Mega Edition: Virginia Roberts Responds To Ghislaine Maxwell's Rule 56.1 Statement Of Facts (Part 3-4) (3/30/26)

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

In this episode we're going to pick right back up where we left off.

With a southern district of New York, local rule 56.1, plaintiff statement of contested facts,

and plaintiffs undisputed facts. 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 in Joanne Pue 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 Miss Maxwell to Miss Robert's

allegations in the motion. Miss Robert's statement, contraverting defendants facts,

Miss Robert's agrees to the first sentence, the second sentence is a false.

Accordingly, there is no record evidence that Gal or anyone else selected journalists for a response

or that there was any selection process whatsoever to the contrary, Gal testified that anyone

who inquired received a reference to the January 2015 defamatory response.

Question, to the extent you can recall or could it estimate how many other emails do you believe

you sent bearing that statement that's in exhibit two? Answer, I really can't remember,

but certainly more than six and probably less than 30, some are in between.

Anytime there was an incoming query, it was either dealt with on the telephone by referring

them back to the two statements of March 2011 and January 2015, or someone would email them the

statement. So no one was left unanswered. Broadly, is the is where we were, but I can't remember

every single person reached out to see McCauley declaration at exhibit six. Defendants purported

facts. 20. The email to the media members said to whom it may concern, please find attached

a quotable statement on behalf of Miss Maxwell, no further communication will be provided by or

on this matter. Thanks for your understanding, best Ross. Jando 3 is Virginia Roberts, so not a

new individual. The allegations made by Victoria Roberts against Golan 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 Miss Roberts that Alan Dershowitz is involved

in having sexual relations with her, which he denies. Miss Roberts claims are obvious lies,

and should be treated as such and not publicized as news, as they are the famitory.

Golan Maxwell's original response to the lies and the famitory 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.

Miss Roberts statement, contraverting defendants facts. While defendant cropped the body text

of the email that was sent to the news media representatives, she completely omitted the

headings and metadata. Miss Roberts has put an image of the email below in Miss Roberts' paragraph,

CGM0068. Defendants purported facts, 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. Gow's firm Acuity Reputation. Miss Roberts statement, contraverting the defendants

facts. Defendants said Mr. Barton, who prepared the statement, did not intend it as a traditional

press release solely to dissemination information to the media. Miss Roberts contested the statement,

and all statements regarding Mr. Barton's beliefs and purposes and the like. Further,

as stated in detail, in Miss Roberts' opposition defendants' motion for a summary judgment,

this court should not even consider the Barton Declaration. Additionally, there is absolutely no

record evidence of Barton's intent and the court should not consider it. The next sentence states,

so he intentionally did not pass it, the press release, through a public relations firm,

such as Mr. Gow's firm Acuity Reputation. Again, there is zero record evidence to support any

assertion of Mr. Barton's intent. To the extent that the sentence claims that Barton did not give

the statement, to Gow with instructions to publish it, see McCauley Declaration at exhibit 48.

To the extent that the sentence claims that the statement did not pass through a public relations

firm, such as Mr. Gow's firm Acuity Reputation, Miss Roberts disputes that statement.

Record documentary evidence and testimony established that this statement was disseminated through

a public relations firm, namely Ross Gow's firm Acuity Reputation. See McCauley Declaration

at exhibit six. The defendants purported facts. The January 2015 statement served two purposes.

First, Mr. Barton intended that it mitigate the harm to Miss Maxwell's reputation from the press

republication of Miss Roberts' false allegations. He believed these ends could be accomplished by

suggesting to the media that among other things they should subject Miss Roberts allegations

to inquiry and scrutiny. For example, he noted in the statement that Miss Roberts allegations

changed dramatically over time, suggesting that they are obvious lies and their force should not

be publicized as news. Miss Roberts statement, contributing defendants facts. Miss Roberts objects

to this paragraph in its entirety. She disputes that the January 2015 statement served two purposes,

as this statement is wholly unsupported by the record, which defendant again neglects to cite.

Miss Roberts also contests the second sentence in which defendant claims that Mr. Barton intended

that it mitigate the harm to Miss Maxwell's reputation from the press republication of Miss Roberts'

false allegations. First, Miss Roberts disputes any statement of Barton's intent as explained

above. Second, Miss Roberts disputes that there was any republication by the press as a matter of

law, as explained in our memorandum of law opposing some re-judgment, as the press did not

republish the press statement under New York law. Third, Miss Roberts disputes that are allegations

or false and sites to the following non-exhaustive sampling of evidence to corroborate our allegations

against the defendant. See McCauley Declaration Exhibit 16, McCauley Declaration Exhibit 4,

McCauley Declaration Exhibit 14, McCauley Declaration Exhibit 12, McCauley Declaration Exhibit 13,

McCauley Declaration Exhibit 15, the excerpt of the Roger's Deposition, see McCauley Declaration at

Exhibit 10 from Arsenecova, see McCauley Declaration at 8 for Kellen, see McCauley Declaration Exhibit 1 for

Olesi, see McCauley Declaration at Exhibit 42 for photographs, McCauley at 30 for US Victim

Notification Letter, McCauley at 33 for New York Presbyterian Hospital Records, McCauley at 38 for

Judith Lightfoot, McCauley at 38 for Message Pads, McCauley at 29 for the Black Book, McCauley at 40

for Sex Lave Books, McCauley at 32 for the Boulder Defendants Center Thailand, McCauley at 39 for

the Palm Beach Police Report, McCauley at 41 for Epstein's Flight Logs. Next Defendants States,

he, Barton, believes these ends could be accomplished by suggesting to the media that, among other things,

they should subject Miss Roberts allegations to inquiry and scrutiny. Miss Roberts disputes

any statements as to Barton's belief, Supra, Miss Roberts disputes that any harm to defendant's

reputation could be mitigated by the media's inquiry into the scrutiny of Miss Roberts allegations

because a deeper inquiry would only reveal additional evidence corroborating Miss Roberts allegations,

such as the evidence put forth in Miss Roberts' opposition memorandum of law and detailed and

the bulleted citation Supra. Defendant then states, for example, he, Barton, noted in the statement

that Miss Roberts allegations changed dramatically over time, suggesting that they are obvious lies,

and therefore should not be publicized as news. First, Miss Roberts disputes that Barton noted

anything in the statement as that is unsubstantiated by the record evidence, not to do defendant's

work for her, but the closest evidence defendant has for such a statement is testimony from the

Gal deposition wherein Gal speculates that Barton had a hand in drafting the press statement,

an opinion which may or may not be based on first-hand knowledge. See McCauley Declaration

at 6 Gal deposition at 4514 through 17. Question, okay, and I say thanks Philip,

because I'm aware of the fact that he had a hand, a considerable hand in the drafting.

This is wholly insufficient to show who drafted the passages quoted by defendant above.

Regardless of those passages, original author, it is ultimately defendant who noted anything

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

Second, Miss Roberts disputes that are allegations of changed over time,

dramatically or otherwise. Third, Miss Roberts disputes that the press release

suggested that her allegations are obvious lies because defendants press release affirmatively,

unambiguously stated that her allegations are obvious lies. There's no subtlety suggestion

or a statement of opinion here. See Roberts versus Maxwell 165F supp.3d 147 152

SDNY 2016. These statements, as they themselves allege, are capable of being proven true or false

and therefore constitute actionable fact and not opinion. Defendants purported facts, 23. Second,

Mr. Barton intended the January 2015 statement to be a shot across the bowel of the media,

which he believed had been unduly eager to publish Miss Roberts allegations without

conducting any inquiry of their own. Accordingly in the statement, he repeatedly noted that

Miss Roberts' allegations were defamatory. In this sense, the statement was intended as a cease

and desist letter to the media recipients, letting the media recipients understand the seriousness

with which Miss Maxwell considered the publication of Miss Roberts' obviously false allegations

and the legal indefensibility of their own conduct. Miss Roberts' statement

Controverting the defendant's facts

This paragraph is another purported statement of defendant's counsel's intent.

Defendant states, second, Mr. Barton intended, the January 2015 statement to be a shot across

the bowel of the media, which he believed had been unduly eager to publish Miss Roberts' allegations

without conducting any inquiry of their own. Not only does defendant once again refer to Mr.

Barton's intent, but she also mischaracterizes the statement as a shot across the bowel of the media.

The press release did not threaten or give warning to the media in any way whatsoever.

See McCauley declaration at exhibit 26-GM-00668.

Next, Miss Roberts disputes the sentences. Accordingly in the statement, he repeatedly noted that

Miss Roberts' allegations were defamatory. Barton did not note anything in the statement,

nor does defendant's site, to any record evidence that he does. Furthermore,

Miss Roberts denies that any of her allegations are defamatory and the slightest as they are all

true and substantiated by record evidence. Miss Roberts also disputes the sentence.

In this sense, the statement was intended as a cease and desist letter to the media recipients,

letting the media recipients understand the seriousness with which Miss Maxwell consider the

publication of Miss Roberts' obviously false allegations and the legal indefensibility of their

own conduct. First, Miss Roberts objects to any statement of Barton's intent as articulated

above. Second, defendant's conventional press release was in no way any type of cease and desist

letter. There is no record evidence in support of this claim and defendant unsurprisingly cites to none.

Third, Miss Roberts disputes that any media recipients would be given to understand the seriousness

with which Miss Maxwell considered the publication of Miss Roberts' obviously false allegations

and the legal indefensibility of their own conduct. By defendant's self-serving press release,

as that is unsupported by the record. Finally, Miss Roberts rejects that her allegations are

obviously false, a claim which is completely unsupported by record evidence.

All right folks we're in a wrap up right there 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 into those core documents and we're going to pick up

where we left off. Taking a look at the southern district of New York's local rule 56.1,

plaintive statement of contested facts and plaintiffs undisputed facts. Number 24,

defendants purported facts. Consistent with those two purposes, Mr. Gals emails

preface the statement with the following language. Please find attached the quotable statement

on behalf of Miss Maxwell. The statement was intended to be a single one-time only comprehensive

response quoted in full to Miss Roberts December 30th 2014 allegations that would give the media

Miss Maxwell's response. The purpose of the preparatory statement was to inform the media recipients

of this intent. Miss Robert's statement, contraverting the defendant's facts. Miss Roberts

disputes that any part of the defendant's press release is consistent with those two of

Barden's purposes. Indeed, Miss Roberts disputes this and any statement relating to Barden's

purposes as explained above. Next, Miss Roberts disputes that the statement was intended to be a

single one-time only comprehensive response quoted in full to Miss Roberts December 30th 2014

allegations that would give the media Miss Maxwell's response. First, Miss Roberts disputes this

statement relating to Barden's intent as explained above. Second, Miss Roberts disputes that anyone

intended the press release to be a one-time only comprehensive response. The record evidence,

as otherwise, Gals repeatedly issued this statement via email and over the phone for months on end.

Next, the defendant states the purpose of the preparatory statement was to inform the media

recipients of this intent. First, Miss Roberts disputes this and any statement relating to Barden's

purpose as explained above. Second, Miss Roberts disputes that the press release was to inform the

media of anything. Defendant issued a press release instructed them to publish it by telling them

it was quotable, see McCauley declaration at exhibit 48 and hired a press agent to feed it to the press.

Question, did Miss Maxwell retain the services of your firm? Answer, yes she did. Question,

is it your belief that the agreement was in effect on January 2nd, 2015? Answer, yes.

Question, do you recall the terms of that agreement? Answer, well, it was a reestablishment

of an existing agreement. So if we go back to the original agreement, it was to provide public

relation services to Miss Maxwell in the matter of Roberts and her activities.

See McCauley declaration at exhibit 6. The record evidence shows that defendant's intent

was for the press to publish her press release. Any other interpretation is not only contrary to

logic but unsupported by the record. The defendant's purported facts, 25. Miss Roberts'

activities to bring light to the rights of victims of sexual abuse. Miss Roberts has engaged in

numerous activities to bring attention to herself to the prosecution and punishment of wealthy

individuals such as Epstein and to her claimed interest of bringing light to the rights of victims

of sexual abuse. Miss Roberts' statement, contraverting defendant's facts. Agreed to the

portion of defendant's assertion and bold font, Miss Roberts has not engaged in activities

to bring attention to herself, rather she has taken action to aid in the prosecution of her

abusers and she seeks to bring light to the rights of victims of sexual abuse.

Miss Roberts' statement, contraverting defendant's facts. Miss Roberts created victims,

refuse silence incorporated in order to help other sexually trafficked victims find the resources

they need to recover in heel. Defendants purported facts, 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, Miss Roberts has dedicated

her professional life to helping victims of sex trafficking. Miss Roberts' statement,

contraverting defendant's facts. Agreed. Defendants purported facts, 28. Miss Roberts repeatedly

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

Miss Roberts' statement, contraverting defendant's facts, denied. Miss Roberts was approached by

numerous media outlets and refused to speak to most of them. Media organizations sought her out,

she did not seek them out, see McCauley Declaration at Exhibit 35, email from Sharon

Churcher seeking to interview Miss Roberts. Defendants purported facts, 29. On December 30, 2014,

Miss Roberts 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 around the world as a sex slave. Miss Roberts' statement, contraverting defendant's

facts. See Roberts' paragraph, seven, Supra, listing multiple reasons why details were in fact

necessary. Defendants purported facts, 30. Miss Roberts' alleged purpose in filing the

jointer motion was to vindicate her rights under the CVRA, exposed government secretly negotiated,

non-prosecution agreement with Epstein, shed tremendous public light on Epstein and other

powerful individuals that would undermine the agreement and support the CVRA, Miss Roberts

requests 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. Miss Roberts' statement, contraverting defendant's facts. See Miss Roberts'

paragraph, seven, Supra, listing multiple purposes of Miss Roberts' lawyer's filing of the

motion. Defendants purported facts. Miss Roberts is written, the manuscript of a book she has been

trying to publish detailing her alleged experience as a victim of sexual abuse and of sex trafficking

in Epstein's alleged sex scheme. Miss Roberts' statement, contraverting the defendant's facts.

See Miss Roberts' paragraph, 52, Infra, explaining that the context of this statement is misleading.

Defendants purported facts, 32. Republication alleged by Miss Roberts. Miss Roberts was required by

interrogatory number six to identify any false statements attributed to Miss Maxwell that were

published globally, including within the Southern District of New York. As Miss Roberts alleged

in paragraph nine of count one, uppercumplane. In response, Miss Roberts 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. Miss Roberts' statement, contraverting

defendant's facts. Miss Roberts' objects to this paragraph, in its entirety, starting with the

bolded heading, Republication alleged by Miss Roberts. There is no republication as a matter of law

in this case, as explained in Miss Roberts' memorandum of law. Accordingly, Miss Roberts is not

alleged republication. As noted in her objection that it is the defendant who possesses the knowledge

as to where the defamatory statements were published, unsurprisingly, defendant failed to comply

with Miss Roberts' discovery request on the same. Defendant already knows Miss Roberts provided

a sampling of defendants defamatory statements published by the news media as identification

of an exhaustive response of list would be unduly burdensome. This, of course, is because

defendant caused her statement to be published in an enormous number of media outlets.

Miss Roberts' full response to interrogatory number six is below. As the court can see,

these nine instances were a good faith effort to provide some samples as it would be virtually

impossible to provide all of them below. Miss Roberts has also put forth an exhaustive expert report

and expert testimony from Jim Janssen regarding the dissemination of defendants defamatory press release.

Miss Roberts objects because of the information. An interrogatory above is in the possession of

the defendant who was failed to comply with her production obligations in this matter,

and is failed to comply with her production obligations with this very subject matter.

See document requests number 17 from Miss Roberts' second request for a production of documents

to defendant Golan Maxwell. Maxwell has not produced all URL or internet addresses for any

internet version of such publication that she directed her agent Ross Gow to send.

Miss Roberts further objects because the information requested above is in the possession

of the defendant's agent who caused the false statements to be issued to various media outlets.

Miss Roberts has not had the opportunity to depose Maxwell's agent Ross Gow,

therefore this answer remains incomplete. Consequently, Miss Roberts reserves the right to modify

and or supplement her responses as information is largely in the possession of the defendant and her

agent. Miss Roberts objects to this interrogatory and that it violates Rule 33 as it subparts in

combination with other interrogatories exceed the allowable 25 interrogatories. Miss Roberts

objects to this request because it is in the public domain. Miss Roberts also objects in that it

seeks information protected by the attorney client work product privilege and any other

applicable privilege stated in the general objections. Notwithstanding such objections Miss Roberts

has already produced documents such responsive documents with the following list of publications.

While the identification of an exhaustive responsive list would be unduly burdensome

and an effort to make a good faith effort towards compliance Miss Roberts provides the following

examples which are incomplete based on the aforementioned reasons. Then she lists a whole there's

a whole bunch of articles listed here from different newspapers. Defendants reported facts 33.

In none of the nine instances was there any publication of the entire January 2015 statement.

Miss Roberts statement contributing the defendant's facts. While there may be certain publications

who did not print every word of defendant's lengthy press release most publications quoted the

most salient to the point parts of the defendant's statement that call Miss Roberts a liar.

In each of the nine articles listed above the defamatory statement as articulated by the complaint

and is identified by the court as actionable is published. See Roberts vs Maxwell 165f.supp.com

3d 147 152 sdny 2016 statements that Roberts claims against defendant are untrue have been

shown to be untrue and are obvious lies have a specific and readily understood factual meaning

that Roberts is not telling the truth about her history of sexual abuse and defendant's role

and that some verifiable investigation has occurred and come to a definitive conclusion

proving that fact. Second, these statements as they themselves allege are capable of being proven

true or false and therefore constitute actionable fact and not opinion. Miss Roberts also put forth

extensive evidence of the mass distribution of defendants defamatory statement to over 66

million viewers through her expert witness Jim Jansen see McCauley declaration at exhibit 24.

expert report of Jim Jansen all right folks we're going to wrap up this episode here and in

the next episode we're going to pick up where we left off all of the information that goes with

this episode can be found in the description box.