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Mega Edition: Maxwell's Undisputed Statement Of Facts Pursuant To Virginia's Allegations (5/30/26) · The Epstein Chronicles

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Speaker 1: What's up, everyone, and welcome back to the Epstein Chronicles.
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In this episode, we're going to dive into some more
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court documents and we're going to start taking a look
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at Laine Maxwell's reply to Virginia Roberts disputing her soul
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called undisputed facts. So let's get busy. Case number fifteen
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dash CB DASH zero seven four three three dash RWs
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Virginia Roberts versus Glaiinne Maxwell. The defendants replied a plaintiff
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Statement of contested facts and Plaintiff's undisputed facts pursuing to
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Local Civil Rule fifty six dot one. Pursuing to Rule
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fifty six point one of the local Civil Rules of
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this Court, Dependent Gallain Maxwell submits this reply to a
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plaintiff Statement of contested Facts and Plaintiff's undisputed facts Response
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Document five eighty six Dash one Introduction. Plaintiff's response fails
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under both the federal rules of evidence and the local
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civil rules of procedures. First, plaintiff largely failed to provide
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any citation to evidence which would be admissible to challenge
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defendant statement of material undisputed facts, and therefore miss Maxwell's
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undisputed facts should be deemed admitted. Second, rather than set
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forth additional material facts as to which it is contended
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that there exists a genuine issue to be tried Local
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Civil Rule fifty six Dot one B, Plaintiff instead set
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forth her own purportedly undisputed facts. Because plaintiff did not
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cross move for some rejudgment, her supposedly undisputed facts are
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not permitted by the rules and should be stricken Section one.
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Miss Maxwell's reply in supportive statement of undisputed facts one
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undisputed fact number one. In early twenty eleven, plaintiff, in
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two British tabloid interviews, made numerous false and defamatory allegations
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against Miss Maxwell. In the articles, plaintiff made no direct
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allegations that missus Maxwell was involved in any improper conduct
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with Jeffrey Epstein, who had pleaded guilty in two thousand
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and seven to procuring a minor for prostitution. Nonetheless, plaintiff
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suggested that miss Maxwell work with Epstein and may have
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known about the crime for which he was convicted Examples
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A and B. Reply Plaintiff cites no admissible evidence to
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contest these undisputed facts. McAuley Example thirty four. In an
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email from Sharon Churchard, a plaintiff. It is Miss Churcher's
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hearsay and therefore inadmissible in any event. It does not
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speak to the contents of Plaintiff's interviews with Churcher. McAuley declaration.
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Example thirty one is an FBI interview, also in admissible hearsay,
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which again does not describe plaintiff's interviews in news articles.
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In the absence of contrary evidence, undisputed fact one should
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be deemed admitted. Two undisputed fact number two. In the articles,
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plaintiff alleged she had sex with Rince Andrew, a well
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known businessman, a world renowned scientist, a respected liberal politician,
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and a foreign head of state. Examples A through B
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at five a reply. Plaintiff does not contest these facts,
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and they therefore should be deemed admitted. Three undisputed fact three.
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In response to the allegation, Miss Maxwell's British attorney, working
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with mister Gow, issued a statement on March ninth, twenty eleven,
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denying the various allegations about Miss Maxwell that have appeared
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recently in the media. These allegations are entirely false. Example
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C A reply Plaintiff denies that mister Barden issued a
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statement but offers no admissible evidence to refute this point. Further,
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she acknowledged that the statement was issued by Devonshire solicitors
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mister Barden's law firm four undisputed fact four. The statement
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read and full, London, March tenth, twenty eleven. Gallaiine Maxwell
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denies the various allegations about her that have appeared recently
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in the media. These allegations are entirely false. It is
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unacceptable that letters sent by Miss Maxwell's legal representatives to
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certain newspapers pointing out the truth and asking for the
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allegations to be withdrawn have simply been ignored. In the circumstances,
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Miss Maxwell is now proceeding to take legal action against
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those newspapers. I understand that newspapers need to sell copies.
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It is well known that certain newspapers live by the
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adage why let truth get in the way of a
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good story. However, the allegations made against me are abhorrent
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and are entirely untrue, and I ask that they stop,
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said Glainne Maxwell. A number of newspapers have shown a
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complete lack of accuracy in their reporting of this story,
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and a failure to carry out the most elementary investigation
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or any real due diligence. I am now taking action
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to clear my name, she said a reply, Plaintiff does
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not dispute the contents of the twenty eleven statement, and
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therefore it should be deemed admitted five undisputed fact number
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five Plaintiff's gratuitous and lurid accusations. In an unrelated action.
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In two thousand and eight, to alleged victims of Epstein
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brought an action under the Crime Victim's Rights Act against
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the United States Government purporting to challenge Epstein's plea agreement.
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They alleged that the government violated their CVR rights by
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entering into an agreement example d at two. A reply
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Plaintiff stipulates to the facts contained in paragraph five, and
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therefore they should be deemed admitted number six undisputed fact
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number six. Seven years later, on December thirtieth, twenty fourteen,
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Miss Roberts moved to join the CVR action, claiming she
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too had her CVR rights violated by the government. On
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January first, twenty fifteen, Miss Roberts filed the corrected joinder
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motion example d at one to nine. Reply plaintiff agreed
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to this paragraph seven Undisputed Fact number seven. The issue
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presented in her joint her motion was narrow whether she
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should be permitted to join the CVRA action as a
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party under Federal Rule of Civil Procedure twenty one, specifically
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whether she was a known victim of mister Epstein and
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the government owed them CVRA duties. Yet, the bulk of
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emotion consists of copious factual details that plaintiff and her
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co movement would prove if allowed to join. Miss Roberts
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gratuitously included provocative and lurid details of her alleged sexual
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activities as an alleged victim of sexual trafficking. A reply,
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plaintiff does not dispute that Judge Marra made the findings
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detailed in Undisputed Fact seven. Further, she admits that the
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government refused to stipulate that she had been sexually abused
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by Jeffrey Epstein and his co conspirators, including co conspirator
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Alan Dershowitz, which would make her a victim of a
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broad set trafficking conspiracy. Although she now admits there were
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other reasons for inclusion of such lurid details, those reasons
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were rejected by Judge Mara, as she does not offer
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any admissible evidence to contradict the findings made by Judge Marra.
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This fact, specifically, Judge Mara's findings should be deemed admitted.
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In any event, we request under Federal rule evid. Two
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one c two that the Court take judicial notice of
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the contents of Judge Mara's ruling and disorder number eight
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undisputed fact number eight. At the time they filed the motion,
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Miss Roberts and her lawyers knew that the media had
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been following the Epstein criminal case and the CVRA action.
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While they deliberately filed the motion without disclosing Miss Roberts's name,
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claiming the need for privacy and secrecy, they made no
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attempt to file the motion under seal. Quite the contrary,
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they filed the motion publicly example d at one and one.
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A reply. Plaintiff offers no admissible evidence to refute these facts,
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and they therefore should be deemed admitted. Specifically, she does
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not offer any evidence to dispute that she knew the
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media had been following Epstein and the CVRA action, nor
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does she dispute that her attorneys made no attempt to
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file the motion under seal rather filing it publicly. The
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facts are thus admitted number nine undisputed Fact number nine.
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As the District Court noted in ruling on the joint
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or motion, miss Roberts names several individuals, and she offers
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details about the type of sex acts performed and where
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they took place. The Court ruled that these lurried details
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are unnecessary. The factual details regarding whom and where the
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jane those engaged in sexual activities are immaterial and impertinent,
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especially considering that these details involved non parties who were
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not related to the respond in government. Accordingly, these unnecessary
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details shall be stricken struck all of Miss Roberts's factual
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allegations relating to her alleged sexual activities and her allegations
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of misconduct by non parties. The Court said the striking
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of the lurid details was a sanction for Miss Roberts
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in proper inclusion of them in the motion. A reply
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plaintiff offers no admissible evidence to refute these facts, and
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they therefore should be deemed admitted. See Reply to Undisputed
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Fact seven, Supra. In any event, we request under Federal
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rule of evidence two one c two, that the Court
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take judicial notice of the contents of Judge Marra's ruling
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and disorder number ten undisputed Fact number ten. The District
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Court found not only that the lurid details were unnecessary,
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but also that the entire joinder motion was entirely unnecessary.
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Miss Roberts and her lawyers knew the motion, with all
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its lurid details was unnecessary because the motion itself recognized
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that she would be able to participate as a fact
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witness to achieve the same result she sought as a party.
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The Court denied Plaintiff's joined or motion id at seven
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through ten number eleven undisputed Fact number eleven. One of
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the non parties Miss Roberts named repeatedly in the joinder
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motion was Miss Maxwell. According to the lurid details of
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Miss Roberts included in the motion, Miss Maxwell personally was
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involved in a sexual abuse and a sex trafficking scheme
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created by Epstein. Miss Maxwell approached plaintiff in nineteen ninety nine,
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when plaintiff was fifteen years old, to a recruiter into
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the scheme. Miss Maxwell was one of the main women
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Epstein used to procure underage girls for sexual activities. Miss
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Maxwell was a primary co conspirator with Epstein in his scheme.
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She persuaded plaintiff to go to Ebstein's mansion in a
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fashion very similar to the manner in which Epstein and
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his other co conspirators coerced dozens of other children at
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the mansion. When plaintiff began to giving Epstein a massage,
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he and Miss Maxwell turned it into a sexual encounter. Epstein,
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with the assistance of Miss Maxwell, converted plaintiff into a
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sex slave. Plaintiff was a sex slave from about nineteen
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ninety nine through two thousand and two. Miss Maxwell also
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was a co conspirator in Epstein's sexual abuse. Miss Maxwell
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appreciated the immunity she acquired under Epstein's plea agreement because
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the immunity protected her from prosecution from the crimes she committed.
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In Florida, Miss Maxwell participated in the sexual abuse of
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plaintiff and others. Miss Maxwell took numerous sexually explicit pictures
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of underage girls involved in sexual activities, including the plaintiff.
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She shared those photos with Epstein as part of her
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role in Epstein's sexual abuse ring. Miss Maxwell connected Epstein
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with powerful individuals so that Epstein could traffick Plaintiff to
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these persons. Plaintiff was forced to have sexual relations with
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Prince Andrew in Miss Maxwell's apartment in London. Miss Maxwell
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fillitated Plaintiff sex with Prince Andrew by acting as a
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madam for Epstein. Miss Maxwell assisted in internationally trafficking Plaintiff
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and numerous other young girls for sexual purposes. Plaintiff was
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forced to watch Epstein, Miss Maxwell, and others engage in
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illegal sexual acts with dozens of underage girls. Reply, Plaintiff
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offers no admissible evidence to refute the facts actually stated
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in the paragraph ie the lurid details as coined by
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Judge Marra were included in her CVRA jointerer motion. Plaintiff
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claims to offer admissible evidence to corroborate the statements she
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made in the joint motion. Setting aside for the moment
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that most of the cited documents are inadmissible hearsay. As
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addressed later, such evidence should be disregarded because none of
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the offered documents speak to fact that these lurid details
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were actually included in the joint motion, as a simple
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reading of example D reveals, because plaintiff does not refute
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that point. The fact that the details were in the
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joinder motion should be deemed admitted. In any event, we
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request under Federal Rules of Evidence Tool one C two
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that the Court take judicial notice of the contents of
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plaintiffs cvra joinder motion. All right, folks, we're going to
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wrap up right there, and in the next episode we'll
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pick up where we left off. What's up, everyone, and
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welcome back to the Epstein Chronicles. We're gonna pick back
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up with Glan Maxwell's response to Virginia Roberts response to
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Glan Maxwell's undisputed facts number twelve. Undisputed fact number twelve
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In the joinder motion, plaintiff also alleged she was forced
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to have sex with the Harvard professor Alan Dershowitz, model
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scout Jean Luke Brunel, and many many other powerful men,
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including numerous prominent American politicians, powerful business executives, foreign presidents,
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a well known prime minister, and other world leaders. A reply, again,
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plaintiff offers no evidence that these lurid details were included
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in the joint or motion, as indeed they were, and
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thus the fact that they were should be deemed admitted.
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Thirteen undisputed fact number thirteen. Plaintiffs said, after serving for
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four years as a sex slave, she managed to escape
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to a foreign country and hide out from Epstein and
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his co conspirators for years. Reply. Plaintiff does not dispute
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that she made the statement in her joint or motion,
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and it is admitted Number fourteen. Undisputed fact Number fourteen.
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Plaintiffs suggested the government was part of Epstein's conspiracy when
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it secretly negotiated a non prosecution agreement with Epstein precluding
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federal prosecution of Ebstein and his co conspirators. The government secrecy,
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plaintiff alleged, was motivated by its fear that plaintiff would
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raise powerful objections to the agreement that would have shed
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tremendous public light on Epstein and other powerful individuals. Reply.
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Plaintiff does not contest the quoted contents of the joint
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or motion, but rather offers argument regarding plaintiff's purported belief.
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Plaintiff did not submit an affidavid attesting to such belief,
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and therefore no admissible evidence was cited or offered. The
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facts should therefore be deemed admitted fifteen Undisputed fact Number
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fifteen Notably, the other Jane Doe, who joined Plaintiff's motion,
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who alleged she was sexually abused on many occasions by Epstein,
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was unable to corroborate any of Plaintiff's allegations Ideas seven
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and eight. Reply. Plaintiff states the facts are untrue, but
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offers no admissible evidence to support that statement. She has
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no Avid David or other statement from the other Jane Doe,
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who was represented by Plaintiff's council and therefore had the
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ability to furnish such an Avidavid. Indeed, Plaintiff acknowledges that
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the other Jane Doe does not know Miss Roberts these
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facts must be deemed admitted redacted. Who is not the
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other Jane Doe, is a relevant to the undisputed fact asserted.
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She also offers no corroboration of the same pattern of abuse,
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and in fact does not remember any such facts, as
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already briefed see Document five sixty seven at twelve through
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fourteen sixteen Undisputed Fact sixteen. Also, notably, in our multiple
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and lengthy consensual interviews with Miss Churcher three years earlier,
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Plaintiff's told Miss Churcher of virtually none of the details
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she described in the joinder motion. A reply Plaintiff's protestations
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aside the Churcher articles attached to Miss churchers sworn affidavit
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filed in this case at document two sixteen and two
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sixteen one through two sixteen and two eighteen failed to
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include the vast majority of details included in Plaintiff's CVR
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joinder motion, as any side by side comparison will reveal.
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Plaintiff's simple facile responses is that she did reveal details
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in twenty eleven consistent with those in the joinder motion.
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She offers no admissible evidence of these details she revealed
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to Miss Churcher, instead citing to a heavily redacted interview
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she purportedly gave to the FBI, not Miss Churcher. The
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purported FBI report in itself is hearsay, not to mention,
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redacted and prepared years after any supposed interview of plaintiff
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mcaulay Declaration example thirty one. Because plaintiff offers no admissible
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evidence to contradict the discrepancies between the Churcher articles and
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the joint or motion, these facts should be deemed admitted.
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Number seventeen undisputed Fact seventeen. Miss Maxwell's response to Plaintiff's
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lurid accusations. The January twenty fifteen statement, as plaintiff and
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her lawyers expected before District Judge Mara in the CVRA action,
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could strike the lurid details of Plaintiff's allegation in the
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joint or motion. Members of the media obtain copies of
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the motion. Example g a reply Saintiff cites no country
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evidence and therefore the fact should be deemed admitted eighteen.
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Undisputed Fact number eighteen. At mister Barden's direction, on January second,
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twenty fifteen, mister Gales sent to numerous representatives of British
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media organizations an email containing a quotable statement on behalf
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of Miss Maxwell. The email was sent to more than
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six and probably less than thirty media representatives. It was
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not sent to non media representatives, a reply plaintiff disputes
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as blaine falsehood without admissible evidence that it was mister
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Barden who directed that the January second emails be sent
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to media organizations. She then goes on to quote the
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very section of mister Gales's deposition in which he surmises
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but does not know indicated by his statement, it was
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his understanding that it was something that had been sent
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to Maxwell by Barden. Indeed, mister Barden clears up this
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confusion in his declaration and in which he unequivocally swore
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number ten. In liaison with mister Goo and my client,
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on January two, twenty fifteen, I prepared a further statement
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denying the allegations, and I instructed mister Goo to transmit
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it via email to members of the British media who
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had made inquiry about plaintiff's allegations about Miss Maxwell. Attached
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as Exhibit A one is an email containing a true
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and correct copy of this statement. The statement was issued
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on my authority, although it is possible others suggested or
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contributed content. I prepared the vast majority of the statement
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and ultimately approved and adopted all of the statement as
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my work. Ten. Mister Goo surmises as to how the
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statement was forwarded to him and by whom does not
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controvert the sworn testimony of mister Bardon himself. Again without
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admissible evidence to the contrary, the facts must be deemed admitted.
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With regard to the number of media representatives to whom
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he sent the email. Mister Gales f it was between
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six and thirty. His further testimony offered by plaintiff that
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he spoke to over thirty journalists does not contradict that statement.
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Nowhere does plaintiff offer testimony that he read the statement
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to over thirty journalists. Instead, mister gal acknowledged it was
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very possible that he had ever read the statement to
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press or media over the phone, not that he read
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it to over thirty journalists. Plaintiffs selective cutting and pasting
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undercuts her so called evidence that the facts in paragraph
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eighteen are false and thus they ought to be deemed
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admissible nineteen undisputed fact number nineteen. Among the media representatives
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were Martin Robinson of The Daily Mail, p Peachey of
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The Independent, Nick Summerland of The Mirror, David Brown of
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The Times and Nick Always and Joe Anne Pew of
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the BBC, and David Mercer of the Press Association. These
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representatives were selected based on their request after the jointer
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motion was filed for a response from Miss Maxwell to
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Plaintiff's allegations in the motion a reply. While plaintiff decries
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the second sentence is false, her cited evidence contradicts her conclusion.
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Mister Gou testified that anytime there was an incoming query,
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it was either dealt with on the telephone by referring
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them back to the two statements, or someone would email
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them the statement, so no one was left unanswered mcauleay
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declaration example six. As his testimony makes clear, mister Gow
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sent the statement to those journalists who made inquiry. He
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did not send it to anyone who did not. Based
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on the admissible evidence, this fact remains undisputed number twenty.
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Undisputed fact number twenty. The email to the media members read,
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please find detached the quotable statement on behalf of Miss Maxwell.
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No further communication will be provided by her on this matter.
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Thanks for your understanding, Best Ross Jane Doe. Three is
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Virginia Roberts, so not a new individual. The allegations made
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by Victoria Roberts against Glaine Maxwell are untrue. The original
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allegations are not new and have been fully responded to
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and shown to be untrue. Each time the story is retold,
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it changes with new salacious details about public figures and
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world leaders. And now it is alleged by miss Roberts
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that Alan Dershowitz is involved in having sexual relations with her,
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which he denies. Miss Roberts claims are obvious lies and
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should be treated as such and not publicized as news
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as they are defamatory. Glainne Maxwell's original response to the
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lives and defamatory claims remains the same. Maxwell strongly denies
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allegations of an unsavory nature which have appeared in the
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British press and elsewhere, and reserves her right to seek
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redress at the repetition of such old defamatory claims. Reply
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Plaintiff does not dispute the contents of the email, and
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therefore it should be deemed admitted. Twenty one undisputed fact
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Number twenty one. Mister Barden, who prepared the January twenty
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fifteen statement, did not intend it as a traditional press
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release solely to disseminate information to the media, so he
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intentionally did not pass it through a public relations firm
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such as mister Gal's firm Acuity Reputation. Reply Plaintiff makes
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two responses as to the first sentence. She asserts, without
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evidentiary support, the court should not consider the Barton declaration.
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This argument is frivolous for the reasons given on pages
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eight eleven. And twelve and eighteen nineteen of reply brief
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in support of motion for some rejudgment. It is a
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declaration provided by an attorney with knowledge of the facts
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mister Barden disclosed by defendant in a rule twenty six
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witnesses whom Plaintiff chose not to depose. As to the
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second sentence, Plaintiff offers two pieces of evidence which she
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argues disputes the facts in question. They do not. That
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mister Goll forwarded the statement prepared by mister Barden to
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the media is not disputed. Rather, as mister Barden asserted
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in his declaration, and Plaintiff failed to cite contradictory evidence,
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he was the one who prepared the vast majority of
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the statement and instructed mister Goll to transmit it via
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email to members of the British media. He likewise averse
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that he did not intend the January twenty fifteen statement
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as a traditional press release solely to disseminate information to
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the media. This is why I intentionally did not request
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that mister Goo or any other public relations specialists prepare
24:39
or participate in preparing the statement. Plaintiff fails to contradict
24:43
mister Barden Sworn's statement Undisputed Fact Number twenty two. The
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January twenty fifteen statement served two purposes. First, mister Bardon
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intended that it mitigate the harm to Miss Maxwell's reputation
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from the press republication of plaintiff's false out He believed
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these ends could be accomplished by suggesting to the media that,
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among other things, they should subject plaintiff's allegations to inquiry
25:09
and scrutiny. For example, he noted in the statement that
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plaintiff's allegations change dramatically over time, suggesting that their obvious
25:18
lies and therefore should not be publicized as news. Reply,
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this paragraph, eliciting mister Barden's intent, is uncontroverted by plaintiff.
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She fails to cite any contradictory admissible evidence, instead making
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legal arguments. Her arguments are not admissible evidence e g.
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It is her statement, and she directed that it be
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sent to the media in public, lacks any citation to
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record evidence. Plaintiff's list of evidence, she contends corroborates Plaintiff's
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claims should be ignored as they do not pertain to
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mister Barden's purposes. In drafting the January second statement, all right, folks,
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we're going to wrap up right here and in the
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next episode we'll pick up where we left off. All
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of the information that goes with this episode can be
26:03
found in the description box. What's up, everyone, and welcome
26:07
back to the Epstein Chronicles. In this episode, we're diving
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right back into the court documents and we're going to
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continue taking a look Glad Maxwell's reply to Virginia Robert's
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Statement of contested Facts and the Plaintiff's undisputed Facts Number
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twenty one. Undisputed Fact Number twenty one. Mister Barden, who
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prepared the January twenty fifteen statement, did not intend it
26:32
as a traditional press release solely to disseminate information to
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the media, so he intentionally did not pass it through
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the public relations firm, such as mister Gal's firm Acuity Reputation.
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Reply Plaintiff makes two responses. As to the first sentence,
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She asserts, without evidentiary support, that the court should not
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consider the Barden declaration. This argument is frivolous for the
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reasons given on page eight, eleven, twelve, eighteen, and nineteen
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of the reply brief in support of motion for a
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summary judgment. It is a declaration provided by an attorney
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with knowledge of the facts mister Barden disclosed by the
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defendant in her rule twenty six witnesses whom Plaintiff chose
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not to depose. As to the second sentence, Plaintiff offers
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two pieces of evidence which she argues disputes the facts
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in question. They do not that mister Gal forwarded the
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statement prepared by mister Barton to the media is not disputed. Rather,
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as mister Barden asserted in his declaration and Plaintiff felt
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to cite contradictory evidence, he was the one who prepared
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the vast majority of the statement and instructed mister Gal
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to transmit it via email to members of the British
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media example at ten. He likewise avers that he did
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not intend the January twenty fifteen statement as a traditional
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press release solely to disseminate information to the media, and
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this is why I in intentionally did not request that
28:01
mister Gow or any other public relations specialist prepare or
28:06
participate in preparing the statement. Plaintiff fails to contradict mister
28:10
Bardon's sworn statement number twenty two undisputed fact number twenty
28:15
two the January twenty fifteen statement served two purposes. First,
28:20
mister Bardon intended that it mitigate the harm to miss
28:23
Maxwell's reputation from the press's republication of plaintiff's false allegations.
28:29
He believed these ends could be accomplished by suggesting to
28:32
the media that, among other things, they should subject plaintiff's
28:36
allegations to inquiry and scrutiny. For example, he noted in
28:40
the statement that plaintiff's allegations change dramatically over time, suggesting
28:45
that their obvious lies and therefore should not be publicized
28:49
as news. Reply, this paragraph, eliciting mister Bardon's intent, is
28:55
uncontroverted by plaintiff. She fails to cite any contradictory in
28:59
missile evidence, instead making legal arguments. Her arguments are not
29:03
admissible evidence e g. It is their statement, and she
29:07
directed that it be sent to the media and public
29:10
lacks any citation to record evidence. Plaintiff's list of evidence,
29:15
she contends corroborates Plaintiff's claims, should be ignored as they
29:19
do not pertain to mister Barden's purposes. In drafting the
29:23
January second statement, undisputed Fact number twenty three, Second, mister
29:28
Barden intended the January twenty fifteen statement to be a
29:32
shot across the bow of the media, which he believed
29:35
had been unduly eager to publish Plaintiff's allegations without conducting
29:40
an inquiry of their own. Accordingly, the statement, he repeatedly
29:45
noted that Plaintiff's allegations were defamatory. In this sense, the
29:49
statement was intended as a cease and assist letter to
29:53
the media recipients, letting the media recipients understand the seriousness
29:58
with which Miss Maxwell consider the publication of Plaintiff's obviously
30:02
false allegations and the legal indefensibility of their own conduct.
30:07
Reply again, Plaintiff disputes mister Barton's intent without citation to
30:12
record evidence. Plaintiff claims that Barden did not note anything
30:16
in the statement, but the statement itself contains the phrase
30:20
Miss Roberts claims or obvious lies and should be treated
30:23
as such and not publicized as news as they are defamatory.
30:27
Plaintiff's unsupported arguments should be ignored and these facts pertaining
30:31
to mister Barden's intent deemed admitted. Fact number twenty four
30:36
consistent with two purposes. Mister Gal's emails preface the statement
30:41
with the following language. Please find attached to quotable statement
30:44
on behalf of Miss Maxwell. The statement was intended to
30:47
be a single, one time only, comprehensive response quoted in
30:51
full to Plaintiff's December thirtieth, twenty fourteen, allegations that would
30:56
give the media Miss Maxwell's response. The purpose of the
30:59
pre vatory statement was to inform the media recipients of
31:03
this intent reply. Plaintiff again disputes any statement related to
31:08
mister Barden's purpose or intent, but offers no evidence contradicting
31:12
his purpose or intent. She simply points out that Miss
31:16
Maxwell retained mister Goo in early twenty fifteen and that
31:20
he works for a public relations firm which is non
31:23
responsive to the fact that issue mister Barden's intent with
31:26
respect to language included in the statement. No one has
31:30
contested that it was mister Gow who actually forwarded this
31:33
statement to select members of the media who had requested
31:36
a response. The facts that fourth should be deemed admitted
31:41
undisputed Fact Number twenty five. Plaintiff's activities bring light to
31:45
the rights of victims of sexual abuse. Plaintiff has engaged
31:49
in numerous activities to bring attention to herself, to the
31:52
prosecution and punishment of wealthy individuals such as Epstein, and
31:57
to her claimed interest of bringing light to the rights
32:00
of victims of sexual abuse. Reply Plaintiff offers no evidence
32:05
to dispute the facts cited, and so they should be
32:08
deemed admitted. Undisputed Fact twenty six. Plaintiff created an organization,
32:14
Victims Refuse Silence, Incorporated, a Florida corporation, directly related to
32:19
her alleged experience as a victim of sexual abuse. Reply
32:24
Plaintiff does not dispute this statement. Twenty seven undisputed fact
32:28
number twenty seven. The goal of Victims Refuse Silence was
32:32
and continues to be, to help survivors surmount the shame, silence,
32:37
and intimidation typically experienced by victims of sexual abuse. Towards
32:42
this end, Plaintiff has dedicated her professional life to helping
32:46
victims of sexual trafficking. Reply Plaintiff agrees twenty eight undisputed
32:51
fact number twenty eight. Plaintiff repeatedly has sought out media
32:55
organizations to discuss her alleged experience as a victim of
32:59
sexual abuse. This reply statement at fifty one through fifty
33:04
four and two through eleven and referenced and exhibits document
33:08
two sixty one, two two sixteen and example n kk
33:13
LLL and MM reply. Plaintiff denies this contention, points to
33:18
an email from Sharon Churcher seeking to interviewer, and asserts
33:22
that it was the media that sought her out. The
33:25
weight of evidence cited by defendant at paragraphs fifty one
33:28
through fifty four, in addition to Plaintiff's own documents, belie
33:32
this assertion. She through her attorneys, sought out a videotaped
33:36
interview with ABC News. She sent her book manuscript to
33:40
publishers and literary agents, and expressed anticipation and frustration that
33:45
her exclusive contract with the Mail prevented her for a
33:48
period of time from marketing her book. Plaintiff disputed none
33:53
of these activities she freely engaged in for years, and
33:57
thus these facts should be admitted. On December thirty, twenty fourteen,
34:03
Plaintiff publicly filed an entirely unnecessary joined or motion laden
34:08
with unnecessary lurid details about being sexually abused as a
34:12
minor victim by wealthy and famous men and being trafficked
34:15
all over the world as a sex slave. Reply plaintiff
34:19
argues that her lurid details were necessarily legal. Judge Mara, however,
34:25
has already held that they were not, and her legal arguments,
34:28
unsupported by any actual evidence in this case, cannot serve
34:32
to controvert his findings. As quoted thirty the plaintiff's alleged
34:37
purpose in filing the joint motion was to vintigate her
34:40
rights under the CVRA exposed the government secretly negotiated non
34:45
prosecution agreement with Epstein, shed tremendous public light on Epstein
34:49
and other powerful individuals that would undermine the agreement and
34:53
support the cvra's plaintiff's request for documents that would show
34:58
how Epstein used as powerful political and social connections to
35:02
secure a favorable plea deal, and the government's motive to
35:05
hate Epstein and his co conspirators example d at one,
35:09
six and seven, and ten. Reply Plaintiff fails to offer
35:15
any evidence to controvert the contents of her CVRA joined
35:18
her motion, and thus the fact should be deemed admitted.
35:22
Number thirty one undisputed. Fact Number thirty one Plaintiff's written
35:27
the manuscript of a book she has been trying to publish,
35:30
detailing her alleged experience as a victim of sexual abuse
35:34
and sex trafficking. In Epstein's alleged scheme reply, plaintiff directs
35:39
the court to her response to paragraph fifty two and
35:43
suggests the factual statement is misleading. She, however, offers no
35:47
contradictory admissible evidence, and thus the fact should be deemed admitted.
35:53
Thirty two undisputed fact thirty two republication alleged by plaintiff.
35:58
Plaintiff was a required hired by Interrogatory number six to
36:02
identify any false statements attributed to miss Maxwell that were
36:06
published globally, including within the Southern District of New York,
36:10
as Plaintiff alleged and paragraphed nine of count one of
36:13
her complaint. In response, Plaintiff identified the January twenty fifteen
36:19
statement and nine instances in which various news media published
36:23
portions of the January twenty fifteen statement in news articles
36:27
or broadcast stories. Reply her arguments aside, Plaintiff offers no
36:33
admissible evidence to controvert the interrogatory request under a response
36:37
which was limited to nine instances in which the press
36:41
published portions of the January twenty fifteen statement. For example,
36:45
Plaintiff does not point to one single news story that
36:48
published the entirety of the January twenty fifteen statement. In
36:53
the absence of contrary evidence, the fact should be deemed admitted.
36:58
Thirty three. In none of the nine instances was there
37:01
any publication of the entire January twenty fifteen statement. Reply.
37:07
Plaintiff does not and cannot point to any of the
37:10
nine publications she disclosed or any of the other publications
37:14
that published the entire January twenty fifteen statement, and this
37:19
fact thus must be deemed admitted. Thirty four. Miss Maxwell
37:23
and her agents exercised no control or authority over any
37:27
media organization, including the media identified in Plaintiff's response to
37:33
Interrogatory number six in connection with the media's publication of
37:37
portions of the January twenty fifteen statement. Reply, Plaintiff profited evidence.
37:44
Testimony from mister Gal fails to support her argument and
37:47
fails to controvert the Bardon declaration as cited by the defendant.
37:52
Nothing in the testimony establishes as plaintiff argues that the
37:56
defendant hired Gal because his position allowed him to influence
38:00
the press to publish her defamatory statement. The testimony is
38:04
irrelevant to the factual point. Gal's testimony at most relates
38:08
to why miss Maxwell engaged mister Gal. It does not
38:12
bear on the factual point ie that Miss Maxwell, mister
38:15
Gal or mister Bardon did not exercise any control or
38:19
authority over the media in the media's republication of portions
38:23
of the statement. On this point, plaintiff has failed to
38:26
introduce any contrary evidence. Accordingly, the fact should be deemed admitted.
38:32
Thirty five Plaintiff's defamation action against Miss Maxwell. Eight years
38:37
after Epskein's guilty plea. Plaintiff brought this action, repeating many
38:41
of the allegations she made in her CVR. Joined her
38:44
motion reply Plaintiff agrees thirty six. The complaint alleged that
38:50
the January twenty fifteen statement contained the following deliberate falsehoods.
38:55
A that Roberts sworn allegations against Maxwell are untrue. That
39:00
the allegations have been shown to be untrue. See that
39:04
Robert's claims are obvious lies. A reply Plaintiff agreed thirty seven.
39:11
Plaintiff lived independently from her parents with her fiance long
39:15
before meeting Epstein or Maxwell. After leaving the growing together
39:19
drug rehabilitation facility. In nineteen ninety nine, plaintiff moved in
39:24
with the family of a fellow patient example l at
39:28
seven and eight and twelve through fourteen. There she met
39:31
and became engaged to her friend's brother, James Michael Ostrich
39:35
id At nineteen. She and Ostrich thereafter rented an apartment
39:39
in the Fort Lauderdale area with another friend, and both
39:43
worked at various jobs in the area. Later, they stayed
39:47
briefly with Plaintiff's parents in the Palm Beach Locksahatchie, Florida area,
39:51
before Ostrich rented an apartment for the couple on Benoak
39:55
Drive in Royal Palm Beach id at seventeen, nineteen twenty
40:00
five through twenty seven. Although plaintiff agreed to marry Ostrich,
40:05
she never had any intention of doing so. Example n
40:09
at one twenty seven and one twenty eight. Reply Plaintiff
40:14
offers argument without an affidavid or any other contradictory evidence
40:19
regarding whether a plaintiff voluntarily lived independently or whether a
40:23
reasonable person could assert that she was engaged. Mister Ostrich
40:27
and plaintiff agreed that they were engaged and testified accordingly
40:31
as cited. In the absence of admissible evidence to the contrary,
40:35
the facts as described by her fiance in his deposition
40:39
should be deemed admitted. All right, folks, we're going to
40:42
wrap up this episode right here, and in the next
40:44
episode we're going to pick up where we left off.
40:47
All of the information that goes with this episode can
40:50
be found in the description box. What's up, everyone, and
40:53
welcome back to the Epstein Chronicles. In this episode, we're
40:57
going to continue taking a look at at Gallaine Maxwell's
41:01
response to Virginia Roberts contested facts and the plaintiff's undisputed
41:07
facts Number thirty eight. Plaintiff re enrolled in high school
41:12
from June twenty first, two thousand, until March seventh, two
41:15
thousand and two. After finishing the ninth grade high school
41:19
year at Forest Hills High School on June ninth, nineteen
41:22
ninety nine, Plaintiff re enrolled at Wellington Adult High School
41:27
on June twenty first, two thousand, again on August sixteenth,
41:31
two thousand, and August fourteenth, two thousand and one. On
41:35
September twentieth, two thousand and one. Plaintiff then enrolled at
41:39
Royal Palm Beach High school. A few weeks later, on
41:41
October twelfth, two thousand and one, she matriculated at Survivor's
41:46
Charter School. Survivor's Charter School was an alternative school designed
41:50
to assist students who had been unsuccessful at more traditional schools.
41:56
Plaintiff remained enrolled at Survivor's Charter School in until March seventh,
42:01
two thousand and two. She was present fifty six days
42:05
and absent thirteen days during her time there. Plaintiff never
42:08
received her high school diploma or ged. Plaintiff and Figueroa
42:13
went back to school together at Survivor's Charter School example
42:17
p at twenty three through twenty seven. The school day
42:21
there lasted from morning until early afternoon id at twenty
42:25
three through twenty seven. Plaintiff argues, again without evidentiary support,
42:31
that the codes on the school records indicate semesters start
42:35
and end dates rather than dates plaintiff was in school.
42:39
Her misreading of the records is aparent from their face.
42:42
One column is labeled entry date and the next withdrawal date.
42:46
Neither say semester start date or semester end date. Moreover,
42:50
the codes simply prove the point plaintiff entered school codes
42:54
EO one and EA one on the designated entry date,
42:58
and withdrew either prior to completion to enter another training
43:02
program or who will continue in the class program the
43:06
next term or school year on the dates designated withdrawal.
43:10
The school records display entry and withdrawal dates for Wellington
43:14
High School Adult Program from June twenty first, two thousand
43:18
through August fifteenth, two thousand, from August sixteenth, two thousand
43:23
through August thirteenth, two thousand and one, and from August fourteenth,
43:26
two thousand and one through September twentieth, two thousand and one,
43:30
and then an entry that same day, September twentieth, two
43:34
thousand and one at Survivor's charter school. Plaintiff would have
43:38
one belief that the records show a school on Plaintiff's
43:41
official transcript that she never went to Wellington High School
43:44
Adult Program that indicates that she withdrew the very day
43:48
she concededly entered Survivor's charter school. Her intentional misreading of
43:53
the record is yet another attempt to offuscate plaintiff's lack
43:56
of memory regarding where and when she went to school,
44:00
just like she failed to remember eight jobs that she
44:03
held in two thousand, whereas she claimed to have none.
44:07
The test is admissible evidence to the country, and plaintiff
44:10
offers none. The flight logs, which show trips in early
44:13
two thousand and one do not contradict the evidence because
44:16
they are during the period of time she was enrolled
44:19
in adult high school, a place where night classes were
44:22
taught and where one might circumstantially infer careful attendance records
44:27
were not kept Fact number thirty nine during the year
44:32
two thousand. Plaintiff worked at numerous jobs. In two thousand,
44:35
while living with her fiance, Plaintiff held five different jobs
44:39
at Aviculture Breeding and Research Center, Southeast Employee Management Company,
44:44
the Club mar A Lago, Oasis Outsourcing, and Neiman Marcus.
44:48
Her taxable earnings that year totaled nearly nine thousand dollars.
44:52
Plaintiff cannot now recall either the Southeast Employment Management Company
44:57
or the Oasis Outsourcing jobs. Example at Q at four
45:01
seventy and four seventy one reply. Plaintiff does not dispute
45:06
the facts as presented, merely argues regarding their significance. The
45:10
Social Security Administration records detail the five jobs at which
45:14
she worked in two thousand. The month and day of
45:17
the jobs are irrelevant for purposes of this recitation of facts. Likewise,
45:22
plaintiff does not dispute the taxable earnings she made that year,
45:26
or that she does not remember the jobs associated without
45:30
Southeast Employment Management Company or Oasis Outsourcing, whether they were
45:35
payroll or not, where she made three thousand, two hundred
45:38
and twelve dollars and two thousand, thirty seven dollars that year.
45:42
She also forgot about the job at Neiman Marcus, where
45:45
she made one thousand, four hundred and forty dollars in
45:47
two thousand, until she was confronted with the SSA Records
45:52
mcauleay Declaration Example five number forty undisputed Fact forty. Plaintiff's
45:59
employment at mar A Lago SPA began in the fall
46:02
of two thousand. Plaintiff's father, Sky Roberts, was hired as
46:06
a maintenance worker at the mar A Lago Club in
46:08
Palm Beach, Florida, beginning on April eleventh, two thousand. Miss
46:12
Roberts worked there year round for approximately three years. After
46:16
working there for a period of time, mister Roberts became
46:20
acquainted with the head of the Spy Area and recommended
46:23
plaintiff for a job there. Mar A Lago closes every
46:26
Mother's Day and reopens on November first example you at
46:31
mar A Lago zero two one two. Most of the
46:34
employees who work at mar A Lago, including all employees
46:37
of the spa area, such as SPA attendants, are seasonal
46:40
and work only when the club is open i e.
46:42
November one and Mother's Day example t At seventy two
46:47
and seventy three. Plaintiff was hired as a seasonal SPA
46:51
attendant to work at the mar A Lago club in
46:54
the fall of two thousand, after she had turned seventeen.
46:58
The reply Plaintiffs responded, this is misleading. First, she does
47:01
not dispute that Miss Roberts and her father began working
47:05
at mar A Lago in April of two thousand, nor
47:07
that he worked there for some time, became acquainted with
47:10
the head of the spy are you, and recommended his
47:12
daughter for a job. Second, plaintiff contends that job postings
47:16
in job descriptions from two thousand and two and later
47:19
are irrelevant. There are no such job posting cited. Rather,
47:23
the job posting cited was from October two thousand, the
47:27
same time the plaintiff was hired. Compare example v posting
47:32
for Saturday, October fourteenth and Sunday October fifteenth with calendar
47:36
for year two thousand showing Saturday and Sundays in October
47:40
corresponding to those dates. Finally, plaintiff points to her own
47:44
recollection as contrary proof. Her recollection about when she worked
47:48
at mar A Lago has shifted dramatically over time. First
47:52
she claimed it was nineteen ninety eight see Jane do
47:54
one O two complaint. Then it was nineteen ninety nine
47:57
see document number one. Now in this response she has
48:01
changed her answer to two thousand. Her vague recollections about
48:05
what year have been off base. No credit should be
48:08
given to her newfound recollection of which month that she
48:12
worked there. In any event, she presents no admissible, credible
48:16
evidence to contradict mar A Lago's own records. Even Plaintiff's father,
48:21
a longtime employee of mar A Lago, admitted that the
48:24
plays closed down in the summer. Plaintiff simply is not
48:28
credible in her testimony that she recalls it being a
48:31
summer job and the fact that she did not work
48:33
at the spa until at least November two thousand, at
48:36
the age seventeen, should be deemed admitted undisputed. Fact forty one.
48:43
Plaintiff represented herself as a messuse for Jeffrey Epstein. While
48:48
working at mar A Lago's spa and reading a library
48:51
book about massage, Plaintiff met Miss Maxwell. Plaintiff thereafter told
48:55
her father that she got a job working for Jeffrey
48:59
Epstein as asus. Plaintiff's father took her to Epstein's house
49:03
on one occasion around that time, and Epstein came outside
49:06
and introduced himself to mister Roberts. Plaintiff commenced employment as
49:11
a traveling messuse for mister Epstein. Plaintiff was excited about
49:15
her job as a messuse, about traveling with him, and
49:18
about meeting famous people. Plaintiff represented that she was employed
49:23
as a massuse beginning in January of two thousand and one.
49:26
Plaintiff never mentioned Miss Maxwell to her then fiance, Ostrich.
49:30
Plaintiff's father never met Miss Maxwell. Reply. Plaintiff does not
49:35
actually refute any of the facts set forth above, but
49:38
rather spends her time discussing different facts. Plaintiff's father testified
49:43
to what she told them that she was going to
49:46
learn massage therapy. She does not contest her father's testimony
49:50
that Epstein came out of the house and greeted her father,
49:52
and that her father never met Miss Maxwell. See a
49:55
reply to undisputed fact number forty one. Whether someone can
49:59
receive a massage license under Florida law without a high
50:03
school equivalency diploma is of no moment. Plaintiff does not
50:07
dispute she represented herself as the masseuse to others in
50:11
her own handwriting beginning in January two thousand and one
50:14
example z M, and then these facts should be deemed admitted.
50:20
Number forty two. Plaintiff resumed a relationship with convicted felon
50:24
Anthony Figaroa in the spring of two thousand and one.
50:28
While living with Ostrich, Plaintiff lied to and cheated on
50:31
him with her high school boyfriend, Anthony Figaroa. Plaintiff and
50:35
Ostrich thereafter broke up, and Figaroa moved into the Bento
50:39
compartment with plaintiff. When Ostrich returned to the Bento compartment
50:44
to check on his pets and to retrieve his belongings, Figaroa,
50:48
in Plaintiff's presence, punched Ostrich in the face. Figaroa and
50:52
plaintiff fled the scene before police arrived. Figaroa was then
50:56
a convicted felon and a drug abuser on probation for
51:00
possession of a controlled substance. Reply, Plaintiff argues relevance regarding
51:05
these facts, but contests none of them they should be
51:08
deemed admitted. Plaintiff's slies, cheating, and association with a convicted
51:14
felon and known drug abuser are all relevant in this
51:17
defamation case concerning her reputation, purported damage to such reputation,
51:22
and whether she was a known liar. As the January
51:25
twenty fifteen statement contends Number forty three, plaintiff freely and
51:31
voluntarily contacted the police to come to her aid in
51:35
two thousand and one and two thousand and two, but
51:38
never reported to them that she was an Epstein's sex slave.
51:42
In August two thousand and one, at age seventeen, while
51:45
living in the same apartment, Plaintiff and Figueroa hosted a
51:48
party with a number of guests. During that party, according
51:52
to the plaintiff, someone entered Plaintiff's room and stole five
51:55
hundred dollars from her shirt pocket. Plaintiff contacted the police.
51:59
She met and spoke with police officers regarding the incident,
52:03
and filed a report. She did not disclose to the
52:06
officer that she was a sex slave. A second time,
52:09
in June two thousand and two, plaintiff contacted the police
52:13
to report that her former landlord had left her belongings
52:16
by the roadside and had lit her mattress on fire. Again,
52:21
plaintiff met and spoke with law enforcement, but did not
52:24
complain that she was the victim of any sexual trafficking
52:27
or abuse or that she was being held as a
52:30
sex slave. Reply, Plaintiff again presents no admissible evidence to
52:35
contradict these facts, instead arguing their relevance they should be
52:39
deemed admitted. Forty four From August two thousand and one
52:43
until September two thousand and two, Epstein and Maxwell were
52:47
almost entirely absent from Florida on documented travel unaccompanied by plaintiff.
52:53
Flight logs maintained by Epstein's private pilot, David Rodgers evidenced
52:58
the substantial number of trips away from Florida that Epstein
53:01
and Maxwell took unaccompanied by plaintiff between August two thousand
53:05
and one and September two thousand and two, Rogers maintained
53:09
the log of all flights on which Epstein and Maxwell
53:12
traveled with them. Epstein additionally traveled with another pilot who
53:16
did not keep such logs, and he also occasionally traveled
53:20
via commercial flights. For substantially all of the thirteen months
53:25
of the twenty two months from November two thousand until
53:28
September two thousand and two, the plaintiff lived in Palm
53:31
Beach and New Epstein. Epstein was traveling outside of Florida
53:35
unaccompanied by plaintiff. During this same time period, Plaintiff was
53:40
employed at various jobs, enrolled in school, and living with
53:43
her boyfriend. Reply, Plaintiff goes to great lengths to dispute
53:47
facts other than those presented as undisputed Fact forty four.
53:52
Her repetitive recitation of the flights that plaintiff was on
53:56
to nothing to demonstrate the thirteen months of flights from
53:59
July to ti On thousand and one until August two
54:01
thousand and two that Epstein and Maxwell were on without plaintiff,
54:06
as reflected in the logs. Her assertions regarding the other
54:10
flights that she took commercial or any other plane do
54:13
nothing to establish all of the many flights she was
54:17
not on during thirteen of the twenty two months period
54:20
during which Epstein and Maxwell were away from Palm Beach.
54:24
Plaintiff does not dispute that Epstein and Maxwell were on
54:27
the flights without her. The facts as presented by defendant
54:31
should be deemed admitted. All right, folks, we're going to
54:34
wrap up this episode right here, and in the next
54:36
episode we're gonna pick up where we left off. All
54:40
of the information that goes with this episode can be
54:42
found in the description box. What's up, everyone, and welcome
54:47
back to the Epstein Chronicles. In this episode, we're going
54:50
to continue taking a look at Klaine Maxwell's response to
54:54
Virginia's response about the undisputed facts. Forty five Plaintiff in
55:01
Figaroa shared a vehicle during two thousand and one and
55:04
two thousand and two. Plaintiff in Figaroa shared a nineteen
55:08
ninety three Pontiac in two thousand and one and two
55:11
thousand and two. Plaintiff freely traveled around the pom Beach
55:14
area in that vehicle. In August of two thousand and two,
55:17
plaintiff acquired a Dodge Dakota pickup truck from her father
55:21
example p. At sixty seven and sixty eight. Figaroa used
55:25
that vehicle in a series of crimes before and after
55:29
plaintiff left for Thailand. Reply again, the response has nothing
55:33
to do with the fact stated as plaintiff concedes she
55:37
and mister Figaroa had one car that they both used.
55:41
In fact, they traveled to and from school together example p.
55:45
At sixty seven and sixty eight. She does not dispute
55:48
that she traveled freely around the Palm Beach area in
55:51
that vehicle, or that her car was used in a
55:54
series of thefts while she was in Thailand. All that
55:58
should be deemed admitted forty six undisputed fact forty six.
56:03
Plaintiff held a number of jobs in two thousand and
56:05
one and two thousand and two. During two thousand and
56:08
one and two thousand and two, plaintiff was gainfully employed
56:11
at several jobs. She worked as a waitress at Menino's Restaurant,
56:15
at TGIF's Friday's Restaurant, and at Roadhouse Grill. She also
56:21
was employed at Courtyard Animal Hospital. Reply. Plaintiff admits all
56:26
of the facts at fourth above, aside from the use
56:29
of the word gainfully. They should be deemed admitted forty seven.
56:34
In September two thousand and two, plaintiff traveled to Thailand
56:38
to receive massage training, and while there met her future
56:41
husband and a lope with them. Plaintiff traveled to Thailand
56:45
in September of two thousand and two to receive formal
56:47
training as a massuse. Figaroa drove her to the airport.
56:51
While there. She initially contacted Figaroa frequently, incurring a phone
56:56
bill of four thousand dollars. She met her husband while
56:59
in Thailand and decided to marry him. She thereafter ceased
57:03
all contact with Figaroa from October two thousand and two
57:07
until two days before mister Figaroa's deposition in this matter
57:11
in May of twenty sixteen. Reply Again, Plaintiff does not
57:15
refute the facts set fourth. She simply offers her own
57:18
interpretation of those facts. In the absence of any country evidence,
57:23
they should be deemed admitted. Forty eight undisputed Fact Number
57:27
forty eight. Detective Ricarrey's investigation of Epstein fell to uncover
57:32
any evidence that Miss Maxwell was involved in sexual abuse
57:35
of miners, sexual trafficking, or production or possession of child pornography.
57:41
Joseph Riccari served as the lead detective from the Palm
57:44
Beach Police Department charged with investigating Jeffrey Epstein example gig
57:49
at ten. That investigation commenced in two thousand and five.
57:53
Riccari worked only on the Epstein case for an entire year.
57:57
He reviewed previous officer's reports and interviews, conducted numerous interviews
58:02
of witnesses and alleged victims himself, reviewed surveillance footage of
58:07
the Epstein home, participated in and had knowledge of the
58:11
search warrant executed on the Epstein home, and testified regarding
58:15
the case before the Florida State grand jury against Epstein.
58:19
Detective Rickerrey's investigation revealed that not one of the alleged
58:24
Epstein victims ever mentioned Miss Maxwell's name, and she was
58:28
never considered a suspect by the government. None of Epstein's
58:32
alleged victims said they had seen Miss Maxwell at Epstein's house,
58:35
nor said they had been recruited by her, nor paid
58:39
any money buyer, nor told what to wear or how
58:41
to act buyer. Indeed, none of Epstein's alleged victims ever
58:45
reported to the government they had ever met or spoken
58:48
to Miss Maxwell. Maxwell was not seen coming or going
58:53
from the house during the law enforcement surveillance of Epstein's home.
58:57
The arrest warrant did not mention Miss Maxwell, and her
59:00
name was never mentioned before the grand jury. No property
59:04
belonging to Maxwell, including sex toys or child pornography, was
59:09
seized from Epstein's home during execution of the search warrant
59:13
IDEA two fifty seven. Detective Roccary, when asked to describe
59:17
everything that you believe you know about Klainne Maxwell's sexual
59:20
trafficking conduct, replied, I don't IDEA two seventy eight. He
59:25
confirmed that he had no knowledge about Miss Maxwell's sexually
59:28
trafficking anybody. Detective Rocary also has no knowledge of Plaintiff's
59:33
conduct that is subject of this lawsuit. Reply, plaintiff offers
59:38
several misleading contrary facts, none of which actually address the
59:42
facts presented herein namely, whether Miss Maxwell was ever mentioned
59:46
by any of Epstein's alleged victims, whether she was the
59:49
target of their investigation, and whether any of her property
59:53
was seized from Epstein's home. Plaintiff cites to numerous inadmissible
59:57
pieces of evidence on facts other than those mister Rodriguez,
1:00:02
a convicted felon for obstructing justice related to the Epstein case,
1:00:06
is dead and his deposition testimony is the subject of
1:00:10
a motion in le Mean because Miss Maxwell has never
1:00:13
had the opportunity to cross examine them Document five point
1:00:17
sixty seven at fourteen. Miss Rebello, likewise, is not a
1:00:21
witness who has been deposed in this case, and therefore
1:00:24
her testimony is not admissible against Miss Maxwell. The message
1:00:28
bads are not authenticated by anyone, as will be the
1:00:32
subject of a forthcoming motion in le Mean. And there
1:00:35
is not one shred of evidence that any child pornography
1:00:39
as opposed to a topless photo of a very adult
1:00:42
Miss Maxwell wherever found in Epstein's home. The fact should
1:00:46
be deemed admitted as those proffered by defendant are based
1:00:50
on admissible evidence. Number forty nine undisputed Fact forty nine.
1:00:55
No nude photograph of plaintiff was displayed in Epstein's home.
1:00:58
Epstein's housekeeper, A Lessi, never saw any photographs of Virginia
1:01:03
Roberts in mister Epstein's house. Detective Racari entered Epstein's home
1:01:08
in two thousand and two to install security cameras to
1:01:11
catch a thief and did not observe any child pornography
1:01:14
within the home, including on Epstein's desk in his office. Reply.
1:01:20
Plaintiff offered no evidence that a nude photograph of her
1:01:24
was displayed in Epstein's home. All of the testimony she
1:01:27
submits has nothing to do with the nude photograph of herself.
1:01:31
The fact should be deemed admitted fifty undisputed Fact fifty.
1:01:35
Plaintiff intentionally destroyed her journal and dream journal regarding her
1:01:39
memories of this case. In twenty eleven, while represented by counsel,
1:01:44
Plaintiff drafted a journal describing individuals to whom she claimed
1:01:48
she was sexually trafficked, as well as her memories and
1:01:51
thoughts about her experiences with Epstein. In twenty thirteen, she
1:01:56
and her husband created a bonfire in her backyard in
1:01:59
Florida and burned the journal, together with other documents in
1:02:03
her possession. Plaintiff also kept a dream journal regarding her
1:02:07
thoughts and memories that she possessed in January twenty sixteen.
1:02:13
To date, plaintiff cannot locate the dream journal. Reply. Plaintiff
1:02:18
offers no contrary admissible evidence regarding her destruction of her journal.
1:02:22
And it should be deemed admitted fifty one. Undisputed Fact
1:02:26
Number fifty one. Plaintiff publicly peddled her story Beginning in
1:02:30
two thousand and one. Plaintiff granted journalist Sharon Churchier extensive
1:02:35
interviews that resulted in seven widely distributed articles. From March
1:02:39
twenty eleven through January twenty fifteen, Churcher regularly communicated with
1:02:45
Plaintiff and her attorneys or other agents. From early twenty
1:02:49
eleven to the present day. Plaintiff received approximately one hundred
1:02:54
and sixty thousand dollars for her stories and pictures that
1:02:57
were published by many news organizations. Reply, Plaintiff offers no
1:03:02
evidence to contradict the facts asserted, and they should therefore
1:03:06
be deemed admitted. Plaintiff's unsupported spin of those facts should
1:03:11
be stricken. Undisputed Fact fifty two. Plaintiff drafted a one
1:03:16
hundred and forty four page purportedly autobiographical book manuscript in
1:03:21
twenty eleven, which she actively sought to publish. In twenty eleven,
1:03:26
contemporaneous with her Churcher interviews, Plaintiff drafted a book manuscript
1:03:31
which purported to document plaintiff's experiences as a teenager in Florida,
1:03:36
including her interactions with Epstein and Maxwell, Plaintiff communicated with
1:03:41
literary agents, ghostwriters, and potential independent publishers in an effort
1:03:46
to get her book published. She generated marketing materials and
1:03:50
circulated those, along with book chapters to numerous individuals associated
1:03:55
with publishing and the media. Reply Plaintiff sites in missible
1:04:00
evidence and attorney argument in contradiction of these facts, they
1:04:04
should be ignored. The victim notification letter is inadmissible hearsay.
1:04:08
The psychologist's record likewise or inadmissible hearsay. The FBI interview
1:04:14
is inadmissible hearsay. Plaintiff's council then flatly misrepresents to the
1:04:19
court her own client's characterizations of the book manuscript, calling
1:04:23
it a fictionalized account. Plaintiff, contradicting her council, testified that
1:04:27
the book manuscript is ninety nine percent true. Question is
1:04:31
there anything? Well? First of all, did you author the
1:04:34
entire manuscript? Answer? Yes, I did? Question did anyone else
1:04:38
author a part of that manuscript? Answer? Do you mean
1:04:42
did anyone else write this with me? Question? Right? Answer? No, question,
1:04:47
that's all you're writing? Answer this is my writing. Question Okay,
1:04:51
to the best of your recollection as you sit here today,
1:04:54
Is there anything in that manuscript about Glainne Maxwell that
1:04:57
is untrue? Answer? I don't believe so. Like I said,
1:05:01
there is a lot of stuff that I actually left
1:05:03
out of here. Question mm hmm. Answer, So there is
1:05:07
a lot more information I could put in there, but
1:05:10
as far as Galainn. Maxwell goes, I would say that
1:05:13
there is ninety nine percent of it would be the
1:05:15
correct knowledge. Question all right, is there anything that you
1:05:19
and I understand that you're doing this from memory? Is
1:05:21
there anything that you recall as you're sitting here today
1:05:24
about Glayn Maxwell that is contained in the manuscript that
1:05:27
is not true? Answer? You know, I haven't read this
1:05:30
in a very long time. I don't believe that there's
1:05:33
anything in there about Gleannne Maxwell that is not true.
1:05:37
Plaintiff clearly now would like to spin the book manuscript
1:05:40
as fictionalized, because she is well aware that the facts
1:05:43
presented by her in that manuscript are contradicted by many
1:05:48
other documentary and testimonial records. Yet she offers no admissible
1:05:52
evidence that plaintiff intended the manuscript to be fictional. Citations
1:05:57
the social scientists who have not testified in this case
1:06:00
and whose work has not been cited by any expert
1:06:03
in this case, is wholly improper and should be stricken.
1:06:07
Number fifty three, Plaintiff publicly filed lurid CVRA pleadings, initiated
1:06:13
a media frenzy and generated highly publicized litigation between her
1:06:18
lawyers and Alan Dershowitz. On December thirtieth, twenty fourteen, plaintiff,
1:06:23
through Council, publicly filed a joined her motion that contained
1:06:26
her lurid allegations about Miss Maxwell and many others, including
1:06:31
Alan Dershowitz, Prince Andrew, and Jean Luc Brunel. The joined
1:06:34
her motion was followed by a corrected motion and two
1:06:38
further declarations in January and February twenty fifteen, which repeated
1:06:44
many of Plaintiff's claims. These CVRA pleadings generated a media
1:06:48
maelstrom and spawned highly publicized litigation between plaintiff's lawyers Edwards
1:06:53
En Cassel and Alan Dershowitz. After plaintiff publicly alleged mister
1:06:58
Dershowitz of sexual mist conduct, mister Dershowitz vigorously defended himself
1:07:03
in the media. He called plaintiff a liar and accused
1:07:06
her lawyers of unethical conduct. In response, Attorneys Edwards n
1:07:10
Cassel sued Dershowitz, who counterclaimed. This litigation in turn caused
1:07:15
additional media attention by national and international media organizations. Reply,
1:07:22
Plaintiff offers no contrary facts and so they should be
1:07:25
deemed admitted. Number fifty four undisputed Fact fifty four Plaintiff
1:07:31
formed non profit Victims Refused Silence to attract publicity and
1:07:35
speak out on a public controversy. In twenty fifteen, Plaintiff,
1:07:39
with the assistance of the same council, formed a nonprofit
1:07:43
organization Victims Refuse Silence. According to plaintiff, the purpose of
1:07:47
the organization is to promote Plaintiff's professed cause against sex slavery.
1:07:52
The stated goal of her organization is to help survivors
1:07:56
surmount the shame, silence, and intimidation typically experienced by victims
1:08:01
of sexual abuse. Plaintiffs attempts to promote Victims Refuse Silence
1:08:06
at every opportunity. For example, plaintiff participated in an interview
1:08:11
in New York with ABC to promote the charity and
1:08:14
to get our mission out to the public. Reply, Plaintiff
1:08:19
offers no contrary evidence and the facts should be deemed admitted. Two,
1:08:24
the court should strike plaintiff's statement of undisputed facts. The
1:08:28
summary judgment procedure is well established when the summary judgment
1:08:31
non movement bears the burden of proof at trial, as
1:08:34
in the case at Bar, the movement may show a
1:08:37
prima facie entitlement for summary judgment in one of two ways.
1:08:42
The movement may point to evidence that negates the non
1:08:45
movement's claims, or to the movement may identify those portions
1:08:50
of its opponent's evidence that demonstrate the absence of a
1:08:53
genuine issue of material fact salahudin versus Gored for sixty
1:08:58
seven Ft two sixty three two seventy two and seventy
1:09:03
three Second Circuit two thousand and six. If the movement
1:09:07
makes the showing in either manner, the burden shifts to
1:09:10
the non movement to identify record evidence creating a genuine
1:09:13
issue of material fact. Local Civil Rule fifty six dot
1:09:17
one A carries out this summary judgment procedure by requiring
1:09:21
the summary judgment movement to set forth material facts as
1:09:25
to which she contends that there is no genuine issue
1:09:28
to be tried. Subsection B of the rule requires the
1:09:32
party opposing some rejudgment to set forth the statement of
1:09:35
additional material facts as to which it is contended that
1:09:39
there exists a genuine issue to be tried. Miss Maxwell
1:09:43
has moved for some rejudgment. Plaintiff has not as movement.
1:09:47
Miss Maxwell is required under local civil rule fifty six
1:09:51
to one to enumerate the fact she is asserting as
1:09:54
undisputed as the party opposing some rejudgment. Plaintiff is permitted
1:09:58
if she can to inch reduce admissible evidence creating a
1:10:02
genuine issue of material fact see fed R. Siev fifty
1:10:07
six C. And one. Plaintiff is confused. Plaintiff believes she
1:10:12
the party opposing some rejudgment, must enumerate facts she is
1:10:15
asserting as undisputed, and so she has submitted her own
1:10:19
rule fifty six to one statement of undisputed facts that
1:10:23
gets a summary judgment procedure exactly backwards. Plaintiffs undisputed facts
1:10:28
are irrelevant. Plaintiff cannot avoid some rejudgment by proposing undisputed facts.
1:10:34
She may only do so by creating a genuine issue
1:10:36
of material fact as to Miss Maxwell's statement of undisputed facts. Accordingly,
1:10:42
this Court should strike Plaintiff's statement of undisputed facts. Although
1:10:46
Miss Maxwell, as a summary judgment movement, has no duty
1:10:50
to respond to plaintiffs alleged undisputed facts, we hasten to
1:10:54
add that Miss Maxwell in fact opposes and disputes most
1:10:58
of Plaintiff's alleged undisputed facts. For example, Defendant's undisputed fact
1:11:03
forty includes the statement Miss Roberts is hired as a
1:11:07
seasonal SPA attendant to work at the mar A Lago
1:11:09
club in the fall of two thousand, after she had
1:11:12
turned seventeen. Yeah, Plaintiff sets forth in her own undisputed
1:11:16
fact fifty eight that Virginia got a job at mar
1:11:19
A Lago in two thousand, either months before or just
1:11:22
after her seventeenth birthday. Plaintiff has done nothing more than
1:11:26
set forth her dispute with defendant undisputed fact forty as
1:11:30
her own undisputed fact. It makes no sense see also
1:11:34
Plaintiff's undisputed fact sixty three. The other alleged undisputed facts
1:11:38
are simply Plaintiff's assertion of her deposition testimony and hearsay
1:11:43
of her statements to other witnesses couched as undisputed facts.
1:11:47
Miss Maxwell's strenuously disputes almost all of the alleged undisputed
1:11:52
facts claiming that she engaged in any sort of sexual acts, misconduct,
1:11:56
or communication with plaintiff or others. Indeed, over the course
1:12:00
of two days and thirteen hours of deposition, Miss Maxwell
1:12:04
disputed all such allegations. Because none of Plaintiff's undisputed facts
1:12:09
have anything to do with the issues raised by defendant's
1:12:12
motion for some rejudgment, Miss Maxwell moves to strike Plaintiff's
1:12:16
statement of undisputed facts conclusion for the foregoing reasons. Miss
1:12:20
Maxwell requests that the Court deem her undisputed facts admitted
1:12:24
and that the Court strikes plaintiff statement of undisputed facts.
1:12:29
This was signed on February tenth of twenty seventeen, and
1:12:33
it was signed by Laura Meninger. All right, folks, that's
1:12:37
going to do it for this one. All of the
1:12:39
information that goes with this episode can be found in
1:12:42
the description box.