Mega Edition: Ghislaine Maxwell And Her Rule 56.1 Statement Of Facts (Parts 4-5) (3/30/26)

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What's up, everyone? And welcome back to the Epstein Chronicles.

In this episode, we're going to continue taking a look at Galein Maxwell's response

to Virginia Roberts contested facts and the plaintiffs undisputed facts.

38. Plaintiff re-enrolled in high school from June 21st, 2000 until March 7th, 2002.

After finishing the 9th grade high school year at Forest Hills High School on June 9th, 1999,

Plaintiff re-enrolled at Wellington Adult High School on June 21st, 2000.

Again, on August 16th, 2000, and August 14th, 2001.

On September 20th, 2001, Plaintiff then enrolled at Royal Palm Beach High School.

A few weeks later, on October 12th, 2001, she matriculated at Survivor's Charter School.

Survivor's Charter School was an alternative school designed to assist students

who had been unsuccessful at more traditional schools.

Plaintiff remained enrolled at Survivor's Charter School until March 7th, 2002.

She was present 56 days and absent 13 days during her time there.

Plaintiff never received her high school diploma or GED.

Plaintiff and Figueroa went back to school together at Survivor's Charter School.

Example P at 23 through 27.

The school day there lasted from morning until early afternoon.

Idea 23 through 27.

Plaintiff argues again without evidentiary support that the codes

on the school records indicate semester, start, and end dates.

Rather than dates, Plaintiff was in school.

Hermes reading of the records is apparent from their face.

One column is labeled entry date and the next withdrawal date.

Neither say semester start date or semester end date.

Moreover, the codes simply prove the point.

Plaintiff entered school, codes EO1 and EA1 on the designated entry date

and withdrew either prior to completion to enter another training program

or who will continue in the class program the next term or school year.

On the dates designated withdrawal, the school records display entry

and withdrawal dates for Wellington High School adult program from June 21st, 2000

through August 15th, 2000 from August 16th, 2000 through August 13th, 2001

and from August 14th, 2001 through September 20th, 2001

and then an entry that same day September 20th, 2001 at Survivors Charter School.

Plaintiff would have one believe that the record show a school on Plaintiff's official transcript

that she never went to.

Wellington High School adult program that indicates that she withdrew the very day

she concededly entered Survivors Charter School.

Her intentional misreading of the record is yet another attempt

to obfuscate Plaintiff's lack of memory regarding where and when she went to school

just like she failed to remember a job that she held in 2000,

whereas she claimed to have none.

The test is admissible evidence to the country and Plaintiff offers none.

The flight logs which show trips in early 2001 do not contradict the evidence

because they are jarring the period of time she was enrolled in adult high school,

a place where night classes were taught and where one might

circumstantially infer careful attendance records were not kept.

Fact number 39

During the year 2000, Plaintiff worked at numerous jobs.

In 2000 while living with her fiance, Plaintiff held five different jobs

at Avoculture Breeding and Research Center,

Southeast Employee Management Company, the club Mar-a-Lago, Oasis outsourcing,

and Neiman Marcus.

Her taxable earnings that year totaled nearly $9,000,

Plaintiff cannot now recall either the Southeast Employee Management Company

or the Oasis outsourcing jobs, example at Q, at 470 and 471.

Reply Plaintiff does not dispute the facts as presented merely argues regarding their significance.

The Social Security Administration records detail the five jobs at which she worked in 2000.

The month and day of the jobs are irrelevant for purposes of this recitation of facts,

likewise Plaintiff does not dispute the taxable earnings she made that year

or that she does not remember the jobs associated with the Southeast Employee Management Company

or Oasis outsourcing, whether they were payroll or not,

where she made $3,212 and $2,037 that year.

She also forgot about the job at Neiman Marcus, where she made $1,440 in 2000

until she was confronted with the SSA records.

McCauley Declaration, Example 5

Number 40

Undisputed Fact 40, Plaintiff's employment at Mar-a-Lago Spa began in the fall of 2000.

Plaintiff's father, Sky Roberts, was hired as a maintenance worker at the Mar-a-Lago Club

in Palm Beach, Florida, beginning on April 11, 2000. Miss Roberts worked their year-round

for approximately three years. After working there for a period of time,

Mr. Roberts became acquainted with the head of the Spa Area and recommended Plaintiff for a job there.

Mar-a-Lago closes every Mother's Day and reopens on November 1.

Example U at Mar-a-Lago 0212

Most of the employees who work at Mar-a-Lago, including all employees of the Spa Area,

such as Spa Attendance are seasonal and work only when the club is open.

I.e. November 1 and Mother's Day. Example T at 72 and 73.

Plaintiff was hired as a seasonal Spa Attendant to work at the Mar-a-Lago Club in the fall of 2000,

after she had turned 17. The reply, Plaintiff's response is misleading. First, she does not dispute

that Ms. Roberts and her father began working at Mar-a-Lago in April of 2000,

nor that he worked there for some time, became acquainted with the head of the Spa Area

and recommended his daughter for a job. Second, Plaintiff contends that job postings and job

descriptions from 2002 and later are irrelevant. There are no such job posting cited.

Rather, the job posting cited was from October 2000, the same time the Plaintiff was hired.

Compare example V, posting for Saturday, October 14th, and Sunday, October 15th, with calendar for

year 2000, showing Saturday and Sundays in October, corresponding to those dates.

Finally, Plaintiff points to her own recollection as contrary proof. Her recollection about

when she worked at Mar-a-Lago has shifted dramatically over time. First, she claimed it was 1998,

see Jane though 102 can plane. Then it was 1999, see document number 1.

Now, in this response, she has changed her answer to 2000. Her vague recollections about what

year have been off base, no credit should be given to her new found recollection of which month

that she worked there. In any event, she presents no admissible credible evidence to contradict Mar-a-Lago's

own records. Even Plaintiff's father, a longtime employee of Mar-a-Lago, admitted that the place

closed down in the summer. Plaintiff simply is not credible in her testimony that she recalls it

being a summer job and the fact that she did not work at the spa until at least November 2000 at

the age 17 should be deemed admitted. Undisputed Fact 41

Plaintiff represented herself as a masseuse for Jeffrey Epstein. While working at Mar-a-Lago's spa

and reading a library book about massage, Plaintiff met Ms. Maxwell. Plaintiff thereafter told her

father that she got a job working for Jeffrey Epstein as a masseuse. Plaintiff's father took her

to Epstein's house on one occasion around that time and Epstein came outside and introduced himself

to Mr. Roberts. Plaintiff commenced employment as a traveling masseuse for Mr. Epstein. Plaintiff

was excited about her job as a masseuse about traveling with him and about meeting famous people.

Plaintiff represented that she was employed as a masseuse beginning in January of 2001. Plaintiff

never mentioned Ms. Maxwell to her then-fiancé ostrich. Plaintiff's father never met Ms. Maxwell.

Reply. Plaintiff does not actually refute any of the facts set forth above, but rather spends

her time discussing different facts. Plaintiff's father testified to what she told him that she was

going to learn massage therapy. She does not contest her father's testimony that Epstein came out

of the house and greeted her father and that her father never met Ms. Maxwell. See reply to

undisputed fact number 41. Whether someone can receive a massage license under Florida law

without a high school equivalency diploma is of no moment. Plaintiff does not dispute. She

represented herself as a masseuse to others in her own handwriting beginning in January 2001.

Examples M and N. These facts should be deemed admitted.

Number 42. Plaintiff resumed a relationship with convicted felon Anthony Figueroa.

In the spring of 2001, while living with ostrich, Plaintiff lied to and cheated on him with her

high school boyfriend Anthony Figueroa, Plaintiff and ostrich thereafter broke up and Figueroa

moved into the bento compartment with Plaintiff. When ostrich returned to the bento compartment

to check on his pets and to retrieve his belongings, Figueroa and Plaintiff's presence

punched ostrich in the face. Figueroa and Plaintiff fled the scene before police arrived.

Figueroa was then a convicted felon and a drug abuser on probation for possession of a controlled

substance. Reply. Plaintiff argues relevance regarding these facts but contests none of them.

They should be deemed admitted. Plaintiff slides, cheating and association with a convicted

felon and known drug abuser are all relevant in this defamation case concerning her reputation,

purported damage to such reputation and whether she was a known liar as the January 2015 statement

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CCNC is 21 plus sponsored by JambaCasino. Plaintiff freely and voluntarily contacted the police

to come to her aid in 2001 and 2002 but never reported to them that she was an Epstein sex slave.

In August 2001, at age 17, while living in the same apartment, Plaintiff and Figueroa

hosted a party with a number of guests. During that party, according to the plaintiff,

someone entered Plaintiff's room and stole $500 from her shirt pocket. Plaintiff contacted the

police. She met and spoke with police officers regarding the incident and filed a report. She did not

disclose to the officer that she was a sex slave. A second time in June 2002, Plaintiff contacted

the police to report that her former landlord had left her belongings by the roadside and had

laid her mattress on fire. Again, Plaintiff met and spoke with law enforcement but did not

complain that she was the victim of any sexual trafficking or abuse or that she was being held

as a sex slave. Reply, Plaintiff again presents no admissible evidence to a contradict these facts

instead arguing their relevance. They should be deemed admitted. 44, from August 2001 until September

2002, Epstein and Maxwell were almost entirely absent from Florida on documented travel on a

company by Plaintiff. Flight logs maintained by Epstein's private pilot David Rogers

evidence the substantial number of trips away from Florida that Epstein and Maxwell took

on a company by Plaintiff between August 2001 and September 2002. Rodgers maintained the

log of all flights on which Epstein and Maxwell traveled with him. Epstein additionally

traveled with another pilot who did not keep such logs and he also occasionally traveled via commercial

flights. For substantially all of the 13 months of the 22 months from November 2000 until September

2002, the Plaintiff lived in Palm Beach and new Epstein. Epstein was traveling outside of Florida

on a company by Plaintiff. During this same time period, Plaintiff was employed at various jobs

enrolled in school and living with her boyfriend. Reply, Plaintiff goes to great lengths to dispute

facts other than those presented as undisputed fact 44. Her repetitive recitation of the flights that

Plaintiff was on to nothing to demonstrate the 13 months of flights from July 2001 until August

2002 that Epstein and Maxwell were on without Plaintiff as reflected in the logs. Her assertions

regarding the other flights that she took commercial or any other plane do nothing to establish

all of the many flights she was not on during 13 of the 22 months period during which Epstein and

Maxwell were away from Palm Beach. Plaintiff does not dispute that Epstein and Maxwell were on the

flights without her. The facts as presented by defendant should be deemed admitted.

45. Plaintiff in Figueroa shared a vehicle during 2001 and 2002. Plaintiff in Figueroa shared a

1993 Pontiac in 2001 and 2002. Plaintiff freely traveled around the Palm Beach area in that vehicle.

In August of 2002, Plaintiff acquired a Dodge Dakota pickup truck from her father, Example P at 67

and 68. Figueroa used that vehicle in a series of crimes before and after Plaintiff left for Thailand.

Reply, again, the response has nothing to do with the facts stated. As Plaintiff concedes,

she and Mr. Figueroa had one car that they both used. In fact, they traveled to and from school

together, Example P at 67 and 68. She does not dispute that she traveled freely around the Palm Beach

area in that vehicle or that her car was used in a series of thefts while she was in Thailand.

All that should be deemed admitted. 46. Undisputed Fact 46. Plaintiff held a number of jobs

in 2001 and 2002. During 2001 and 2002, Plaintiff was gainfully employed at several jobs.

She worked as a waitress at Manino's Restaurant at TGIF's Friday's Restaurant and at Roadhouse Grill.

She also was employed at Courtyard Animal Hospital. Reply, Plaintiff admits all of the facts

had forth above aside from the use of the word gainfully. They should be deemed admitted. 47.

In September 2002, Plaintiff traveled to Thailand to receive massage training and while there

met her future husband and a lope with him. Plaintiff traveled to Thailand in September of 2002

to receive formal training as a masseuse. Figueroa drove her to the airport. While there,

she initially contacted Figueroa frequently, incurring a phone bill of $4,000.

She met her husband while in Thailand and decided to marry him. She thereafter ceased all contact

with Figueroa from October 2002 until two days before Mr. Figueroa's deposition in this matter

in May of 2016. Reply, again, Plaintiff does not refute the facts at fourth.

She simply offers her own interpretation of those facts. In the absence of any country,

they should be deemed admitted. 48. Undisputed Fact No. 48

Detective Rikari's investigation of Epstein,

felled on cover any evidence that Ms. Maxwell was involved in sexual abuse of minors,

sexual trafficking, or production, or possession of child pornography.

Joseph Rikari served as the lead detective from the Palm Beach Police Department,

charged with investigating Jeffrey Epstein, example of GG at 10.

That investigation commenced in 2005. Rikari worked only on the Epstein case for an entire year.

He reviewed previous officers' reports and interviews, conducted numerous interviews of witnesses

and the alleged victims himself, reviewed surveillance footage of the Epstein home,

participated in and had knowledge of the search warrant executed on the Epstein home

and testified regarding the case before the Florida State grand jury against Epstein.

Detective Rikari's investigation revealed that not one of the alleged Epstein victims

ever mentioned Ms. Maxwell's name and she was never considered a suspect by the government.

None of Epstein's alleged victims said they had seen Ms. Maxwell at Epstein's house,

nor said they had been recruited by her, nor paid any money by her, nor told what to wear,

or had to act by her. Indeed, none of Epstein's alleged victims ever reported to the government,

they had ever met or spoken to Ms. Maxwell. Maxwell was not seen coming or going from the house

during the law enforcement surveillance of Epstein's home. The arrest warrant did not mention Ms. Maxwell

and her name was never mentioned before the grand jury. No property belonging to Maxwell,

including sex toys or child pornography, was seized from Epstein's home during execution of the

search warrant. Idea 257. Detective Rikari, when asked to describe everything that you believe you

know about Golan Maxwell's sexual trafficking conduct replied, I don't. Idea 278. He confirmed that

he had no knowledge about Ms. Maxwell's sexually trafficking anybody. Detective Rikari also has

no knowledge of plaintiff's conduct that is subject of this lawsuit. Reply. Plaintiff offers several

misleading contrary facts, none of which actually addressed the facts presented herein. Namely,

whether Ms. Maxwell was ever mentioned by any of Epstein's alleged victims, whether she was the

target of their investigation, and whether any of her property was seized from Epstein's home,

plaintiff cites to numerous inadmissible pieces of evidence on facts other than those. Mr. Rodriguez,

a convicted felon for obstructing justice related to the Epstein case, is dead and is deposition

testimony is the subject of emotion in Lameen because Ms. Maxwell has never had the opportunity to

cross-examine them. Document 567 at 14. Ms. Rebeo, likewise, is not a witness who has been

deposed in this case, and therefore her testimony is not admissible against Ms. Maxwell. The message

fads are not authenticated by anyone, as will be the subject of a forthcoming motion in Lameen,

and there is not one shred of evidence that any child pornography, as opposed to a topless photo

of a very adult Ms. Maxwell, were ever found in Epstein's home. The facts should be deemed

admitted, as those profored by defendant are based on admissible evidence.

49. Undisputed Fact 49. No nude photograph of plaintiff was displayed in Epstein's home,

Epstein's housekeeper Wanda Lessi. Never saw any photographs of Virginia Roberts and Mr.

Epstein's house. Detective Riccari entered Epstein's home in 2002 to install security cameras

to catch a thief and did not observe any child pornography within the home, including on Epstein's

desk in his office. Reply plaintiff offered no evidence that a nude photograph of her was

displayed in Epstein's home. All of the testimony she submits has nothing to do with a nude photograph

of herself. The fact should be deemed admitted, 50. Undisputed Fact 50. Plaintiff intentionally

destroyed her journal and dream journal regarding her memories of this case in 2011 while represented

by counsel. Plaintiff drafted a journal describing individuals to whom she claimed she was sexually

trafficked, as well as her memories and thoughts about her experiences with Epstein.

In 2013, she and her husband created a bonfire in her backyard in Florida and burned the journal

together with other documents in her possession. Plaintiff also kept a dream journal regarding her

thoughts and memories that she possessed in January 2016. To date, plaintiff cannot locate the dream

journal. Reply plaintiff offers no contrary admissible evidence regarding her destruction of her journal

and it should be deemed admitted. 51. Undisputed Fact No. 51. Plaintiff publicly

peddled her story beginning in 2001. Plaintiff granted journalists Sharon Churcher,

extensive interviews that resulted in seven widely distributed articles from March 2011 through

January 2015. Churcher regularly communicated with plaintiff and her attorneys or other agents from

early 2011 to the present day. Plaintiff received approximately $160,000 for her stories and pictures

that were published by many news organizations. Reply plaintiff offers no evidence to contradict

the facts asserted and they should therefore be deemed admitted. Plaintiff's unsupported spin

of those facts should be stricken. Undisputed Fact 52. Plaintiff drafted a 144 page purportedly

autobiographical book manuscript in 2011 which she actively sought to publish. In 2011,

contemporaneous with her Churcher interviews, plaintiff drafted a book manuscript which

reported to document plaintiff's experiences as a teenager in Florida, including her interactions

with Epstein and Maxwell. Plaintiff communicated with literary agents, ghost writers, and potential

independent publishers in an effort to get her book published. She generated marketing materials

and circulated those along with book chapters to numerous individuals associated with publishing

and the media. Reply plaintiff's sites in admissible evidence and attorney argument

in contradiction of these facts they should be ignored. The victim notification letter is inadmissible

The psychologist's record, likewise, are inadmissible hearsay. The FBI interview is inadmissible

hearsay. Plaintiff's council then flatly misrepresents to the court her own client's characterizations

of the book manuscript calling it a fictionalized account. Plaintiff contradicting her counsel

testified that the book manuscript is 99% true. Question, is there anything? Well, first of all,

did you author the entire manuscript? Answer, yes, I did. Question, did anyone else author a part

of that manuscript? Answer, do you mean did anyone else write this with me? Question, right. Answer,

no. Question, that's all you're writing. Answer, this is my writing. Question, okay, to the best of your

recollection, as you sit here today, is there anything in that manuscript about Elaine Maxwell that

is untrue? Answer, I don't believe so, like I said, there is a lot of stuff that I actually left

out of here. Question, mm-hmm. Answer, so there is a lot more information I could put in there,

but as far as Elaine Maxwell goes, I would say that there is 99% of it would be the correct

knowledge. Question, all right, is there anything that you and I understand that you're doing this

from memory? Is there anything that you recall as you're sitting here today about Elaine Maxwell

that is contained in the manuscript that is not true? Answer, you know, I haven't read this in a

very long time. I don't believe that there's anything in there about Elaine Maxwell that is not true.

Plaintiff clearly now would like to spin the book manuscript as fictionalized because she is well

aware that the facts presented by her in that manuscript are contradicted by many other

documentary and testimonial records. Yet she offers no admissible evidence that Plaintiff intended

the manuscript to be fictional, citations to social scientists who have not testified in this case,

and whose work has not been cited by any expert in this case is wholly improper and should be

stricken. Number 53. Plaintiff publicly filed lured CVRA pleadings initiated a media frenzy

and generated highly publicized litigation between her lawyers and Alan Dershowitz.

On December 30, 2014, Plaintiff, through council, publicly filed a jointer motion that contained her

lured allegations about Miss Maxwell and many others, including Alan Dershowitz, Prince Andrew,

and Jean-Luc Brunel. The jointer motion was followed by a corrected motion and two further

declarations in January and February 2015, which repeated many of Plaintiff's claims. These CVRA

pleadings generated a media maelstrom and spawned highly publicized litigation between Plaintiff's

lawyers Edwards and Cassel and Alan Dershowitz. After Plaintiff publicly alleged Mr. Dershowitz

of sexual misconduct, Mr. Dershowitz vigorously defended himself in the media. He called Plaintiff a

liar and accused her lawyers of unethical conduct. In response, Attorney's Edwards and Cassel

sued Dershowitz who counter-clamed. This litigation in turn caused additional media attention

by national and international media organizations. Reply, Plaintiff offers no contrary facts,

and so they should be deemed admitted. Number 54, Undisputed Fact 54, Plaintiff formed non-profit

victims' refuse silence to attract publicity and speak out on a public controversy. In 2015,

Plaintiff, with the assistance of the same council, formed the non-profit organization,

victims' refuse silence. According to Plaintiff, the purpose of the organization is to promote

Plaintiff's profess cause against sex slavery. The stated goal of her organization is to help

survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual

abuse. Plaintiff attempts to promote victims' refuse silence at every opportunity. For example,

Plaintiff participated in an interview in New York with ABC to promote the charity and to get

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Reply, Plaintiff offers no contrary evidence and the fact should be deemed admitted.

Two, the court should strike plaintiff statement of undisputed facts. The summary judgment procedure

is well established. When the summary judgment non-movement bears the burden of proof at trial,

as in the case at bar, the movement may show a prima facie entitlement for summary judgment in one

of two ways. The movement may point to evidence that negates the non-movement's claims or to

the movement may identify those portions of its opponent's evidence that demonstrate the absence

of a genuine issue of material fact. Salahuddin vs. Gord 467 F.3D 263 272 and 73 Second Circuit 2006.

If the movement makes the showing in either manner, the burden shifts to the non-movement to

identify record evidence creating a genuine issue of material fact. Local civil rule 56.1A

carries out the summary judgment procedure by requiring the summary judgment movement to set forth

material facts as to which she contends that there is no genuine issue to be tried. Subsection B

of the rule requires the party opposing summary judgment to set forth a statement of additional

material facts as to which it is contended that there exists a genuine issue to be tried.

Ms. Maxwell has moved for summary judgment plaintiff has not. As movement, Ms. Maxwell is required

under local civil rule 56.1 to enumerate the fact she is asserting as undisputed. As the party

opposing summary judgment plaintiff is permitted, if she can, to introduce admissible evidence

creating a genuine issue of material fact. See Fed, R, Civ, 56C, and 1. Plaintiff is confused.

Plaintiff believes she, the party opposing summary judgment, must enumerate fact she is asserting

as undisputed. And so she has submitted her own rule 56.1 statement of undisputed facts.

That gets the summary judgment procedure exactly backwards. Plaintiffs undisputed facts are irrelevant.

Plaintiff cannot avoid summary judgment by proposing undisputed facts. She may only do so by creating

a genuine issue of material fact as to Ms. Maxwell's statement of undisputed facts.

Accordingly, this court should strike plaintiff statement of undisputed facts. Although Ms. Maxwell,

as the summary judgment movement, has no duty to respond to plaintiffs alleged undisputed facts,

we hasten to add that Ms. Maxwell in fact opposes and disputes most of plaintiffs alleged undisputed facts.

For example, defendants undisputed fact 40 includes the statement, Ms. Roberts has hired

it as a seasonal spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she

had turned 17. Yet plaintiff sets forth in her own undisputed fact 58 that Virginia got a job

at Mar-a-Lago in 2000, either months before or just after her 17th birthday. Plaintiff has done

nothing more than set forth her dispute with defendant undisputed fact 40 as her own undisputed fact.

It makes no sense. See also plaintiffs undisputed facts 63. The other alleged undisputed facts are

simply plaintiff's assertion of her deposition testimony and hearsay of her statements to other

witnesses couched as undisputed facts. Ms. Maxwell strenuously disputes almost all of the alleged

undisputed facts, claiming that she engaged in any sort of sexual acts, misconduct, or communication

with plaintiff or others. Indeed, over the course of two days and 13 hours of deposition, Ms. Maxwell

disputed all such allegations. Because none of plaintiffs undisputed facts have anything to do with

the issues raised by defendant's motion for summary judgment, Ms. Maxwell moves to strike

plaintiff's statement of undisputed facts. Conclusion for the foregoing reasons Ms. Maxwell

requests that the court deemed her undisputed facts admitted and that the court strikes plaintiff's

statement of undisputed facts. This was signed on February 10th of 2017 and it was signed by Laura

Meninger. All right folks, that's going to do it for this one. All of the information that goes

with this episode can be found in the description box.

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