Mega Edition: Virginia Roberts Responds To Ghislaine Maxwell's Rule 56.1 Statement Of Facts (Part 3-4) (3/28/26)

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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 Somerland of the Mirror, David Brown

of the Times, and Nick always in Joanne Pew of the BBC, and David Mercer of the Press Association.

These representatives were selected based on their request after the jointer motion was

filed for a response from Miss Maxwell to Miss Robert's allegations in the motion.

Miss Robert's statement, Controverting Defendants Facts.

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

Interestingly 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.

After I really can't remember but certainly more than six and probably less than 30 some

were in between.

Any time 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

the McCauley Declaration at exhibit six.

Defendants purported facts 20.

The email to the media member said to whom it may concern please find attached the quoteable

statement on behalf of Miss Maxwell.

No further communication will be provided by or on this matter.

Thanks for your understanding best Ross.

Jane though three is Virginia Roberts so not a new individual.

The allegations made by Victoria Roberts against GAL and 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.

Find 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 contributing 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. GAL's firm acuity reputation.

Miss Roberts statement contributing the defendants facts.

Defendants states 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 and Miss Roberts opposition defendants motion for 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. GAL'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 GAL with

instructions to publish it see McCauley declaration at exhibit 48.

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

relations firm such as Mr. GAL's firm acuity reputation Miss Roberts disputes that statement.

Record documentary evidence and testimony establish that this statement was disseminated

through a public relations firm namely Ross GAL'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 contraverting 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 rejudgment as the press did

not republish the press statement under New York law.

Third Miss Roberts disputes that are allegations are false and sites to the following non-exhaust

of sampling of evidence to corroborate our allegations against the defendant.

See McCauley declaration exhibit 16 McCauley declaration exhibit four.

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 arson

cova see McCauley declaration at eight for Kellen see McCauley declaration exhibit one for

a lessy 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 30 at 28 for message pads McCauley at 29 for

the black book McCauley at 40 for sex slave books McCauley at 32 for the folder defendant

sent to Thailand McCauley at 39 for the Palm Beach police report McCauley at 41 for

Epstein's flight logs next defendant 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 the 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 defendants work for

but the closest evidence defendant has for such a statement is testimony from the Gau

deposition wherein Gau speculates that Barton had a hand in drafting the press statement an opinion

which may or may not be based on firsthand knowledge see McCauley declaration at six Gau

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 are allegations are obvious lies because defendants press release affirmatively

unambiguously stated that her allegations are obvious lies there's no subtleties suggestion

or a statement of opinion here see Roberts verse Maxwell 165 f 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 it is Ryan C crest here there

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chumbacacino.com sponsored by chumbacacino they keep telling you that the Jeffrey Epstein story is

finished that it was investigated that it was handled but here's the part that they never explain

why the charges were so narrow when the conduct was so broad how does a man with multiple

properties private aircraft international travel and a documented pipeline of victims get treated

like a lone offender why were logistics treated as background noise instead of evidence why

were facilitators reduced the footnotes instead of defendants well that's where we come in

the Epstein chronicles exist because those questions were never answered this podcast breaks down

what the public record actually shows the deals that kept exposure the decisions that limited scope

and the moments where prosecutors chose restraint overreach if you ever wondered why this case

feels unfinished why accountability stopped at the perimeter or why so many names remain officially

invisible you've come to the right place welcome to the Epstein chronicles 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 Robert's allegations without conducting an

inquiry of their own accordingly in the statement he repeatedly noted that Miss Robert's 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 consider the

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

own conduct Miss Robert's statement contributing the defendant's facts this paragraph is another

reported 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 Robert's 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 00068

next Miss Robert's disputes the sentences accordingly in the statement he repeatedly noted that

Miss Robert's allegations were defamatory Barton did not note anything in the statement

nor does defendant cite to any record evidence that he does furthermore Miss Robert's denies

that any of her allegations are defamatory in the slightest as they are all true and substantiated

by record evidence Miss Robert's also disputes the sentence in this sense the statement was intended

as the cease and desist letter to the media recipients letting the media recipients understand

the seriousness with which Miss Maxwell consider the publication of Miss Robert's obviously false

allegations and the legal indefensibility of their own conduct first Miss Robert's

objection 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 Robert's disputes that any

media recipients would be given to understand the seriousness with which Miss Maxwell considered

the publication of Miss Robert's obviously false allegations and the legal indefensibility

of their own conduct by defendant self-serving press release as that is unsupported by the record

finally Miss Robert's 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 a 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

Robert's 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

statement contraverting the defendant's facts Miss Robert's disputes that any part of the

defendant's press release is consistent with those two of Barton's purposes indeed Miss Robert's

disputes this and any statement relating to Barton's purposes as explained above next Miss Robert's

disputes that the statement was intended to be a single one-time only comprehensive response

quoted in full to Miss Robert's December 30th 2014 allegations that would give the media

Miss Maxwell's response first Miss Robert's disputes this and any statement relating to Barton's

intent as explained above second Miss Robert's 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

Robert's disputes this and any statement relating to Barton's purpose as explained above second Miss

Robert's 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 Robert's

ender activities see McCauley declaration at exhibit six the record evidence shows that defendants

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 defendants purported facts 25

Miss Robert's activities to bring light to the rights of victims of sexual abuse

Miss Robert's 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 Robert's statement contributing defendants facts

agreed to the portion of defendant's assertion and bold fonts Miss Robert's 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 Robert's statement contributing defendants facts

Miss Robert's created victims refuse silence incorporated in order to help other sexually

trafficked victims find the resources they need to recover in heal 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 Robert's has dedicated her professional life to helping victims of sex

trafficking Miss Robert's statement contributing defendants facts agreed defendants purported facts

28 Miss Robert's repeatedly has sought out media organizations to discuss her alleged experience

as a victim of sexual abuse Miss Robert's statement contributing defendants facts

denied Miss Robert's 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 Robert's defendants purported facts

29 on December 30 2014 Miss Robert's publicly filed an entirely unnecessary

joineder 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 Robert's

statement contributing defendants facts see Robert's paragraph seven Supra listing multiple

reasons why details were in fact necessary defendants purported facts 30 the Miss Robert's alleged

purpose and filing the joineder 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 Robert'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 Miss Robert's statement contributing defendants facts see Miss Robert's

paragraph seven Supra listing multiple purposes of Miss Robert's lawyer's filing of the motion

defendants purported facts Miss Robert's 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

and Epstein's alleged sex scheme Miss Robert's statement contributing the defendants facts see

Miss Robert's paragraph 52 Infra explaining that the context of this statement is misleading

defendants purported facts 32 republication alleged by Miss Robert's Miss Robert's 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 Robert's alleged

and paragraph nine of count one of her complaint in response Miss Robert's 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 tell a reddick here from 2311 racing

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Miss Robert's statement contributing defendants facts Miss Robert's objects to this paragraph

in its entirety starting with the bolded heading republication alleged by Miss Robert's

there is no republication as a matter of law in this case as explained in Miss Robert's memorandum

of law accordingly Miss Robert's is not and has not alleged republication as noted inner 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 Robert's discovery request on the same

defendant already knows Miss Robert's provided a sampling of defendants defamatory statements

published by the news media as identification of an exhaustive responsive 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 Robert's 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 Robert's has also put forth an exhaustive

expert report and expert testimony from Jim Janssen regarding the dissemination of defendants defamatory

press release Miss Robert's objects because the information in 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

request number 17 from Miss Robert's 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 Gouda Sen Miss Robert's 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 Robert's has not had the opportunity

to depose Maxwell's agent Ross Gouda therefore this answer remains incomplete consequently Miss Robert's

reserves the right to modify and or supplement her responses as information is largely in the

possession of the defendant and her agent Miss Robert's objects to this interrogatory and that

it violates rule 33 as it subparts in combination with other interrogatories exceed the allowable

25 interrogatories Miss Robert's objects to this request because it is in the public domain

Miss Robert's 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 Robert's 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 Robert's 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 Robert's statement contraverting 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

that call Miss Robert's 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 verse Maxwell 165f.supp.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 defendants role and that some verifiable investigation has occurred and come to a definitive

conclusion proving that fact second the statements as they themselves allege are capable of being

proven true or false and therefore constitute actionable fact and not opinion Miss Robert's

also put forth extensive evidence of the mass distribution of defendants defamatory statement

to over 66 million viewers through her expert witness Jim Janssen see McCauley declaration at

exhibit 24 expert report of Jim Janssen 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

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