Mega Edition: Ghislaine Maxwell And Her Rule 56.1 Statement Of Facts (Parts 1-3) (3/29/26)

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What's up everyone and welcome back to the Epstein Chronicles.

In this episode, we're going to dive into some more court documents and we're going to start taking a look at Elaine Maxwell's reply to Virginia Roberts disputing her so called undisputed facts.

So let's get busy.

Case number 15-cv-074-33-RWS for junior Roberts vs. Elaine Maxwell.

The defendants replied a plaintiff statement of contested facts and plaintiffs undisputed facts pursuant to local civil rule 56.1.

Pursuant the rule 56.1 of the local civil rules of this court, defendant Elaine Maxwell submits this reply to plaintiff statement of contested facts and plaintiffs undisputed facts response document 586-1.

Introduction.

Plaintiffs response fails under both the federal rules of evidence and the local civil rules of procedure.

First, plaintiff largely failed to provide any citation to evidence which would be admissible to challenge defendants' statement of material undisputed facts and their form as Maxwell's undisputed facts should be deemed admitted.

Second, rather than set forth additional material facts as to which it is contended that there exists a genuine issue to be tried, local civil rule 56.1.B.

Plaintiff instead set forth her own purportedly undisputed facts because plaintiff did not cross-move for summary judgment, her supposedly undisputed facts are not permitted by the rules and should be stricken.

Section 1. Miss Maxwell's reply and supportive statement of undisputed facts 1.

Undisputed fact number 1.

In early 2011, plaintiff and two British tabloid interviews made numerous false and defamatory allegations against Miss Maxwell.

In the articles plaintiff made no direct allegations that Miss Maxwell was involved in any improper conduct with Jeffrey Epstein who had pleaded guilty in 2007

to procuring a minor for prostitution. Nonetheless, plaintiff suggested that Miss Maxwell work with Epstein and may have known about the crime for which he was convicted, examples A and B.

Reply, plaintiff cite no admissible evidence to contest these undisputed facts, McCauley, example 34, in an email from Sharon Churchill to plaintiff.

It is Miss Churcher's hearsay and therefore inadmissible. In any event, it does not speak to the contents of plaintiff's interviews with Churcher. McCauley Declaration, example 31, is an FBI interview also inadmissible hearsay which again does not describe plaintiff's interviews in news articles.

In the absence of contrary evidence, undisputed fact 1 should be deemed admitted.

2. Undisputed Fact Number 2. In the articles plaintiff alleged she had sex with Prince Andrew, a well-known businessman, a world renowned scientist, a respected liberal politician, and a foreign head of state, examples A through B at 5.

A. Reply, plaintiff does not contest these facts and they therefore should be deemed admitted. 3. Undisputed Fact 3. In response to the allegation,

Miss Maxwell's British Attorney, working with Mr. Gao, issued a statement on March 9, 2011 denying the various allegations about Miss Maxwell that have appeared recently in the media. These allegations are entirely false, example C.

A. Reply, plaintiff denies that Mr. Barton issued a statement but offers no admissible evidence to refute this point further she acknowledged that the statement was issued by Devonshire solicitors, Mr. Barton's law firm.

4. Undisputed Fact 4. The statement read in full London March 10, 2011.

Galen Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are entirely false. It is unacceptable that letters sent by Miss Maxwell's legal representatives to certain newspapers pointing out the truth and asking for the allegations to be withdrawn have simply been ignored.

In the circumstances, Miss Maxwell is now proceeding to take legal action against those newspapers. I understand that newspapers need to sell copies. It is well known that certain newspapers live by the adage, why let truth get in the way of a good story. However, the allegations made against me are abhorrent and are entirely untrue and I ask that they stop, say Galen Maxwell.

A number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name, she said.

A. Reply, plaintiff does not dispute the contents of the 2011 statement and therefore it should be deemed admitted. 5. Undisputed Fact 5.

Plaintiff's gratuitous and lurid accusations in an unrelated action in 2008 to alleged victims of Epstein brought an action under the Crime Victims Rights Act against the United States government purporting the challenge Epstein's plea agreement. They alleged that the government violated their CVRA rights by entering into an agreement.

Example D at 2. A. Reply, plaintiff stipulates to the facts contained in paragraph 5 and therefore they should be deemed admitted.

6. Undisputed Fact 6. Seven years later, on December 30, 2014, Ms. Roberts moved to join the CVRA action, claiming she too had her CVRA rights violated by the government.

On January 1, 2015, Ms. Roberts filed a corrected joineder motion, Example D at 1.9. Reply, plaintiff agreed to this paragraph. 7. Undisputed Fact 7.

The issue presented in her joineder motion was narrow, whether she should be permitted to join the CVRA action as a party under federal rule of Civil Procedure 21.

Specifically, whether she was a known victim of Mr. Epstein and the government owed them CVRA duties. Yet the bulk of the motion consists of copious factual details that plaintiff and her co-movement would prove if allowed to join.

Ms. Roberts gratuitously included provocative and lurid details of her alleged sexual activities as an alleged victim of sexual trafficking.

A. Reply. Plaintiff does not dispute that Judge Mara made the findings detailed in Undisputed Fact 7. Further, she admits that the government refused to stipulate that she had been sexually abused by Jeffrey Epstein and his co-conspirators, including co-conspirator Alan Dershowitz, which would make her a victim of a broad sex trafficking conspiracy.

Although she now admits there were other reasons for her inclusion of such lurid details, those reasons were rejected by Judge Mara. As she does not offer any admissible evidence to contradict the findings made by Judge Mara, this fact specifically Judge Mara's findings should be deemed admitted.

In any event we request under federal rule EVID-201-C2 that the court takes judicial notice of the contents of Judge Mara's ruling and disorder.

8. Undisputed Fact 8. At the time they filed the motion, Ms. Roberts and her lawyers knew that the media had been following the Epstein criminal case and the CVRA action. While they deliberately filed the motion without disclosing Ms. Roberts' name, claiming the need for privacy and secrecy, they made no attempt to file the case.

No attempt to file the motion under seal. Quite the contrary, they filed the motion publicly. Example D at 1 and N1. A. Reply

Plaintiff offers no admissible evidence to refute these facts and they therefore should be deemed admitted. Specifically, she does not offer any evidence to dispute that she knew the media had been following Epstein and the CVRA action, nor does she dispute that her attorneys made no attempt to file the motion under seal.

Rather filing it publicly. The facts are thus admitted.

9. Undisputed Fact 9. As the district court noted in ruling on the jointer motion, Ms. Roberts named several individuals and she offers details about the type of sex acts performed and where they took place.

The court ruled that these loaded details are unnecessary. The factual details regarding whom and where the Jane Does engaged in sexual activities are immaterial and impertinent, especially considering that these details involve nonparties who are not related to the respondent government.

Accordingly, these unnecessary details shall be stricken. The court then struck all of Ms. Roberts' factual allegations relating to her alleged sexual activities

under allegations of misconduct by nonparties. The court said the striking of the loaded details was a sanction for Ms. Roberts and proper inclusion of them in the motion.

A. Reply. Plaintiff offers no admissible evidence to refute these facts and they therefore should be deemed admitted.

C. Reply. To Undisputed Fact 7. Supra. In any event, we request under federal rule of evidence to O1C2 that the court take judicial notice of the contents of Judge Mara's ruling and his order.

10. Undisputed Fact 10. The district court found not only that the loaded details were unnecessary but also that the entire jointer motion was entirely unnecessary.

Ms. Roberts and her lawyers knew the motion with all its loaded details was unnecessary because the motion itself recognized that she would be able to participate as a fact witness to achieve the same result she sought as a party.

The court denied plaintiffs' jointer motion, ID at 7-10.

11. Undisputed Fact 11. One of the nonparties Ms. Roberts named repeatedly in the jointer motion was Ms. Maxwell.

According to the lurid details of Ms. Roberts included in the motion, Ms. Maxwell personally was involved in a sexual abuse and a sex trafficking scheme created by Epstein.

Ms. Maxwell approached plaintiff in 1999 when plaintiff was 15 years old to recruit her into the scheme. Ms. Maxwell was one of the main women, Epstein used to procure underage girls for sexual activities.

Ms. Maxwell was a primary co-conspirator with Epstein in his scheme. She persuaded plaintiff to go to Epstein's mansion in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children.

At the mansion, when plaintiff began to give Epstein a massage, he and Ms. Maxwell turned it into a sexual encounter.

Epstein, with the assistance of Ms. Maxwell, converted plaintiff into a sex slave, plaintiff was a sex slave from about 1999 through 2002.

Ms. Maxwell also was a co-conspirator and Epstein's sexual abuse. Ms. Maxwell appreciated the immunity she acquired under Epstein's plea agreement because the immunity protected her from prosecution from the crimes she committed in Florida.

Ms. Maxwell participated in the sexual abuse of plaintiff and others. Ms. Maxwell took numerous sexually explicit pictures of underage girls, involved in sexual activities, including the plaintiff. She shared those photos with Epstein.

As part of her role in Epstein's sexual abuse ring, Ms. Maxwell connected Epstein with powerful individuals so that Epstein could traffic plaintiff to these persons.

plaintiff was forced to have sexual relations with Prince Andrew in Ms. Maxwell's apartment in London. Ms. Maxwell facilitated plaintiff sex with Prince Andrew by acting as a madam for Epstein.

Ms. Maxwell assisted an internationally trafficking plaintiff and numerous other young girls for sexual purposes.

plaintiff was forced to watch Epstein, Ms. Maxwell, and others engage in illegal sexual acts with dozens of underage girls.

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Reply.

Plaintiff offers no admissible evidence to refute the facts, actually stated in the paragraph, i.e., the lurid details, as coined by Judge Mara, were included in her CVRA Joinder motion.

Plaintiff claims to offer admissible evidence to corroborate the statements she made in the Joinder motion, setting aside for the moment that most of the cited documents are inadmissible, here say, as address later.

Such evidence should be disregarded because none of the offered documents speak to fact that these lurid details were actually included in the Joinder motion, as a simple reading of example D reveals.

Because plaintiff does not refute that point, the fact that the details were in the Joinder motion should be deemed admitted.

In any event, we request under federal rules of evidence 201-C2 that the court takes judicial notice of the contents of plaintiffs CVRA Joinder motion.

What's up everyone and welcome back to the Epstein Chronicles.

We're going to pick back up with Galen Maxwell's response to Virginia Roberts' response to Galen Maxwell's undisputed facts.

12. Undisputed Fact Number 12. In the Joinder motion plaintiff also alleged she was forced to have sex with the Harvard professor, Alan Dershowitz, model scout Jean-Luc Brunel, and many, many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.

Again, plaintiff offers no evidence that these lurid details were included in the Joinder motion, as indeed they were, and thus the fact that they were should be deemed admitted.

13. Undisputed Fact Number 13. Plaintiff said after serving for four years as a sex slave, she managed to escape to a foreign country and hide out from Epstein and his co-conspirators for years.

Plaintiff does not dispute that she made the statement in her Joinder motion, and it is admitted.

14. Undisputed Fact Number 14. Plaintiff suggested the government was part of Epstein's conspiracy when it secretly negotiated a non-prosecution agreement with Epstein, precluding federal prosecution of Epstein and his co-conspirators.

The government secrecy, plaintiff alleged, was motivated by its fear that plaintiff would raise powerful objections to the agreement that would have shed tremendous public light on Epstein and other powerful individuals.

Reply. Plaintiff does not contest the quoted contents of the Joinder motion, but rather offers argument regarding plaintiff's purported belief.

Plaintiff did not submit an affidavit, attesting to such belief, and therefore no admissible evidence was cited or offered.

The facts should therefore be deemed admitted.

15. Undisputed Fact Number 15. Notably, the other Jane though, who joined plaintiff's motion, who alleged she was sexually abused on many occasions by Epstein,

was unable to corroborate any of plaintiff's allegations, idea 7 and 8. Reply. Plaintiff states the facts are untrue, but offers no admissible evidence to support that statement.

She has no affidavit or other statement from the other Jane though, who was represented by plaintiff's counsel, and therefore had the ability to furnish such an affidavit.

Indeed, plaintiff acknowledges that the other Jane though does not know Ms. Roberts. These facts must be deemed admitted.

Redacted, who is not the other Jane though, is irrelevant to the undisputed fact asserted.

She also offers no corroboration of the same pattern of abuse, and in fact does not remember any such facts as already briefed.

See Document 567 at 12-14.

16. Undisputed Fact 16. Also notably, in a multiple and lengthy consensual interviews with Ms. Churcher three years earlier,

plaintiff told Ms. Churcher a virtually none of the details she described in the Joinder Motion.

A. Reply. Plaintiff's protestations aside, the Churcher articles attached to Ms. Churcher's sworn affidavit filed in this case at Document 216 and 216 through 216 and 218 fell to include the vast majority of details included in plaintiffs, CVRA Joinder Motion, as any side-by-side comparison will reveal.

Plaintiff's simple, facile responses is that she did reveal details in 2011 consistent with those in the Joinder Motion.

She offers no admissible evidence of these details she revealed to Ms. Churcher, instead citing to a heavily redacted interview she purportedly gave to the FBI, not Ms. Churcher.

The purported FBI report in itself is hearsay, not to mention, redacted and prepared years after any supposed interview of plaintiff.

McCauley Declaration Example 31. Because plaintiff offers no admissible evidence to contradict the discrepancies between the Churcher articles and the Joinder Motion, these facts should be deemed admitted.

17. Undisputed Fact 17.

Ms. Maxwell's response to plaintiff's lurid accusations the January 2015 statement.

As plaintiff and her lawyers expected, before District Judge Mara in the CVRA action could strike the lurid details of plaintiff's allegation in the Joinder Motion, members of the media obtained copies of the motion, Example G.

A reply. Plaintiff cites no contrary evidence and therefore the fact should be deemed admitted.

18. Undisputed Fact 18.

At Mr. Barton's direction, on January 2, 2015, Mr. Gauss sent to numerous representatives of British media organizations in email containing a quotable statement on behalf of Ms. Maxwell.

18. The email was sent to more than six and probably less than 30 media representatives. It was not sent to non-media representatives. A reply.

18. Plaintiff disputes, as Blaine falsed, without admissible evidence that it was Mr. Barton who directed that the January 2 emails be sent to media organizations.

18. She then goes on to quote the very section of Mr. Gauss' deposition in which he surmises but does not know indicated by a statement, it was his understanding that it was something that had been sent to Maxwell by Barton.

18. Indeed, Mr. Barton clears up this confusion in his declaration in which he unequivocally swore, number 10, in liaison with Mr. Gauss and my client on January 2, 2015.

18. I prepared a further statement denying the allegations and I instructed Mr. Gauss to transmit it via email to members of the British media who had made inquiry about plaintiff's allegations about Ms. Maxwell.

18. The statement was issued on my authority, although it is possible other suggested or contributed content, I prepared the vast majority of the statement and ultimately approved and adopted all of the statement as my work.

18. Mr. Gauss surmises as to how the statement was forwarded to him and by whom does not contravert the sworn testimony of Mr. Barton himself.

18. Again without admissible evidence to the contrary, the facts must be deemed admitted.

18. With regard to the number of media representatives to whom he sent the email, Mr. Gauss testified it was between 6 and 30.

18. His further testimony offered by plaintiff that he spoke to over 30 journalists does not contradict that statement.

18. No where does plaintiff offer testimony that he read the statement to over 30 journalists. Instead, Mr. Gauss acknowledged it was very possible that he had ever read the statement to press or media over the phone not that he read it to over 30 journalists.

19. Plaintiff selective cutting and pasting undercutter so-called evidence that the facts in paragraph 18 are false and thus they ought to be deemed admissible.

19. Undisputed fact number 19. Among the media representatives were Martin Robinson of the Daily Mail, PPG of the Independent, Nick Summerland of the Mirror, David Brown of the Times, and Nick Always and Joanne Pew of the BBC,

and David Mercer of the press association. These representatives were selected based on their request after the joint promotion was filed for a response from this Maxwell to plaintiff's allegations in the motion.

19. A reply

19. While plaintiff decries the second sentence as false, her cited evidence contradicts her conclusion. Mr. Gauss testified that any time there was an incoming query it was either dealt with on the telephone by referring them back to the two statements or someone would email them the statement.

19. So no one was left unanswered, McCauley declaration, example six. As his testimony makes clear, Mr. Gauss sent the statement to those journalists who made inquiry, he did not send it to anyone who did not. Based on the admissible evidence, this fact remains undisputed.

20. Undisputed fact number 20. The email to the media members read, please find the touch the quotable statement on behalf of Ms. Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross.

19. Jane Doe 3 is Virginia Roberts, so not a new individual. The allegations made by Victoria Roberts against Colleen Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is retold, it changes with new, salacious details about public figures and world leaders. And now it is alleged by Ms. Roberts that Alan Dershowitz is involved in having sexual relations with her, which he denies.

Ms. Roberts claims are obvious lies and should be treated as such and not publicized as news as they are defamatory.

Glaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavory nature which have appeared in the British press and elsewhere and reserves her right to seek, redress at the repetition of such old defamatory claims.

Reply plaintiff does not dispute the contents of the email and therefore it should be deemed admitted.

21. Undisputed fact number 21, Mr. Barton, who prepared the January 2015 statement, did not intend it as a traditional press release solely to disseminate information to the media. So he intentionally did not pass it through a public relations firm such as Mr. Gals firm acuity reputation.

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Reply plaintiff makes two responses. As to the first sentence, she asserts without evidentiary support, the court should not consider the Barton declaration.

This argument is frivolous for the reasons given on pages 8, 11 and 12 and 18 and 19 over a ply brief in support of motion for summary judgment.

It is a declaration provided by an attorney with knowledge of the facts Mr. Barton disclosed by defendant in a rule 26 witnesses whom plaintiff chose not to oppose.

As to the second sentence, plaintiff offers two pieces of evidence which she argues disputes the facts in question. They do not.

That Mr. Gal forwarded the statement prepared by Mr. Barton to the media is not disputed.

Rather, as Mr. Barton asserted in his declaration and plaintiff failed to cite contradictory evidence, he was the one who prepared the vast majority of the statement and instructed Mr. Gal to transmit it via email to members of the British media.

He likewise, a verse that he did not intend the January 2015 statement as a traditional press release solely to disseminate information to the media.

This is why I intentionally did not request that Mr. Gal or any other public relations specialist prepare or participate in preparing the statement.

Plaintiff fails to contradict Mr. Barton's sworn statement. Undisputed fact number 22, the January 2015 statement served two purposes.

First, Mr. Barton intended that it mitigate the harm to Ms. Maxwell's reputation from the press publication of plaintiff's false allegations.

He believed these ends could be accomplished by suggesting to the media that among other things they should subject plaintiff's allegations to inquiry and scrutiny.

For example, he noted in the statement that plaintiff's allegations change dramatically over time, suggesting that they are obvious lies and therefore should not be publicized as news.

Reply, this paragraph eliciting Mr. Barton's intent is uncontroverted by plaintiff. She fails to cite any contradictory admissible evidence instead making legal arguments.

Her arguments are not admissible evidence, e.g. it is her statement and she directed that it be sent to the media and public lacks any citation to record evidence.

Plaintiff's list of evidence she contends, corroborates, plaintiff's claims should be ignored as they do not pretend to Mr. Barton's purposes and drafting the January second statement.

Number 21, undisputed fact, number 21. Mr. Barton, who prepared the January 2015 statement did not intend it as a traditional press release solely to disseminate information to the media so he intentionally did not pass it through the public relations firm such as Mr. Gall's firm acuity reputation.

Reply, plaintiff, makes two responses. As to the first sentence, she asserts without evidentiary support that the court should not consider the Barton Declaration.

This argument is frivolous for the reasons given on page 8, 11, 12, 18 and 19 of the reply brief in support of motion for a summary judgment.

It is a declaration provided by an attorney with knowledge of the facts, Mr. Barton, disclosed by the defendant in a rule 26 witnesses whom plaintiff chose not to depose.

As to the second sentence, plaintiff offers two pieces of evidence which she argues disputes the facts in question. They do not.

That Mr. Gall forwarded the statement prepared by Mr. Barton to the media is not disputed. Rather as Mr. Barton asserted in his declaration and plaintiff felt to cite contradictory evidence, he was the one who prepared the vast majority of the statement and instructed Mr. Gall to transmit it via email to members of the British media, example at 10.

He likewise a verse that he did not intend the January 2015 statement as a traditional press release solely to disseminate information to the media and this is why I intentionally did not request that Mr. Gall or any other public relations specialist prepare or participate in preparing the statement.

Plaintiff felt to contradict Mr. Barton's sworn statement, number 22, undisputed fact, number 22.

The January 2015 statement served two purposes.

First, Mr. Barton intended that it mitigate the harm to Miss Maxwell's reputation from the press's Republican of plaintiff's false allegations.

He believed these ends could be accomplished by suggesting to the media that among other things they should subject plaintiff's allegations to inquiry and scrutiny.

For example, he noted in the statement that plaintiff's allegations changed dramatically over time suggesting that there are obvious lies and therefore should not be publicized as news.

Reply. This paragraph, eliciting Mr. Barton's intent, is uncontroverted by plaintiff.

She fails to cite any contradictory admissible evidence instead making legal arguments. Her arguments are not admissible evidence.

EG, it is her statement and she directed that it be sent to the media and public.

Lacks any citation to record evidence.

Plaintiff's list of evidence. She contends corroborates plaintiff's claims should be ignored as they do not pertain to Mr. Barton's purposes and drafting the January 2nd statement.

Undisputed fact, number 23.

Second, Mr. Barton intended the January 2015 statement to be a shot across the bow of the media, which he believed had been unduly eager to publish plaintiff's allegations without conducting an inquiry of their own.

Accordingly, the statement he repeatedly noted that plaintiff's allegations were defamatory, in this sense the statement was intended as a cease-endesis letter to the media recipients, letting the media recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiffs' obviously false allegations and the legal indefensibility of their own conduct.

Plaintiff disputes Mr. Barton's intent without citation to record evidence.

Plaintiff claims that Barton did not note anything in the statement, but the statement itself contains the phrase, Mr. Robert's claims are obvious lies and should be treated as such and not publicized as news as they are defamatory.

Plaintiff's unsupported arguments should be ignored and these facts pertaining to Mr. Barton's intent deemed admitted.

Fact number 24. Consistent with two purposes, Mr. Gall's emails, prefaced the statement with the following language.

Please find attached a quotable statement on behalf of Ms. Maxwell.

The statement was intended to be a single one-time only comprehensive response quoted in full to plaintiffs December 30, 2014 allegations that would give the media Ms. Maxwell's response.

The purpose of the preparatory statement was to inform the media recipients of this intent, reply.

Plaintiff again disputes any statement related to Mr. Barton's purpose or intent, but offers no evidence contradicting his purpose or intent.

She simply points out that Ms. Maxwell retained Mr. Gall in early 2015, and that he works for a public relations firm which is non-responsive to the fact that issue.

Mr. Barton's intent with respect to language included in the statement.

No one is contested that it was Mr. Gall who actually forwarded the statement to select members of the media who had requested a response.

The facts that fourth should be deemed admitted.

Undisputed Fact number 25.

Plaintiff's activities bring light to the rights of victims of sexual abuse.

Plaintiff has engaged in numerous activities to bring attention to herself, to the prosecution,

and punishment of wealthy individuals such as Epstein, and to her acclaimed interest of bringing light to the rights of victims of sexual abuse.

Reply.

Plaintiff offers no evidence to dispute the facts cited and so they should be deemed admitted.

Undisputed Fact 26.

Plaintiff created an organization, victims refuse silence incorporated, a Florida corporation, directly related to alleged experience as a victim of sexual abuse.

Reply.

Plaintiff does not dispute this statement.

27.

Undisputed Fact number 27.

The goal of victims refuse silence was and continues to be to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse.

Towards this end, Plaintiff has dedicated her professional life to helping victims of sexual trafficking.

Reply.

Plaintiff agrees.

28.

Plaintiff repeatedly has sought out media organizations to discuss her alleged experience as a victim of sexual abuse.

This reply statement, at 51 through 54, and 2 through 11, and referenced in exhibits document 261 to 216, and example N, KK, LL, and MM reply.

Plaintiff denies this contention points to an email from Sharon Churcher seeking to interviewer and asserts that it was the media that sought her out.

The weight of evidence cited by defendant at paragraphs 51 through 54 in addition to Plaintiff's own documents belive this assertion.

She, through her attorneys, sought out a videotaped interview with ABC News, she sent her book manuscript to publishers and literary agents,

and expressed anticipation and frustration that her exclusive contract with the mail prevented her for a period of time from marketing her book.

Plaintiff disputed none of these activities, she freely engaged in for years, and thus these facts should be admitted.

29.

On December 30, 2014, Plaintiff publicly filed an entirely unnecessary jointer motion, laden with unnecessary lurid details about being sexually abused as a minor victim, by wealthy and famous men, and being trafficked all over the world as a sex slave.

Reply, Plaintiff argues that her lurid details were necessarily legal.

Judge Mara, however, has already held that they were not, and her legal arguments unsupported by any actual evidence in this case, cannot serve to contravert his findings as quoted.

30.

The plaintiff's alleged purpose in filing the jointer motion was to vindicate her rights under the CVRA, exposed the government secretly negotiated non-prossecution agreement with Epstein,

Shet tremendous public light on Epstein and other powerful individuals that would undermine the agreement and support the CVRA's plaintiff's request for documents that would show how Epstein used his powerful political and social connections to secure a favorable plea deal and the government's motive to aid Epstein and his co-conspirators, example D at 1, 6, and 7, and 10.

Reply, Plaintiff, fails to offer any evidence to contravert the contents of her CVRA jointer motion and thus the fact should be deemed admitted.

31.

Undisputed Fact No. 31

Plaintiff's written the manuscript of a book, she has been trying to publish detailing her alleged experience as a victim of sexual abuse and sex trafficking in Epstein's alleged scheme.

Reply, plaintiff directs the court to her response to paragraph 52 and suggests the factual statement is misleading.

She, however, offers no contradictory admissible evidence and thus the fact should be deemed admitted.

32.

Undisputed Fact No. 32

Republication alleged by plaintiff

Plaintiff was required by interrogatory No. 6 to identify any false statements attributed to Ms. Maxwell that were published globally, including within the Southern District of New York.

As plaintiff alleged in paragraph 9 of Count 1 of her complaint, in response plaintiff identified the January 2015 statement and nine instances in which various news media published portions of the January 2015 statement in news articles or broadcast stories.

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Reply. Her arguments aside, plaintiff offers no admissible evidence to contravert the interrogatory request under response, which was limited to nine instances in which the press published portions of the January 2015 statement.

For example, plaintiff does not point to one single new story that published the entirety of the January 2015 statement.

In the absence of contrary evidence, the fact should be deemed admitted.

33. In none of the nine instances, was there any publication of the entire January 2015 statement, reply, plaintiff does not and cannot point to any of the nine publications she disclosed or any of the other publications.

That published the entire January 2015 statement and this fact thus must be deemed admitted.

34. Miss Maxwell and her agents exercise no control or authority over any media organization, including the media identified in plaintiff's response to interrogatory number six in connection with the media's publication of portions of the January 2015 statement.

Reply. Plaintiff propered evidence testimony from Mr. Gal fails to support her argument and fails to contravert the burden declaration as cited by the defendant.

Nothing in the testimony establishes as plaintiff argues that the defendant hired Gal because his position allowed him to influence the press to publish her defamatory statement.

The testimony is irrelevant to the factual point. Gal's testimony at most relates to why Miss Maxwell engaged Mr. Gal.

It does not bear on the factual point i.e. that Miss Maxwell, Mr. Gal or Mr. Barton did not exercise any control or authority over the media in the media's republication of portions of the statement.

On this point, plaintiff has failed to introduce any contrary evidence.

Accordingly, the fact should be deemed admitted.

35. Plaintiff's defamation action against Miss Maxwell.

Eight years after Epstein's guilty plea, plaintiff brought this action repeating many of the allegations she made in her CVRA joined her motion.

Reply plaintiff agrees.

36. The complaint alleged that the January 2015 statement contained the following deliberate falsehoods.

A. That Roberts sworn allegations against Maxwell are untrue. B. That the allegations have been shown to be untrue. C. That Roberts claims are obvious lies.

A. Reply plaintiff agreed.

27. Plaintiff lived independently from her parents with her fiance, long before meeting Epstein or Maxwell.

After leaving the growing together drug rehabilitation facility in 1999, plaintiff moved in with the family of a fellow patient, example L at 7 and 8 and 12 through 14.

There she met and became engaged to her friend's brother, James Michael Austrich, ID at 19.

She and Austrich thereafter rented an apartment in the Fort Lauderdale area with another friend and both worked at various jobs in the area.

Later, they stayed briefly with plaintiff's parents in the Palm Beach, Laxahatchee, Florida area before Austrich rented an apartment for the couple on Beno Drive in Royal Palm Beach, ID at 17, 19, 25, through 27.

Although plaintiff agreed to marry Austrich, she never had any intention of doing so.

Example N at 127 and 128. Reply.

Plaintiff offers argument without an affidavit or any other contradictory evidence regarding whether plaintiff voluntarily lived independently or whether a reasonable person could assert that she was engaged.

Mr. Austrich and plaintiff agreed that they were engaged and testified accordingly as cited.

In the absence of admissible evidence to the contrary, the facts as described by Herfiance in his deposition should be deemed admitted.

All right folks, we're going to wrap up this episode right here and in the next episode we're going to pick up where we left off.

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