly relevant to this case, Defendant should
40:31
Speaker 1: be ordered to answer questions about it as the Court
40:35
Speaker 1: is aware of. This defamation case involves Miss roberts assertions
40:39
Speaker 1: that she and other females were recruited by the defendant
40:43
Speaker 1: to be sexually abused by Jeffrey Epstein under the guise
40:46
Speaker 1: of being massaged therapists seek Complaint D one at twenty seven.
40:51
Speaker 1: Roberts described Maxwell's role as one of the main women
40:54
Speaker 1: who Epstein used to procure underage girls for sexual activities
40:58
Speaker 1: and a primary code conspirator and participant in his sexual
41:02
Speaker 1: abuse and sex trafficking scheme. In response to these assertions,
41:07
Speaker 1: Defendant has made the sweeping claim that Miss roberts assertions
41:10
Speaker 1: are entirely false and entirely untrue Complaint DE one at
41:15
Speaker 1: thirty one. Yet, during her deposition, defendant refused to answer
41:19
Speaker 1: any questions that she construed as having something to do
41:22
Speaker 1: with consensual adult sex. Defense counsels supported that position that frankly,
41:28
Speaker 1: that's none of your business and I instruct the witness
41:30
Speaker 1: not to answer. See declaration of Sigurd McAuley McAuley declaration
41:35
Speaker 1: at Exhibit one. The result was that a number of
41:39
Speaker 1: points throughout her deposition, defendant refused to answer questions about
41:43
Speaker 1: subjects integral to this lawsuit, including questions about what the
41:47
Speaker 1: alleged massage therapists were doing at Jeffrey Epstein's house and
41:51
Speaker 1: the sexual nature of those massages. For example, the defendant
41:55
Speaker 1: refused to answer questions about whether she had given Jeffrey
41:58
Speaker 1: Epstein a massage? Question have you ever given Jeffrey Epstein
42:02
Speaker 1: a massage? Pagliuca? Subject to the form and foundation, and
42:07
Speaker 1: I'm going to instruct you not to answer that question.
42:09
Speaker 1: I don't have any problem with you asking questions about
42:12
Speaker 1: what the subject matter of this lawsuit is, which would be,
42:16
Speaker 1: as you've termed it, sexual trafficking of Miss Roberts. To
42:20
Speaker 1: the extent that you were asking for information relating to
42:23
Speaker 1: any consensual adult interaction between my client and mister Epstein.
42:27
Speaker 1: I'm going to instructor not to answer because it's not
42:30
Speaker 1: part of this litigation and it's her private, confidential information
42:33
Speaker 1: not subject to this deposition. McCauley, you can instruct her
42:38
Speaker 1: not to answer. That is your right, but I will
42:40
Speaker 1: bring her back for another deposition because it is part
42:43
Speaker 1: of the subject matter of this litigation. So she should
42:46
Speaker 1: be answering these questions. This is civil litigation deposition and
42:51
Speaker 1: she should be responsible for answering these questions. Pagliuka, I disagree,
42:56
Speaker 1: and you understand the bounds that I put on it. McCauley, No,
42:59
Speaker 1: I don't. I will continued to ask my questions and
43:01
Speaker 1: you can continue to make your objections. Question did you
43:06
Speaker 1: ever participate from the time period of nineteen ninety two
43:09
Speaker 1: to two thousand and nine, did you ever participate in
43:12
Speaker 1: a massage with Jeffrey Epstein and another female? Pagliuka objection.
43:16
Speaker 1: Do not answer that question again to the context you
43:19
Speaker 1: are asking for some sort of legal activity, as you've
43:22
Speaker 1: construed in connection with this case. I don't have any
43:24
Speaker 1: problem with you asking that question to the extent these
43:27
Speaker 1: questions involve consensual acts between adults. Frankly, there are none
43:31
Speaker 1: of your business, and I will instruct the witness not
43:34
Speaker 1: to answer. Miss McCauley. This case involves sexual trafficking sexual abuse.
43:38
Speaker 1: Questions about her having interactions with other females is relevant
43:42
Speaker 1: to this case. She needs to answer these questions. Pagliuka,
43:46
Speaker 1: I'm instructing her not to answer, McCauley, then we'll be
43:49
Speaker 1: back here again. Defendant's participation in massages with Epstein is
43:54
Speaker 1: a central part of this case. Miss Roberts has explained
43:57
Speaker 1: that during her first sexual encounters with Jeffrey Epa Epstein,
44:00
Speaker 1: it was defendant who provided instruction on how to do
44:03
Speaker 1: it and how to turn the massage into a sexual event. Obviously,
44:07
Speaker 1: proof that the defendant had previously massage Epstein include massages
44:12
Speaker 1: with sexual component would provide important corroboration for Miss Robert's
44:16
Speaker 1: testimony at trial, and proof that defendant was involved in
44:20
Speaker 1: massages will further help prove that statements to the press
44:25
Speaker 1: that Virginia's allegations were obvious lies was itself an obvious lie.
44:30
Speaker 1: As another example, defendant refused to answer questions about her
44:34
Speaker 1: knowledge that Johanna Schoberg was hired to work for Epstein
44:37
Speaker 1: and provide massages. In the police report, Johanna admitted that
44:41
Speaker 1: Maxwell recruited her to work for Epstein. C. McCauley declaration
44:45
Speaker 1: at Exhibit three, Yet during defendant's deposition, she refused to
44:50
Speaker 1: answer questions regarding Johanna Schoberg. Question do you know what
44:54
Speaker 1: task Johanna was hired to perform? Answer? She was tasked
44:58
Speaker 1: to answer telephones. Did you ever ask her to rub
45:01
Speaker 1: Jeffrey's feet? Answer? I believe that I have read that,
45:04
Speaker 1: but I don't have any memory of it. Did you
45:08
Speaker 1: ever tell Johanna that she would get extra money if
45:10
Speaker 1: she provided Jeffrey with a massage? Answer? I always am
45:16
Speaker 1: happy to give career advice to people, and I think
45:18
Speaker 1: that becoming somebody in the healthcare profession, either exercise instructor
45:22
Speaker 1: or nutritionist or professional massage therapist, is an excellent job opportunity.
45:27
Speaker 1: Hourly wages are around seven eight nine dollars an hour,
45:30
Speaker 1: and as a professional health care provider, you can earn
45:33
Speaker 1: somewhere between as we have established one hundred to two
45:37
Speaker 1: hundred dollars, and to be able to travel and have
45:40
Speaker 1: a job that pays that is wonderful opportunity. So, in
45:43
Speaker 1: the context of advising people for opportunities for work, it's
45:47
Speaker 1: possible that I would have said that she should explore
45:50
Speaker 1: that as an option. Did you ever tell her that
45:53
Speaker 1: she would get extra money if she massaged Jeffrey? Answer
45:56
Speaker 1: I'm just saying I cannot recall the exact conversation. I
45:59
Speaker 1: give your advice and I have done that. Question did
46:03
Speaker 1: you ever have Johanna massage? You? Answer? I did? Question
46:07
Speaker 1: how many times? Answer? I don't recall how many times?
46:11
Speaker 1: Question with sex involved? Answer no, question did you ever
46:15
Speaker 1: have sexual contact with Johanna Pagliuca? Object to the form
46:18
Speaker 1: and foundation. You need to give me an opportunity to
46:21
Speaker 1: get in between the questions anything that involves consensual sex
46:25
Speaker 1: on your part. I'm instructing you not to answer question
46:28
Speaker 1: did you ever have sex with Johanna Pakliuka? Again, she
46:32
Speaker 1: is an adult question. I'm asking you, did you ever
46:35
Speaker 1: have sexual contact with Johanna? Answer I've been instructed not
46:39
Speaker 1: to answer question on what basis? Answer you have to
46:43
Speaker 1: ask my lawyer here. Again, this information is critical to
46:47
Speaker 1: the case. Among other things, these questions are designed to
46:50
Speaker 1: show how a modus operundi for Epstein and Maxwell, specifically,
46:54
Speaker 1: how they recruited for a non sexual massage then converted
46:58
Speaker 1: the massage into sexual activity. One last illustration comes from
47:02
Speaker 1: defendant's refusal to answer about her knowledge of Epstein's sexual
47:06
Speaker 1: interests during massages. Question does Jeffrey like to have his
47:10
Speaker 1: nipples pinch during massage encounters. Pagliuca objection to Foreman foundation answer,
47:16
Speaker 1: I'm not referring to any advice on my counsel. I'm
47:19
Speaker 1: not talking about any adult sexual things when I was
47:22
Speaker 1: with them. Question when Jeffrey would have a massage, what
47:25
Speaker 1: do you request that the messuse pinches nipples while he
47:29
Speaker 1: was having his massage? Answer, I'm not talking about anything
47:32
Speaker 1: with consensual adult situations. While Epstein himself might also provide
47:37
Speaker 1: answers to these questions, it appears likely that he will
47:41
Speaker 1: assert his Fifth Amendment privilege regarding his sexual activities. Accordingly,
47:45
Speaker 1: Miss Roberts must pursue questioning of Maxwell to obtain information
47:50
Speaker 1: on this subject. Here Again, information about Epstein's sexual idio
47:54
Speaker 1: sequencies will provide important corroboration to Miss Roberts's testimony that
47:59
Speaker 1: she had sexual interactions of an identical nature with Epstein.
48:03
Speaker 1: These refusals are not an isolated incident. Instead, similar refusals
48:09
Speaker 1: to answer questions occurred repeatedly throughout the deposition. The court
48:13
Speaker 1: should compelled defendant to answer these questions. In addition to
48:16
Speaker 1: the specific points made above, the big picture here reveals
48:20
Speaker 1: how vital such discovery is as the core of Miss
48:23
Speaker 1: Robert's allegations is the allegation that the defendant lured her
48:27
Speaker 1: into a sexual situation with the offer of a job
48:30
Speaker 1: making money as a massage therapist, with Epstein always habitually
48:35
Speaker 1: tried to turn massages into sex. This was his m
48:38
Speaker 1: O and plan all along, and that Maxwell recruited other
48:41
Speaker 1: females for ostensibly proper position such as therapeutic massage, with
48:47
Speaker 1: knowledge that the intent was for that person would be
48:50
Speaker 1: pressured to provide sexual gratification to Epstein as a result.
48:54
Speaker 1: Epstein's use of massages for sexual purposes is a central
48:57
Speaker 1: part of this case, and Defendant's role in those massages
49:02
Speaker 1: and knowledge of the purpose of those massages is a
49:05
Speaker 1: critical piece of evidence showing her state of mind when
49:08
Speaker 1: she attacked. Miss Roberts assertions as entirely untrue. Miss Roberts
49:12
Speaker 1: intends to prove a trial that defendant knew full well
49:15
Speaker 1: the sexual purpose for which he was recruiting females, including
49:19
Speaker 1: underage females like Miss Roberts. Miss Roberts is entitled to
49:23
Speaker 1: explore the defendant's knowledge of the sexual activities that took
49:26
Speaker 1: place under the guy's massages. Otherwise, defendant will be able
49:30
Speaker 1: to betray to the jury an inaccurate picture of what
49:35
Speaker 1: was happening at Epstein's house, and that was nothing more
49:38
Speaker 1: than run of the mill massage therapy. Question. Did the
49:41
Speaker 1: pay for the massage therapists vary on what sexual acts
49:45
Speaker 1: they performed? Answer? No, It varied depending on how much time.
49:49
Speaker 1: Some massage therapists charge more and some charge less. Defendant's
49:54
Speaker 1: refusal to answer questions about alleged adult consensual sex also
49:58
Speaker 1: blocks Miss Roberts from seeking the jgitimate discovery in the case.
50:02
Speaker 1: By refusing to answer questions about her and Epstein's sexual
50:04
Speaker 1: activities with alleged adults, defendant is essentially given the ability
50:09
Speaker 1: to refuse to answer any sexual question she does not
50:13
Speaker 1: wish to answer. Defendant simply has to deem the question
50:16
Speaker 1: as involving consensual adult sex and no more need to
50:20
Speaker 1: be given. The result is to leave Miss Roberts with
50:23
Speaker 1: no way of exploring the identity of all these alleged adults,
50:27
Speaker 1: the ages of these alleged adults, and indeed whether they
50:31
Speaker 1: were adults at all. This allows the defendant to claim
50:35
Speaker 1: that she is unaware of any sexual activity involving underage females.
50:40
Speaker 1: Because she claims the only sexual activity she was aware
50:42
Speaker 1: of involved adults, the court should can tell Miss Maxwell
50:46
Speaker 1: to answer all questions about her knowledge relating to sexual
50:50
Speaker 1: activities with Epstein and other females while at Epstein's various homes.
50:54
Speaker 1: See fed Our Crime p. Dot thirty seven A three
50:58
Speaker 1: b I le versus AI Tech Number zero nine SIV
51:03
Speaker 1: nine six two lak MHD twenty ten w L one
51:08
Speaker 1: five four five eight five at twenty SDN Y April twelfth,
51:12
Speaker 1: twenty ten. Under federal rules, when a party refuses to
51:16
Speaker 1: answer a question during a deposition, the questioning party may
51:20
Speaker 1: subsequently move to compel disclosure of the testimony that it sought.
51:24
Speaker 1: The court must determine the propriety of the deponent's objection
51:28
Speaker 1: to answering the questions, and can order the deponent to
51:32
Speaker 1: provide improperly withheld answers during a continued deposition. Of course,
51:37
Speaker 1: the party objecting to discovery must carry the burden of
51:40
Speaker 1: proving the validity of its objections, particularly in light of
51:44
Speaker 1: the broad and liberal construction afforded the federal discovery rules.
51:49
Speaker 1: John Wiley and Sons Incorporated, First book Dog books LLC.
51:53
Speaker 1: Two ninety eight FRD one eighty four one eighty six,
51:56
Speaker 1: SDN Y twenty fourteen. For purposes of a deposition, the
52:02
Speaker 1: information sought need to be admissible at the trial if
52:05
Speaker 1: the discovery appears reasonably calculated to lead to the discovery
52:09
Speaker 1: of admissible evidence. Chen Oster versus Goldman Saxon Company, two
52:14
Speaker 1: ninety three fr D five point fifty seven five sixty one,
52:18
Speaker 1: SDNY twenty thirteen. Defendant cannot carry her burden of showing
52:23
Speaker 1: that the questions asked are not reasonably calculated to lead
52:26
Speaker 1: to the discovery of admissible evidence. This is a case
52:29
Speaker 1: in which sexual activities lie at the heart of the
52:32
Speaker 1: issues in dispute. As a result, it is hardly surprising
52:36
Speaker 1: to find that discovery pertains to allege the adult sexual
52:40
Speaker 1: activities and questions about such subjects are entirely proper ceeeg.
52:45
Speaker 1: Condit versus Done two twenty five fr D one hundred
52:49
Speaker 1: one thirteen, SDNY two thousand and four. In defamation case,
52:53
Speaker 1: plaintiff is hereby order to answer questions regarding a sexual
52:57
Speaker 1: relationship in so far as they are relevant to a
53:00
Speaker 1: defense of substantial truth, mitigation of damages, or impeachment of
53:05
Speaker 1: the plaintiff Weber versus Multimedia Entertainment Incorporated. Number ninety seven
53:10
Speaker 1: CIV zero six A two pkl THHK nineteen ninety seven,
53:15
Speaker 1: WL seven two nine zero three nine at three, SDN Y,
53:20
Speaker 1: November twenty four, nineteen ninety seven. While discovery is not
53:24
Speaker 1: unlimited and may not unnecessarily intrude into private matters, in
53:29
Speaker 1: the instant case, inquiry into private matters is clearly relevant
53:33
Speaker 1: to the subject matter of the suit. Accordingly, Plaintiff Misty
53:36
Speaker 1: Weber shall respond to defendants interrogatories concerning her sexual partners.
53:42
Speaker 1: Generally speaking, instructions from attorneys to their clients not to
53:45
Speaker 1: answer questions at a deposition should be limited to issues
53:49
Speaker 1: regarding privilege morales versus z Ondo Incorporated. Two four FRD
53:55
Speaker 1: fifty fifty four SDNY two thousand and one. In this case,
53:59
Speaker 1: the defence counsel ranged far beyond the normal parameters of
54:03
Speaker 1: objections and sought to decide for himself what issues were relevant.
54:08
Speaker 1: That was improper, and the court should order a resumption
54:11
Speaker 1: of the defendant's deposition so that she can answer questions
54:14
Speaker 1: about her knowledge of sexual activity relating to Jeffrey Epstein. Conclusion,
54:19
Speaker 1: defendant should be ordered to sit for a follow up
54:22
Speaker 1: deposition and directed to answer questions regarding her knowledge of
54:26
Speaker 1: alleged adult sexual activity. Respectfully submitted by Sigrid McAuley, and
54:32
Speaker 1: this was dated on May fifth, twenty sixteen. All Right, folks,
54:36
Speaker 1: that's going to do it for this one. All of
54:38
Speaker 1: the information that goes with this episode can be found
54:41
Speaker 1: in the description box.