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Mega Edition: Virginia Roberts Responds To Ghislaine Maxwell's Rule 56.1 Statement Of Facts (Part 7-9) (3/28/26)
About this Episode
In response to Ghislaine Maxwell's Rule 56.1 Statement of Undisputed Material Facts, Virginia Giuffre (formerly known as Virginia Roberts) submitted a detailed counterstatement challenging Maxwell's assertions. Giuffre disputed Maxwell's denials of involvement in Jeffrey Epstein's alleged sexual abuse and trafficking operations, providing specific instances and evidence to support her claims. She contended that Maxwell's public statements dismissing her allegations as false were themselves defamatory and aimed at discrediting her experiences as a victim. Giuffre's response emphasized the existence of genuine disputes over material facts, arguing that these issues necessitated a trial to resolve the conflicting accounts.
Giuffre's counterstatement also highlighted inconsistencies and omissions in Maxwell's narrative, aiming to demonstrate that Maxwell's involvement with Epstein was more extensive than acknowledged. By presenting corroborative testimonies and documentary evidence, Giuffre sought to undermine Maxwell's credibility and reinforce the legitimacy of her own allegations
to contact me:
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Giuffre's counterstatement also highlighted inconsistencies and omissions in Maxwell's narrative, aiming to demonstrate that Maxwell's involvement with Epstein was more extensive than acknowledged. By presenting corroborative testimonies and documentary evidence, Giuffre sought to undermine Maxwell's credibility and reinforce the legitimacy of her own allegations
to contact me:
[email protected]
Transcript
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What's up, everyone?
And welcome back to the Epstein Chronicles.
In this episode, we're going to pick up,
right where we left off, with the SDNY rule 56.1
Court document.
The defendants purported facts, 44.
From August, 2001, until September, 2002,
Epstein and Maxwell were almost entirely absent from Florida
on documented travel on accompanied by Miss Roberts.
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 accompanied by Miss Roberts between August, 2001
and September of 2002.
Rogers maintaining a 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 13 months of the 22 months
from November, 2000, until September, 2002,
that Miss Roberts lived in Palm Beach and new Epstein.
Epstein was traveling outside of Florida
on accompanied by Miss Roberts.
During the same period of time, Miss Roberts was employed
at various jobs enrolled in school
and living with her boyfriend.
Miss Roberts statement,
contributing the defendant's facts.
The flight logs produced in this matter
provide substantive evidence of Miss Roberts travel
in the control of defendant and Epstein,
but are clearly incomplete.
Moreover, Miss Roberts also was flown
by defendant on commercial flights,
Seamalcoly Declaration, at exhibit five.
Roberts' deposition at 155 through 5 and 11.
Miss Roberts disputes defendant statement
to the country as reliance upon incomplete records
to prove that Miss Roberts was not in fact
in the presence of defendant and Epstein is insufficient.
Miss Roberts incorporates additional details
contained in response 38 and 46 herein.
Miss Roberts obvious gap in her school records,
her presence verified by Epstein's pilot on flight logs
and witness testimony corroborate her story
that she was traveling with defendant and Epstein.
In fact, flight logs and pilot testimony clearly proved
that Miss Roberts was flying domestic
and internationally with Epstein at least 32 times
between 1211 of 2000 and 728 of 2001 and 621 of 02
and 821 of 02.
Defendant traveling with Miss Roberts on 23 of the flights.
As defendant acknowledges in her own statement,
flight records are incomplete.
There are several pilots and co-pilots
that flew Epstein and Maxwell, Lawrence, Larry Vesosky,
David, Dave Rogers, Bill Hammond, Pete Rathgeb,
Gary Roxberg and Bill Murphy in multiple aircrafts.
Yet only one pilot, David Rogers produced flight records.
Seamalcoly Declaration at exhibit 41.
David Rogers flight log.
In addition, many of the girls recruited by defendant
routinely traveled on commercial flights
for the purpose of providing massages to Epstein
or guests at Epstein's New York, New Mexico
or US Virgin Island homes.
Seamalcoly Declaration at exhibit 16.
As thoroughly depicted below, Miss Roberts passport application,
travel records and witness testimony clearly demonstrate
flight logs are incomplete because only one pilot kept a log
and Miss Roberts also flew commercially
while she worked for defendant and Epstein.
For example, on December 11, 2000, while underage,
Miss Roberts appears on Roger's flight log flight number 1433,
traveling with Epstein, Maxwell and Emmy Taylor
from Palm Beach to Titorboro,
then on December 14, 2001,
continues traveling with Epstein and Maxwell
to the US Virgin Islands.
However, there is no flight record
of Miss Roberts return to Palm Beach.
Seamalcoly Declaration at exhibit 15.
Question, and do you know how Jeffrey Epstein
glane Maxwell, Adam Perry Lang and Virginia get off
of St. Thomas or leave the island answer no I don't,
probably a charter I'm guessing.
And just to interject real quick,
all of Jimmy Kimmel's nonsense recently
after the statements made by Aaron Rogers about Kimmel
and Epstein, well that all might be correct
that he had nothing to do with Epstein per se,
but notice he doesn't comment on his buddy,
Adam Perry Lang, right?
You know, it was good buddy, Adam Perry Lang here,
who was Jeffrey Epstein's personal chef.
And it was traveling around with Virginia and other girls.
Maybe you want to comment on that, Mr. Kimmel.
On January 26, 2001, while underage,
Miss Roberts appears on Roger's flight log flight 1444,
traveling with Epstein, Maxwell and Emmy Taylor
from T.E.B to PBI Palm Beach.
However, there is no flight record indicating
how Miss Roberts got to New York on January 27, 2001,
1445 continues traveling with Epstein, Maxwell and Emmy Taylor
from Palm Beach to the US Virgin Islands,
returning from US Virgin Islands,
four days later on January 30, 2001,
see McCauley Declaration at exhibit 15.
On March 5, 2001, Miss Roberts, Maxwell, Epstein,
Emmy Taylor traveled together,
internationally flight 1464,
leaving West Palm Beach to Stevenville, Canada.
Then on March 6, 2001,
they continued on to Paris, France,
with a layover for three days.
On March 8, 2001, other passengers,
including one unidentified female,
joined the Montflights 1466 and 1467
from Paris, France to Grenada, Spain,
eventually landing in London, England.
On March 11, 2001,
where she was then introduced to and lent out to Prince Andrew,
see McCauley Declaration at exhibit 15.
Miss Roberts, Epstein, Maxwell and Taylor
remained in London for three days
until departing on March 11, 2001,
stopping in Bangor, Maine,
before departing back to Titorboro.
However, there is no flight record
of Miss Roberts' return to Palm Beach.
On March 7, 2001, while underage,
Miss Roberts, Maxwell, Epstein, Emmy Taylor,
two unidentified females and others traveled together
from Palm Beach to Titorboro.
Then three days later, on March 29, 2001,
continued on 1479 to Santa Fe, New Mexico,
returning to Palm Beach with Nadia Borlin,
on March 31, 2001,
see McCauley Declaration at exhibit 15.
A few glaring examples of how Miss Roberts travel records
are incomplete is that Miss Roberts traveled
from ADS, Addison, Texas on May 3, 2001,
on 1501 to San Antonio, Texas,
then depart San Antonio, Texas on May 5, 2001,
on flight 1502 to Pine Bluff, Arkansas.
But there is no record produced that explains
how Miss Roberts arrived in Addison, Texas
or how she returned to Palm Beach
from Pine Bluff, Arkansas.
Although Epstein's plane appears to have originated
from Palm Beach on April 23, 2001,
Miss Roberts' name does not appear on the log.
See Roberts' deposition, Example 1.
Question, do you know how Virginia Roberts
got to Addison, Texas?
Answer no, question, went to Addison
and picked up Virginia Roberts.
Answer, it looks like it.
Another prime example of how incomplete Miss Roberts
travel records are is on May 14, 2001,
while Miss Roberts appears on flight 1506
with Epstein, Maxwell, Emmy Taylor,
and others, including one unidentified female
from the US Virgin Islands to Tita Burrow.
There is no record produced explaining how Miss Roberts
arrived in the US Virgin Islands
or where she stayed when she landed in New York.
See McCauley Declaration at Exhibit 15,
Roger's Deposition Example 1.
Question, what were the other possible avenues
back in those days for Jeffrey Epstein, Golan Maxwell,
to travel to the Virgin Islands?
Answer, they could have done a charter possibly.
Question, all right, so at some point in time
between May 7th and May 14th, answer, uh-huh, question.
Somebody flies the Gulf Stream to the Virgin Islands.
Answer, correct.
Question, and who would that be?
Answer, Larry Vesosky, and I don't know
who the other person would have been.
Question, do you know where Virginia Roberts went
during that time after she landed in Tita Burrow
on the 14th?
Answer, I do not.
On June 3rd, 2001, Miss Roberts
travels from Palm Beach to US Virgin Islands
on flight 1510 for three days, then on June 5th, 2001,
continues on flight 1511 to Tita Burrow.
However, there is no record of Miss Roberts
returning to Palm Beach.
See Roger's Deposition Example 1.
Then on July 4th, 2001, Miss Roberts reappears
on flight 1524 with Epstein and an unidentified female,
leaving US Virgin Islands to return to Palm Beach.
However, there is no flight record that reflects
how Miss Roberts got to the US Virgin Islands,
see McCauley Declaration at Exhibit 15.
Roger's Deposition Example 1.
Question, and do you know how Virginia
got to the Virgin Islands?
Answer, no.
Question, is there any, is it possible
that the Cessna tooker or the Boeing tooker
or any other aircraft that is owned by Jeffrey?
Answer, no.
I would, if I had to guess, I would guess the airlines.
Again, on July 8th, 2001, Miss Roberts
appears on flight 1525 with Epstein and Maxwell,
Emmy Taylor and others, including an unidentified female
departing Palm Beach to Tita Burrow.
Four days later, on July 11th, 2001, Miss Roberts,
Epstein and Maxwell, continue on 1526 to CPS,
Kehokia St. Louis Illinois, which was a stop due
to mechanical delay on the way to Santa Fe, New Mexico.
However, there is no flight record that reflects
how Miss Roberts returns home to Palm Beach,
see McCauley Declaration at Exhibit 15.
Roger's Deposition Example 1.
Question, and then three days later,
you leave out of Tita Burrow to CPS?
Answer, yes.
Question, where is that?
Answer, that is St. Louis, actually,
it's Kehokia, Illinois, across the river from St. Louis.
Question, who are your passengers?
Answer, Jeffrey Epstein, Golan Maxwell,
Emmy Taylor, Virginia Roberts.
We were actually on route to Santa Fe.
We had a mechanical problem,
and we had to go in there for some maintenance.
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On July 16th, 2001,
Miss Roberts appears on flight 1528 with Epstein Maxwell
and Emmy Taylor from Santa Fe to Titorboro.
However, Miss Roberts flight to Santa Fe
is missing from the records.
In addition, on July 28th, 2001, Miss Roberts appears
on the flight log 1531, returning with Epstein
from the US Virgin Islands to Palm Beach.
However, there is no record of Miss Roberts flight
to the US Virgin Islands.
See McColley Declaration at Exhibit 15.
On June 21st, 2002, Miss Roberts appears on flight 1570
with Epstein Maxwell, Sarah Kellen, Cindy Lopez,
and Jean-Luc Brunel from Palm Beach to Georgetown Bahamas.
However, there is no record of Miss Roberts returning
the Palm Beach, see McColley Declaration at Exhibit 15.
See Roberts' deposition, example one.
Question for junior Roberts was taken to the Bahamas.
Do you know where she went from there?
Answer, I do not.
On August 17th, 2002, Miss Roberts appears on flight 1589
with Epstein Maxwell, Sarah Kellen, Cindy Lopez,
and others from Santa Fe, New Mexico to Titorboro.
Miss Roberts returns to Palm Beach, Florida,
on August 18th, 2002 with Epstein,
and one unidentified female.
See McColley Declaration at Exhibit 15.
See Rogers' deposition, example one.
Question, do you know how Virginia Roberts got the Santa
Fe? Answer, no.
From September 29th, 2002, through October 19th, 2002,
defendant and Epstein sent Miss Roberts
on a commercial flight to Thailand for a massage training
and provided her with all the accommodations.
See McColley Declaration at Exhibit 43.
All right folks, we're on a wrap-up right here,
and then the next episode dealing with the topic
will pick up where we left off.
All of the information that goes with this episode
can be found in the description box.
What's up everyone, and welcome back to the Epstein Chronicles.
In this episode, we're gonna pick up where we left off
with the rule 56.1 S-D-N-Y court document.
The defendants purported facts, 45.
Miss Roberts and Figueroa shared a vehicle during 2001 and 2002.
Miss Roberts and Figueroa shared a 1993 white Pontiac
in 2001 and 2002.
Miss Roberts freely traveled around the Palm Beach area
in that vehicle.
In August of 2002, Miss Roberts acquired a Dodge Dakota
pickup truck from her father.
Figueroa used that vehicle in a series of crimes
before and after Miss Roberts left for Thailand.
Miss Roberts stayed in contraverting the defendants' facts.
Miss Roberts and Tony Figueroa did not share a vehicle
during 2001 and 2002.
Instead, Figueroa borrowed Miss Roberts' car
while she was traveling with defendant and Epstein.
Figueroa testified that he got to take the car
because she was going somewhere else in the world
and did not need it, so Figueroa deposition at 89 and 90.
In fact, Miss Roberts was frequently traveling
with defendant and Epstein.
See McCauley Declaration at Exhibit One.
A Lese deposition, TR at nine through 14,
stating that Virginia started traveling on an airplane
with Golan and Jeffrey, not too long after she started going
over to the house, Figueroa further testified
that Virginia would normally go about two weeks
out of every month with Epstein.
Figueroa deposition TR at 90.
He further stated, pretty much every time I took her there,
it was always to his mansion, I picked her up one time,
maybe it was a couple of times from the jet stream place,
but pretty much every single time
it was at the mansion.
Moreover, Miss Roberts testified she purchased a car
from the $10,000 payment she received from Epstein
after she was forced to have sex with Prince Andrew
in London at Defendant's Home
when Miss Roberts was a minor.
See McCauley Declaration at Exhibit Five.
Defendants reported facts, 46.
Miss Roberts held the number of jobs in 2001 and 2002.
During 2001 and 2002, Miss Roberts was gainfully employed
at several jobs.
She worked as a waitress at Menino's Restaurant,
at TGI Friday's Restaurant,
AKA CCI of Royal Palm Incorporated,
and at Roadhouse Grill.
She was also employed at Courtyard Animal Hospital,
AKA Mark Pinkwaster, DVM.
Miss Roberts statements,
Controverting Defendants Facts.
This statement is laughable.
Miss Roberts was hardly gainfully employed
during a time period in which she was trying to escape
from the grip of Epstein and Maxwell.
While social security provides that she earned
normal amounts of earning statements for 2001 and 2002,
the records do not indicate the month
or quarter of the year's work.
See McCauley Declaration at Exhibit 46.
For a brief period, Miss Roberts attempted to go back
to school to earn her GED and tried unsuccessfully
to hold down waitressing jobs.
See McCauley Declaration at Exhibit 27.
For example, in 2001, Miss Roberts earned $212
as a waitress working briefly at Menino's Restaurant.
See McCauley Declaration at Exhibit 5.
In 2002, Miss Roberts earned $403.64
at CCI of Royal Palm Beach,
working there TGI Friday's for a short period of time.
See McCauley Declaration at Exhibit 5.
Then Miss Roberts worked at Roadhouse Grill
until about March 2002, earning $1,247.90.
According to Dr. Pinkwasser's records,
Miss Roberts also received payroll checks
for weeks ending 422.02 and 6402,
earning a total of $1,561.71.
Not long after Miss Roberts losing her job
at Courtyard Animal Hospital, flight records show
that Miss Roberts was soon back under Epstein's control,
traveling with Maxwell to the Bahamas, Santa Fe, New York,
and then New Mexico.
See McCauley Declaration at Exhibit 47.
The defendants reported facts.
Number 47.
In September 2002, Miss Roberts traveled to Thailand
to receive massage training and while there
met her future husband and a lope with him.
Miss Roberts traveled to Thailand in September 2002
to receive formal training as a masseuse.
Figueroa drove her to the airport and while there,
she initially contacted Figueroa frequently,
incurring a phone bill of $4,000.
She met her husband 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 2016.
Miss Roberts' statement,
Controverting Defendants Facts.
Miss Roberts did travel to Thailand
to receive massage training in September of 2002.
However, defendant has inaccurately told only part of the story.
Defendant has conveniently left out certain key facts
which includes the fact that Miss Roberts was given an assignment
from the defendant and Epstein that she had to recruit
another underage girl from Thailand
and bring that young girl back to Epstein.
See McCauley Declaration at Exhibit 43.
The document Miss Roberts was given,
directs her to call Miss Maxwell,
see McCauley Declaration at Exhibit 32.
It's not disputed by the defendant or Epstein
that Miss Roberts was expected to return
to Epstein and Maxwell upon completion
of her massage training and assignment.
It is undisputed by Miss Roberts
that she did not return to defendant and Epstein
but instead escaped clear across the world to Australia
where she remained in hiding from defendant and Epstein
for several years.
Defendants purported facts.
Number 48.
Detective Rikari's investigation of Epstein
fell to uncover any evidence that Miss Maxwell
was involved in sexual abuse of minors,
sexual trafficking or a production or possession
of child pornography.
Joseph Rikari served as the lead detective
from the Palm Beach Police Department
charged with investigating Jeffrey Epstein.
That investigation commenced in 2005.
Rikari worked only on the Epstein case for an entire year.
He reviewed previous officer's reports and interviews,
conducted numerous interviews of witnesses
and 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 Miss Maxwell's name
and she was never considered a suspect by the government.
None of Epstein's alleged victims said they had seen
Miss Maxwell at Epstein's house
nor said that they had been recruited buyer
nor paid any money buyer nor told what to wear
or how to act buyer.
Indeed, none of Epstein's alleged victims
ever reported to the government
that they had met or spoken to Miss 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 Miss 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.
Detective Rikari when asked to describe everything
that you believe you know about Elaine Maxwell's
sexual trafficking conduct replied, I don't.
He confirmed he has no knowledge about Miss Maxwell
sexually trafficking anybody.
Detective Rikari also has no knowledge
of Miss Robert's conduct that is subject to this lawsuit.
Miss Robert's statement,
contributing defendants facts.
This statement is false.
Detective Rikari knew that Maxwell was involved
in the illegal sexual activities at Epstein's house.
He wanted to speak to her, but Maxwell did not return
his calls.
See McCauley declaration at exhibit 13.
Detective Rikari concluded that defendants role
was to procure girls for Epstein.
See McCauley declaration at exhibit 13.
In the execution of the search warrant,
stationary was found in the home bearing Maxwell's name
and notes were written by House Staff to Maxwell.
See McCauley declaration at exhibit 13.
See also message pads.
Robert 001412.
A key piece of evidence in the investigation
were message pads uncovered in trash pools
and from inside the residence during the search warrant.
Those message pads revealed numerous calls
left at the house for Maxwell,
indicating she was staying in the house
during the days when Epstein was engaging
in illegal sex acts with minors.
Additionally, a walkthrough video taken
during the execution of a search warrant,
reveal photos of topless females at the home
and there was even a photograph of Maxwell naked
hanging in the home.
The House Staff, who were deposed in the civil cases,
each testified to Maxwell being the boss
in charge of everyone in the house.
See McCauley declaration at exhibit 1.
Rodriguez, the house butler from 2004 to 2005,
a time period that revealed a daily sexual abuse
of underage females, testified that Maxwell kept the list
of the local girls who were giving massages at her desk
and that Maxwell kept nude photos of the girls
on our computer.
See McCauley declaration at exhibit 21.
Recari testified that when the search warrant was executed,
the house had been sanitized and the computer
is removed from the home.
See McCauley declaration at exhibit 13.
Recari deposition at 72.25 through 73.15.
Banazi act testified that the computers were removed
by Adriana Ross, another employee who entered the Maxwell.
See McCauley declaration at exhibit 19.
The record is replete with testimony demonstrating
that Maxwell recruited Virginia and recruited other females
who in turn recruited other females,
all who were sexually abused by Epstein,
meaning it is undisputed that Maxwell started
the top of the pyramid of local Palm Beach girls
who were all eventually identified as victims.
See McCauley declaration at one.
The co-conspirator who maintained direct contact
with many underage victims was Sarah Kellen,
whose sole responsibility was to schedule underage girls
to visit Epstein for sex.
Sarah reported directly to Maxwell,
see McCauley declaration at exhibit 21.
On the day that the search warrant was executed, the house made,
Rubio was scheduled to report to the house that day at 8 a.m.
However, she received a call from Maxwell,
telling her not to go.
See McCauley declaration at exhibit 20.
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Hi, this is Alex Cantrowitz.
I'm the host of Big Technology podcast,
a long time reporter and an on air contributor to CNBC.
And if you're like me, you're trying to figure out
how artificial intelligence is changing the business world
and our lives.
So each week on Big Technology,
I bring on key actors from companies building AI tech
and outsiders trying to influence it,
asking where this is all going.
They come from places like Nvidia, Microsoft, Amazon,
and plenty more.
So if you want to be smart with your wallet,
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Maxwell orchestrated and ran the entire sex trafficking
scheme from a high level and insulated herself
from most of the underage girls who were being paid for sex.
Tony Figueroa, Miss Roberts' boyfriend,
did testify that Maxwell personally requested
that he find and bring girls to Epstein for sex
once Miss Roberts had escaped
and that when he brought the girls,
Maxwell interacted with them.
See McCauley declaration at exhibit four,
Figueroa deposition at 200 and 228, 23.
Rodriguez testified unequivocally that Maxwell was the boss
and that she knew everything that was going on.
See McCauley declaration at exhibit 21.
All right folks, we're on a wrap up right here
and in the next episode,
talking about the topic we'll pick up where we left off.
All of the information that goes with this episode
can be found in the description box.
What's up everyone and welcome back to the Epstein Chronicles.
In this episode, we're diving right back in
to the SDNY56.1 court documents
and we're gonna pick up where we left off.
The defendant's purported facts, 49.
No nude photograph of Miss Roberts was displayed
in Epstein's home.
Epstein housekeeper, Juan Alessi,
never saw any photographs of Virginia Roberts
in Mr. Epstein's house, Detective Recari
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.
Miss Roberts statement,
contributing the defendant's facts.
This is false.
Nude photographs were displayed throughout Epstein's home.
Furthermore, Alfredo Rodriguez testified
to Maxwell having pornography on her computer,
Rodriguez deposition.
He also testified to their being,
a collage of nude photos in Epstein's closet,
ID at 253.
That collage was eventually taken
into evidence by Detective Recari who testified to the fact
in his deposition,
Seema Colley Declaration at Exhibit 13.
And those photos are still in the possession of the FBI
or the US Attorney's Office.
Seema Colley Declaration at Exhibit 13.
Numerous other people have testified
about nude photographs being on display
in the home, including Ronaldo Rizzo,
who visited the home on numerous occasions
and who was reprimanded by Maxwell herself
for looking at the nude photos.
Seema Colley Declaration at Exhibit 14.
Additionally, the search warrant video
taken at the time when the house had already been sanitized,
revealed photographs of nudity displayed,
including a photograph of Maxwell herself in the nude.
Seema Colley Declaration at Exhibit 44.
Search warrant video attached to the deposition of Recari.
Johanna Schoberg testified that the defendant
bought her a camera for the specific purpose
of her taking nude photos of herself.
Seema Colley Declaration at Exhibit 16.
Finally, Virginia Roberts testified
that there was a nude photograph of her at the house.
Seema Colley Declaration at Exhibit 5.
Defendants purported facts.
Number 50.
Miss Roberts intentionally destroyed her journal
and Dream Journal regarding her memories of this case
in 2013 while represented by council.
Miss Roberts drafted a journal describing individuals
to whom she claims 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.
Miss Roberts also kept a dream journal
regarding her thoughts and memories
that she possessed in January 2016
to date Miss Roberts cannot locate the dream journal.
Miss Roberts statement controversy the defendant's facts.
The dream journal contained memories of Miss Roberts dreams.
While Miss Roberts has looked for this journal
which is wholly relevant to the case,
she has been unable to locate it.
Miss Roberts also wrote in a personal journal.
Some of her experiences with Maxwell and Epstein,
which were harmful and painful
in an effort to relieve herself
of those past painful experiences,
Miss Roberts followed the advice of a therapist
and burned the journal as a form of cathetic release
at a time when she was under no obligation
to maintain the personal memorialization
of personal and painful experiences.
See McCauley Declaration at exhibit five.
Defendants purported facts, 51.
Miss Roberts publicly peddled her story beginning in 2011.
Miss Roberts granted journalist Sharon Churchill
extensive interviews that resulted
in seven widely distributed articles
from March 2011 through January 2015.
Churchill regularly communicated with Miss Roberts
and her attorneys or other agents
from early 2011 to the present day.
Miss Roberts received approximately $160,000 for her stories
and pictures that were published by many news media organizations.
Miss Roberts statement contributing defendants facts.
Defendants statement, Miss represents history.
In 2011, Miss Roberts was still in hiding
from Epstein and Maxwell in Australia.
Miss Roberts was not looking to sell anything
or even to speak with anyone about what had happened to her
in her previous life from which she had dramatically escaped.
Journalist Sharon Churchill located Miss Roberts
and impressed the importance of Miss Roberts standing up
to those who had harmed her
and to speak with federal authorities,
which Miss Roberts did in 2011.
See McCauley Declaration at exhibit 31, redacted 302.
In addition, Churchill impressed the importance
of bringing the abuse of defendant
and Epstein the public light to prevent
their continued abuse of others.
See McCauley Declaration at exhibit 35.
After much deliberation, Miss Roberts agreed to be interviewed
by Churchill and was compensated for sharing her story
which came at a heavy price of being publicly scrutinized.
Defendants purported facts.
Miss Roberts drafted a 144 page purportedly
autobiographical book manuscript in 2011,
which she actively sought to publish.
In 2011, contemporaneous with her church interviews,
Miss Roberts drafted a book manuscript
which purported to document Miss Roberts' experiences
as a teenager in Florida,
including her interactions with Epstein and Maxwell.
Miss Roberts 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.
Miss Roberts statement,
contributing the defendant's facts.
Defendants characterization of these activities
are out of context and thus misleading.
In 2008, Miss Roberts received a victim notification
letter from the United States Attorney's Office
for the Southern District of Florida,
see McCauley Declaration at Exhibit 30.
It was regarding her sexual victimization by Epstein.
Thereafter, in 2011,
she sought psychological counseling from a psychologist
for the trauma that she endured.
Also, that year,
journalist Sharon Churcher sought her out
and traveled halfway around the globe
to interview her on painful subjects.
Miss Roberts was interviewed by the FBI in 2011,
see McCauley Declaration at 31.
She was also getting psychological help,
see McCauley Declaration at Exhibit 38.
In that situation,
Miss Roberts began to draft a fictionalized account
of what happened to her.
It was against this backdrop of her trauma being unearthed,
her steps to seek psychological counseling for it,
that she drafted this manuscript,
doing so was an act of empowerment
and a way of reframing and taking control
over the narrative of her past abuse, that answer.
Writing I has been an emancipatory project for women,
Perot, Gene Autobiography Transformation,
Women Autobiography Theory a Reader edited
by Sedone Smith and Julia Watson.
Indeed, scholars have written that the act of engaging
in autobiography or even accounts loosely based
on autobiography is a process of taking control
of one's own narrative and one's own self.
Thus a specific recitation of identity
involves the inclusion of certain identity contents
and the exclusion of others,
the incorporation of certain narrative itineraries
and internationalities, the silencing of others,
the adoption of certain autobiographical voices
and the muting of others.
Smith Sedone performedativity autobiographical practice.
Indeed, even a cursory look at the manuscript
penned by Ms. Roberts informs the reader
that she is trying to put forth a more palatable
and more empowering narrative to overwrite
that powerlessness she felt when being abused
by the defendant and by Epstein.
While Ms. Roberts explored trying to publish her story
to empower other individuals who were subject to abuse,
she ultimately decided not to publish it.
See McCauley Declaration at Exhibit Five.
Defendants purported facts, 53, Ms. Roberts,
publicly filed lurid CVRA pleadings,
initiated a media frenzy and generated
highly publicized litigation between her lawyers
and Alan Dershowitz.
On December 30, 2014, Ms. Roberts,
through council, publicly filed a joineder motion
that contained her lurid allegations about Ms. Maxwell
and many others, including Alan Dershowitz,
Prince Andrew, and Jean-Luc Brunel.
The joineder motion was followed by a corrected motion
and two further declarations in January and February of 2015,
which repeated many of Ms. Roberts claims.
These CVRA pleadings generated a media maelstrom
and spawned highly publicized litigation
between Ms. Roberts lawyers, Edwards and Cassel
and Alan Dershowitz.
After Ms. Roberts publicly alleged Mr. Dershowitz
of sexual misconduct, Mr. Dershowitz vigorously
defended himself in the media.
He called Ms. Roberts a liar and accused her lawyers
of unethical conduct in response to Terny's Edwards
and Cassel, Sue Dershowitz, who counterclaimed.
This litigation, in turn, caused additional media attention
by national and international media organizations.
Ms. Roberts' statement,
contributing the defendant's facts,
see Ms. Roberts' paragraph seven,
Supra, explaining why the allegations were necessary
and appropriate for multiple reasons.
Ms. Roberts disputes defendant's false characterization
of these events and, indeed, the media attention
was caused by defendant issuing her defamatory press release.
Defendants purported facts, 54.
Ms. Roberts formed non-profit victims refuse silence
to attract publicity and speak out on public controversy.
In 2014, Ms. Roberts, with the assistance of the same counsel,
formed a non-profit organization, victims refuse silence,
according to Ms. Roberts, the purpose of the organization
is to promote Ms. Roberts' 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.
Ms. Roberts attempts to promote victims'
refused silence at every opportunity.
For example, Ms. Roberts participated in an interview
in New York with ABC to promote the charity
and to get her mission out to the public.
Ms. Roberts' statement,
contributing the defendant's facts.
Ms. Roberts did not form the non-profit victims'
refuse silence to speak out on a public controversy,
but instead to simply help survivors
of sexual abuse and sexual trafficking.
In order to provide assistance to victims, Ms. Roberts,
attempted to talk about the non-profits mission
when she had the opportunity to do so.
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Miss Robert statement of undisputed facts.
55 Virginia Roberts was born August 9, 1983, 56.
Virginia turned 18 on August 9, 2001.
57 in 2000 Virginia's father Sky Roberts
worked at the Mar-a-Lago, 58.
Sky Roberts got Virginia a job at Mar-a-Lago in 2000,
either months before or just after Virginia's 17th birthday.
59 the only year in which Virginia was employed
at Mar-a-Lago was 2000.
60 Virginia worked at Mar-a-Lago
as a spa bathroom attendant, 61.
Virginia was not a masseuse at Mar-a-Lago,
as she had no massage experience.
62 Maxwell approached Virginia at Mar-a-Lago
and recruited her to come to Jeffrey Epstein's house,
see McCauley Declaration, exhibits one, five, and 17.
63 at the time Maxwell recruited Virginia
to Jeffrey Epstein's house, Virginia was either 16
or 17 years old, depending on whether this occurred
just before or just after Virginia's birthday.
64 Virginia followed Maxwell's instructions
and reported to Jeffrey Epstein's house on the night
of the day when Maxwell approached Virginia at Mar-a-Lago.
65 Maxwell told Virginia at Mar-a-Lago
that Virginia could get paid for giving a massage
to Jeffrey Epstein, see McCauley Declaration at exhibit five.
66 when Virginia arrived at Epstein's house,
she was taken upstairs to Epstein's bedroom
and instructed by Maxwell and Epstein
how to give Epstein a massage.
67 Epstein and Maxwell turned the massage
into a sexual encounter, 68.
Virginia was not a professional masseuse
and was not old enough to be a masseuse in Florida
even though Maxwell testified she only hired
professional masseuses, 69.
Maxwell and Epstein promised Virginia money
and a better life in exchange for complying
with their sexual demands, 70.
Maxwell had sex with Virginia and other females,
71, Virginia was trafficked nationally
and internationally for sexual purposes, 72.
Maxwell recruited other non-professionals
under the guise of being a masseuse
but in reality only recruited girls for sexual purposes.
73 Maxwell was the boss of others
whose job it was to recruit minor females for Epstein
for sex such as Sarah Kellen, 74.
Maxwell was a recruiter of underage girls
and other young females for Epstein for sex
and was the boss in charge of those females.
This document was dated on January 31st, 2017
and it was signed by Sigrid McCauley.
All right folks, that's a wrap for the rule 56.1 document
and in the next episode we'll keep it moving.
All of the information that goes with the episode
can be found in the description box.
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