Mega Edition: Virginia Roberts Responds To Ghislaine Maxwell's Rule 56.1 Statement Of Facts (Part 5-6) (3/28/26)

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What's up, everyone?

And welcome back to the Epstein Chronicles.

In this episode, we're picking right back up,

where we left off with the SDNY rule 56.1 core document.

The defendants purported facts, 34.

Miss Maxwell, under agents, exercised no control or authority

over any media organization, including the media identified,

in Miss Roberts' response to interrogatory number six,

in connection with the media's publication

of portions of the January 2015 statement.

Miss Roberts' statement, contraverting the defendant's facts,

Miss Roberts disputes this statement in its entirety

as it's completely devoid of record evidence.

In fact, the record establishes the contrary.

First, defendant hired Gao, because his position

allowed him to influence the press

to publish her defamatory statement.

A sampling of Gao's testimony establishes just that.

Question, did Miss Maxwell retain the services of you

or 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' under activities.

Question, you can answer to the extent

that anything you testify is not protected by privilege.

Answer, Miss Roberts first came to my attention

on around March 2011, when I was called into a meeting

with Philip Barton and Miss Maxwell

at Devonshire's Law Office that she had made, Miss Roberts,

had made extremely unpleasant allegations

about Miss Maxwell's private life.

We were, acuity reputation, my firm,

was called in to protect Miss Maxwell's reputation

and to set the record straight.

That was, and that work, commenced on or around

the March of 2011.

Question, does this document fairly depict pages

from your, from Acuity Reputations website?

Answer, yes it does.

Question, do you see where it says we manage reputation

and forge opinion through public relations,

strategic communications, and high level networking?

Answer, I do.

Question, is that a truth statement?

Answer, say it again, sorry.

Question, is that a truth statement?

Answer, it is, yes, I wrote that statement.

Question, okay, do you see where your website claims

that your company has excellent relationships

with the media?

Answer, I do.

Question, is that a truth statement?

Answer, yeah, that's a truth statement, yeah.

Question, is it correct that you're advertised

your excellence relationship with the media

because your services often include giving communications

to the media, on behalf of your clients?

Answer, yes.

See McCauley Declaration, exhibit six, gal.

In addition to testimonial evidence, the proof,

is also in the result.

By using gal to issue her press release, defendant,

caused her statement to be published

by numerous major news organizations

with wide readership all over the globe.

Accordingly, the record evidence shows

that Ms. Maxwell, through her agent,

had immense control and authority over the media,

convincing major news outlets to publish her words

based on nothing more than a single email from gal.

The defendants reported facts.

Ms. Roberts' defamation, action against Ms. Maxwell.

Eight years after Epstein's guilty plea, Ms. Roberts

brought this action, repeating many of the allegations

she made in her CVRA joined her motion.

Ms. Roberts' statement, contraverting defendants facts,

agreed, but noting that the defamation

caused of action against defendant

did not accrue until defendant, defender,

in January of 2015.

The same year, Ms. Roberts filed suit

against defendant for defamation.

The defendants reported facts.

The complaint alleges that the January 2015 statement

contained the following deliberate falsehoods.

A, that Roberts sworn allegations against

Golan Maxwell are untrue.

B, that the allegations have been shown to be untrue.

C, that Roberts' claims are obvious lies.

Ms. Roberts' statement, contraverting,

the defendant's facts, agreed.

However, in discovery, defendant was finally forced

to produce the complete press release she issued,

C. McCauley Declaration at Exhibit 26.

The defendants reported facts.

Ms. Maxwell lived independently from her parents,

with her fiance, long before meeting Epstein,

or Ms. Maxwell.

After leaving the growing together drug rehabilitation facility

in 1999, Ms. Roberts moved in with the family

of a fellow patient.

There she met and became engaged to her friend's brother,

James Michael Lostrich.

She and Lostrich thereafter rented an apartment

in Fort Lauderdale with another friend

and both worked at various jobs in that area.

Later, they stayed briefly with Ms. Roberts' parents

in the Palm Beach, Laxahatchee, Florida area,

before Ostrich rented an apartment for the couple

on Pento Drive and Royal Palm Beach.

Although Ms. Roberts agreed to marry Ostrich,

she never had any intention of doing so.

Ms. Roberts' statement, contraverting the defendant's facts.

Ms. Roberts did not voluntarily live independently

from her parents, with her fiance.

Rather, Ms. Roberts was a troubled minor child

who was not truly engaged prior to meeting the defendant

and Epstein, where Ms. Roberts lived

and who she lived with are not relevant to the issues

being decided in this action.

Again, this is merely a transparent distraction

from the case that is actually at issue

and is being used for the sole purpose

of inserting conjecture in an effort to distract the court

and ultimately the jury.

Although Ostrich testified that he proposed

Ms. Roberts on Valentine's Day, see Ostrich at page 19,

Ms. Roberts was a troubled teen

who could not realistically be considered a fiance

in the true sense of the word, nor was she of legal age to marry.

In fact, as accurately described by the defendant,

Ms. Roberts never had any intention of marrying Ostrich.

Roberts' deposition at 127, 22, 128, 21,

given that Ms. Roberts was a child

with limited legal capacity at this point

and that she did not have any intention of marrying Ostrich,

a reasonable person, could not assert

that Ms. Roberts was engaged.

Defendants purported facts.

38. Ms. Roberts re-enrolled in high school

from June 21st, 2000 until March 7th, 2002.

After finishing the ninth grade school year

at Forest Hills High School on June 9th, 1999,

Ms. Roberts re-enrolled at Wellington Adult School

on June 21st, 2000, again on August 16th, 2000

and on August 14th, 2001.

On September 20th, 2001, Ms. Roberts 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.

Ms. Roberts remained enrolled at Survivor's Charter School

until March 7th, 2002.

She was present 56 days and absent 13 days

during her time there.

Ms. Roberts never received her high school diploma

or her GED.

Ms. Roberts and Figueroa went back to school together

at Survivor's Charter School.

The school day there lasted from morning until afternoon.

Ms. Roberts' statement,

contributing the defendant's facts.

Ms. Roberts denies this statement.

Either defendant is blatantly misleading this court

or a defendant simply does not understand

how to interpret Ms. Roberts' school records.

The record produced by defendant

is specifically titled A-07 Assignment History,

which reflects semester's start and end dates

per each 180-day school year.

Not dates that Ms. Roberts physically enrolled

or withdrew from school.

See McCauley Declaration at Exhibit 27.

While grade 30 indicates adult education,

Ms. Roberts' attendance records indicate

that she was not present at school between 621 of 2009-20 of 2001.

See with Drull Code's W32 and W47.

With Drull Code's adult students, W26,

any student who withdraws from school

to enter the adult education program

prior to completion of graduation requirements, W32.

Any adult student who left the class program

to enter another training program, W47.

Any adult student who is procedurally withdrawn

at the end of the term or school year

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

More importantly, Ms. Roberts' school transcript

clearly indicate no course is taken

for the 1999-2000 and 2000-2001 school years.

See McCauley Declaration at Exhibit 27.

Ms. Roberts' attempt to work and resume school

at survivor's charter school as a 10th grader

in the 2001-2002 school year

was limited to a portion of the school year

and further substantiates Ms. Roberts' testimony

that she attempted to get away from Epstein's abuse

along with the following testimony by Figueroa.

Question.

Was there a period of time between 2001

and when she left in 2002,

where she was not working for Jeffrey, answer, yes, question?

What period of time was that?

Answer, it was pretty much like

when she was actually working as a server,

like basically because we were trying

to not have her go back there,

like she did not want to go back there.

And we were trying to just work without needing his money,

you know?

See McCauley Declaration exhibit four.

Question.

So the thing that Virginia was tired of,

what was it that Virginia was trying to get away from

and stop with respect to working at Jeffrey Epstein's house?

Answer to stop being used and abused.

See McCauley Declaration at exhibit four.

Even still, if the records are correct,

which Ms. Roberts does not concede,

the records indicate that Ms. Roberts' attendance was poor

with 69 days present and 32 days absent

out of a required 180 day school year

that she was not enrolled at the end of the school year.

Emphasis added.

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See McCauley Declaration, exhibit 27.

Miss Roberts, obvious Gapner School attendance,

per president's verified by Epstein's pilot on flight

logs, and an abundance of witness testimony,

all corroborate her story that she.

Miss Roberts was flying domestic and internationally

with Epstein at least 32 times between 1211 of 2000

and 728-01 and 621-02 and 821-02,

defendant traveling with Miss Roberts on 23 of the flights.

See McCauley Declaration, at exhibits 15 and 41.

And that points us to the deposition of David Rogers,

who is the pilot of Jeffrey Epstein.

Question, do you know how long Virginia had been coming over

to the house before she started traveling on an airplane

with Galein and Jeffrey, the witness not too long?

I don't think it was long after that.

See McCauley Declaration, at exhibit 37.

All right, folks, we're going to wrap up

this episode right here, and in the next episode,

talking about the topic, 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.

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 the SDNY rule 56.1 document.

The defendants purported facts 39.

During the year 2000, Miss Roberts worked at numerous jobs

in 2000 while living with her fiance, Miss Roberts,

held five different jobs at Avoculture Breeding

and Research Center, Southeast Employee Management Company,

the club at Mar-a-Lago, Oasis outsourcing, and Neiman Marcus.

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

Miss Roberts cannot now recall either

of the Southeast Employee Management Company

or the Oasis outsourcing job.

Miss Roberts statement, Controverting Defendants Facts.

Miss Roberts disputes this statement.

During 2000, Miss Roberts shared an apartment

with her then boyfriend, James Michael Ostrich,

and his friend, Mario.

See McCauley Declaration, exhibit two.

Although Ostrich testified that he proposed

to Miss Roberts on Valentine's Day,

see Ostrich at page 19.

Miss Roberts was a troubled teen

who could not realistically be considered

a fiance in the true sense of the word

nor was she legal age to marry.

While Miss Roberts held various jobs

in 2000, SSA records do not show the exact date

of employment month and day

because they do not need this information

to figure social security benefits.

See McCauley Declaration at exhibit 46.

The reason that Miss Roberts cannot recall

two companies listed on her SSA records,

Southeast Employee Management Company,

or Oasis outsourcing is simply because

they were not her employers.

See McCauley Declaration at exhibit five.

Had defendant bothered to run a simple Google search,

she would have ruled them out

as being payroll and benefit administration companies.

Miss Roberts is testified that she believes

she worked at Taco Bell at an aviary

then Mar-a-Lago, see McCauley Declaration at exhibit five.

Ostrich also testified that Miss Roberts

worked with them at Taco Bell

as well as a pet store for over a month

before working at Mar-a-Lago,

see McCauley Declaration at exhibit five.

Neither Taco Bell nor the pet store

are listed on Miss Roberts' SSA records

because they were most likely paid

through payroll companies.

See McCauley Declaration at exhibit 46.

Miss Roberts also testified that she had volunteered

at an aviary where they eventually put her on the payroll,

but paid her very little.

Roberts' deposition at 52.

Avoculture Breeding and Research Center taxable earnings

for $2,000 is $99.48.

See McCauley Declaration at exhibit 46.

The defendants purported facts.

Miss Roberts' employment at the Mar-a-Lago spa

began in the fall of 2000.

Miss Roberts' father, Sky Roberts,

was hired as a maintenance worker

at the Mar-a-Lago Club in Palm Beach, Florida,

beginning on April 11, 2000.

Mr. Roberts worked there year-round

for approximately three years.

After working there for a period of time,

Mr. Roberts became acquainted with the head of the spa

and recommended Miss Roberts for a job there.

Mar-a-Lago closes every mother's day

and reopens on November 1st.

Most of the employees at Mar-a-Lago,

including all employees of the spa area,

such as spa attendants are seasonal,

and work only when the club is open,

i.e. between November 1st and Mother's Day.

Miss Roberts 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.

Miss Roberts' statement,

contributing, defendants' facts.

Miss Roberts disputes this statement.

Defendant cannot simply infer Miss Roberts' employment history

and claim it to be undisputed,

the Mar-a-Lago Club produced 177 pages of records

in response to defendant's subpoena.

However, not one page indicated,

Miss Roberts' actual dates of employment,

nor whether she was a full-time or seasonal employee.

In fact, the only significant record produced

was a single vague chart,

entry indicating that Miss Roberts was terminated in 2000.

Job postings and job descriptions

produced by Mar-a-Lago from 2002 and later

are irrelevant to Miss Roberts' employment

because they are from after she worked there.

Miss Roberts testified that Mar-a-Lago

was a summer job,

see McCauley Declaration at exhibit five.

In fact, her father Sky Roberts testified

that he referred his daughter for employment

and she did not get the job through a posting.

He drove his daughter to and from work consistent

with his full-time schedule,

see McCauley Declaration at exhibit 17.

He believes the spa, like the kitchen, dining room,

was open to local guests in the summer,

see McCauley Declaration at exhibit 17.

And that his daughter was not attending school

when she worked at Mar-a-Lago.

See McCauley Declaration at exhibit 17.

In addition, Juan Alessi testified that it was summer

when defendant approached Miss Roberts at Mar-a-Lago

because he specifically remembered that day

I was sweating like hell in in the car waiting

for Miss Maxwell to come out of the massage,

see McCauley Declaration at exhibit one, Alessi Deposition.

Defendants purported facts, 41.

Miss Roberts represented herself as a masseuse

for Jeffrey Epstein while working at the Mar-a-Lago spa

and reading a library book about massage,

Miss Roberts met Miss Maxwell.

Miss Roberts thereafter told her father

that she got a job working for Jeffrey Epstein as a masseuse.

Miss Roberts' father took her to Epstein's house

on one occasion around that time

and Epstein came outside

and introduced himself to Mr. Roberts.

Miss Roberts commenced employment

as a traveling masseuse for Mr. Epstein.

Miss Roberts was excited about her job as a masseuse

about traveling with him and about meeting famous people.

Miss Roberts represented that she was employed

as a masseuse beginning in January 2001.

Miss Roberts never mentioned Miss Maxwell

to her then fiancee ostrich.

Miss Roberts' father never met Miss Maxwell.

Miss Roberts' statement,

contributing defendant's facts.

Miss Roberts denies defendant's falls

and factually unsupported narrative

in Florida, a person cannot work as a masseuse

unless she is at least 18 years of age

or has received a high school diploma

or high school equivalency diploma.

Florida statute, section 480-041.

Miss Roberts was a minor child under the age of 18

when she was working at Mar-a-Lago as a spa attendant.

Roberts' deposition at 61 and 61-24.

She was approached by defendant who told her

she could make money as a masseuse,

a profession in which Miss Roberts had no experience.

See McCauley Declaration at Exhibit Five.

Sky Roberts, Virginia Roberts' father verified

Miss Roberts' account that defendant recruited his daughter

to learn massage therapy.

See McCauley Declaration at Exhibit 17.

Miss Roberts' father,

Drover, two Jeffrey Epstein's house,

the address of which was given to her by the defendant.

See McCauley Declaration at Exhibit Five.

Miss Roberts was led into the house

and was instructed by defendant on how to give a massage

during which Epstein and defendant

turn the massage into a sexual encounter

and offered Miss Roberts' money

and a better life to be compliant

in the sexual demands of defendant and Epstein.

See McCauley Declaration at Exhibit Five.

The minor Miss Roberts then began traveling

with defendant and Epstein on private planes

and servicing people sexually for money,

working not as a legitimate masseuse,

but in a position of sexual servitude.

See McCauley Declaration at Exhibit One and Five.

Epstein's house manager, Juan Alessi,

described defendant's methodical routine

of how she prepared a list of places ahead of time

that entroved each place for the purpose

of recruiting girls to massage Epstein.

See McCauley Declaration at Exhibit 18.

Alessi also stated that on multiple occasions

he drove defendant to pre-plan places

while she recruited girls for a massage.

He further testified that he witnessed Miss Roberts

at Epstein's house on the very same day

that he witnessed defendant recruit Miss Roberts

from Mar-a-Lago.

See McCauley Declaration at Exhibit 18.

Johanna Schoberg, through her sworn testimony,

demonstrated that defendant recruited her

in a similar fashion by driving to the college campus

where she attended school and approached

her to work at Epstein's home answering phones.

See McCauley Declaration at Exhibit 16.

Schoberg testified that she answered phones for one day

before defendant propositioned her to rub feet

for a hundred bucks an hour.

See McCauley Declaration at Exhibit 16.

The following day, Schoberg was paired

with defendant's assistant, Emmy Taylor,

who provided her with massage training on Epstein.

Schoberg at 13 and 15.

Miss Roberts, then boyfriend, Austrich,

testified that he could not recall the name of the person

who recruited Miss Roberts.

However, he did say she was recruited by someone

to work for Epstein as a massage therapist,

but that Miss Roberts did not have any experience.

See McCauley Declaration at Exhibit 2.

Neither Miss Roberts nor Miss Schoberg

were licensed or trained in massage,

but were invited soon after being recruited

to travel with Epstein on his private plane to massage him.

See McCauley Declaration at Exhibit 16.

The defendants purported facts, 42.

Miss Roberts resumed a relationship

with convicted felon, Anthony Figueroa.

In spring, 2001, while living with Austrich,

Miss Roberts lied to and cheated on him

with her high school boyfriend, Anthony Figueroa.

Miss Roberts and Austrich thereafter broke up

and Figueroa moved into the bento compartment

with Miss Roberts.

When Austrich returned to the bento compartment

to check on his pets and retrieve his belongings,

Figueroa, Miss Roberts presents,

punched Austrich in the face.

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Figueroa and Miss Roberts fled the scene before police arrived.

Figueroa was then convicted, felon,

and drug abuser on probation for possession

of a controlled substance.

Miss Roberts statement,

contributing defendants facts.

This entire statement is wholly relevant

to the case being tried and is improperly being inserted

to tarnish the record.

Miss Roberts dating history as a young teen

bears no relation to the allegations made

within Miss Roberts complaint against the defendant.

As previously stated,

defendant is attempting to muddy the record

with nonsensical teen drama in an effort to detract

from her salacious sexual abuse of a minor child.

Such statements bear no relation to the issues presented

through a motion for summary judgment

and should be given way reflecting the same.

A specifically set fourth in Miss Roberts objections

to designated testimony,

the alleged information would be excluded

by multiple rules of evidence

and contested by Miss Roberts.

See McCauley declaration at exhibit five.

Moreover, it was the defendant who solicited

Anthony Figueroa to recruit high school-aged girls

for Epstein.

See McCauley declaration at exhibit four.

Defendants purported facts.

Miss Roberts freely and voluntarily contacted the police

to come to her aid in 2001 and 2002,

but never reported to them that she was Epstein's ex-slave.

In August 2001 at age 17,

while living in the same apartment,

Miss Roberts and Figueroa hosted a party

with a number of guests.

During the party,

according to Miss Roberts,

someone entered Miss Roberts' room

and stole $500 from her shirt pocket.

Miss Roberts 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,

Miss Roberts contacted the police

to report that her former landlord

had left her belongings by the roadside

and had lit her mattress on fire.

Again, Miss Roberts met and spoke with the law enforcement

officers, but did not complain that she was the victim

of any sexual trafficking or abuse

or that she was then being held as a sex slave.

Miss Roberts' statement,

contraverting the defendant's facts.

This statement is misleading in several respects

and irrelevant.

The fact that Miss Roberts did not contact police

on two occasions for two specific purposes

and did not take that opportunity

to also inform the police of everything else

that was going on in her life

at the time is immaterial.

Defended implies that anytime someone calls the police

for one thing,

they should tell the police about every other crime

regardless of the relevance to the crime

for which the police responded

and regardless to the threat to herself

should she report on these powerful people.

Moreover, as Professor Coonan explained,

popular understanding of the term sex slave

might still canot images of violent pimps, white slavery,

or a victim's chain to a bed and a brothel

in the minds of some people to call Miss Roberts

a victim of sex trafficking,

would however very accurately convey the reality

that she, along with a great many other victims

of contemporary forms of slavery,

are often exploited by the invisible chains of fraud

and psychological coercion.

See McCauley Declaration at Exhibit 23,

Coonan expert report at 20.

Miss Roberts specifically testified

that she was fearful of the defendant and Epstein

and accordingly she would not have reported her abusers.

She also knew that Epstein had control over the Palm Beach police.

See McCauley's Declaration at Exhibit five.

All right folks, we're gonna wrap up this episode here

and in the next episode, dealing with the topic,

we're gonna pick up where we left off.

All of the information that goes with this episode

can be found in the description box.

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