Mega Edition: Virginia Roberts Responds To Ghislaine Maxwell's Rule 56.1 Statement Of Facts (Part 7-9) (3/31/26)

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 a company

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 them.

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

contraverting 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,

Seymilcoly Declaration at Exhibit 5. Robert's deposition at 155 through 511.

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 prove 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. Seymilcoly 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. Seymilcoly 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.

Seymilcoly Declaration at Exhibit 15. Question, and do you know how Jeffrey Epstein,

Glan 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 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 a 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 TeB 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, Seymilcoly Declaration at Exhibit 15. On March 5, 2001,

Miss Roberts, Maxwell, Epstein, Emmy Taylor, traveled together internationally flight 1464,

leaving West Palm Beach to Stephenville, 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, Seymilcoly 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, Seymilcoly 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 Pinebluff, Arkansas.

But there is no record produced that explains how Miss Roberts arrived in Addison, Texas,

or how she returned to Palm Beach from Pinebluff, 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, Emmie Taylor,

and others, including one unidentified female from the US Virgin Islands to Tita Borough.

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. Seymilcoly 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 7 and May 14,

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 Borough on the 14th? Answer, I do not. On June 3, 2001, Miss Roberts travels from Palm Beach

to US Virgin Islands on Flight 1510 for three days, then on June 5, 2001, continues on Flight 1511

to Tita Borough. However, there is no record of Miss Roberts returning the Palm Beach,

see Roger's deposition, example 1. Then on July 4, 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 8, 2001,

Miss Roberts appears on Flight 1525 with Epstein and Maxwell, Emmy Taylor and others, including an

unidentified female departing Palm Beach to Tita Borough. Four days later, on July 11, 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 returned 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 Borough 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. On July 16, 2001, Miss Roberts appears on flight 1528

with Epstein Maxwell and Emmy Taylor from Santa Fe to Tita Borough. However, Miss Roberts flight

to Santa Fe is missing from the records. In addition, on July 28, 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 McCauley Declaration at Exhibit 15. On June 21, 2002, Miss Roberts appears on flight

1570 with Epstein Maxwell, Sarah Kellen, Cindy Lopez, and John Luke Brunel from Palm Beach

to Georgetown Bahamas. However, there is no record of Miss Roberts returning the Palm Beach,

see McCauley Declaration at Exhibit 15. See Roberts deposition, example 1.

Question, Virginia Roberts was taken to the Bahamas. Do you know where she went from there? Answer,

I do not. On August 17, 2002, Miss Roberts appears on flight 1589 with Epstein Maxwell,

Sarah Kellen, Cindy Lopez, and others from Santa Fe, New Mexico to Tita Borough.

Miss Roberts returns to Palm Beach, Florida on August 18, 2002 with Epstein and one unidentified

female. See McCauley Declaration at Exhibit 15. See Roger's deposition, example 1.

Question, do you know how Virginia Roberts got the Santa Fe? Answer, no. From September 29,

2002 through October 19, 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 McCauley

Declaration at Exhibit 43. All right folks, we're on a wrap up right here and in the next episode,

dealing with 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 going to pick up where we left off with the rule 56.1

SDNY 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 statement

contraverting the defendant's 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. Seamacoli Declaration at Exhibit 1. A Lese deposition

TR at 9 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. Seamacoli Declaration at Exhibit 5.

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.

Seamacoli 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. Seamacoli Declaration at Exhibit 27.

For example, in 2001, Miss Roberts earned $212 as a waitress, working briefly at Menino's Restaurant.

Seamacoli Declaration at Exhibit 5. In 2002, Miss Roberts earned $403.64 at CCI of Royal Palm Beach,

working there, TGI Fridays, for a short period of time. Seamacoli Declaration at Exhibit 5.

Then Miss Roberts worked at Roadhouse Grill until about March 2002, earning $1,247.90.

According to Dr. Pinkwaster's records, Miss Roberts also received payroll checks for weeks ending

422.02.064.02, 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.

Seamacoli 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, contraverting 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. Seamacoli Declaration at Exhibit 43.

The document Miss Roberts was given, directs her to call Miss Maxwell, Seamacoli 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 failed 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 officers' reports

in 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

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 went asked to describe everything that you believe you know

about the Lane Maxwell 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 Roberts' conduct that is subject to this lawsuit. Miss Roberts

statement contributing defendant's 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. Seema Colley Declaration at Exhibit 13.

Detective Rikari concluded that defendant's role was to procure girls for Epstein. Seema Colley

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. Seema Colley 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. Seema Colley 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 a list of the local girls who were giving

massages at her desk and that Maxwell kept nude photos of the girls on her computer.

Seema Colley 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. Seema Colley Declaration

at Exhibit 13. Recari deposition at 72.25 through 73.15. Benazziac testified that the computers

were removed by Adriana Ross, another employee, who entered the Maxwell. Seema Colley 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. Seema Colley Declaration at 1.

The co-conspirator who maintained direct contact with many underage victims with Sarah

who's sole responsibility was to schedule underage girls to visit Epstein for sex. Sarah reported

directly to Maxwell, Seema Colley 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. Seema Colley Declaration at Exhibit 20.

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, Ms.

Roberts' ex-boyfriend did testify that Maxwell personally requested that he find and bring

girls to Epstein for sex once Ms. Roberts had escaped and that when he brought the girls,

Maxwell interacted with them. Seema Colley Declaration at Exhibit 4, Figueroa deposition

at 200 and 228, 23. Rodriguez testified unequivocally that Maxwell was the boss and that she knew

everything that was going on. Seema Colley 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 going to pick up where we left off.

The defendant's purported facts 49. No nude photograph of Ms. Roberts was displayed in Epstein's

home. Epstein Housekeeper, Juan Alessi, never saw any photographs of Virginia Roberts in Mr.

Epstein's house, Detective Ricari, and her 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. Ms. Roberts statement, contributing the defendant's facts. This is false.

Nude photographs were displayed throughout Epstein's home. Further more 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 Ricari who testified to the fact in his deposition,

C. McCauley Declaration at Exhibit 13. And those photos are still in the possession of the FBI

or the U.S. Attorney's Office. C. McCauley 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. C. McCauley 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. C. McCauley Declaration at Exhibit

44. Search warrant video attached to the deposition of Ricari. Johanna Schoberg testified that the

defendant bought her a camera for the specific purpose of her taking nude photos of herself.

C. McCauley Declaration at Exhibit 16. Finally, Virginia Roberts testified that there was a nude

photograph of her at the house. C. McCauley 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 contributing 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 a carthetic 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 5

Defendants purported facts. 51. Miss Roberts publicly peddled her story beginning in 2011.

Miss Roberts granted journalist Sharon Churcher extensive interviews that resulted in seven

widely distributed articles from March 2011 through January 2015. Churcher 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 defendant's facts.

Defendant 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 Churcher 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, Churcher 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 Churcher 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 Churcher 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, Seema College 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's 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, Seema College Declaration at 31. She was also getting psychological help, Seema College

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 active 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,

parole, 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, performativity 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, seem a colleague declaration

at Exhibit 5. Defendants purported facts, 53. Ms. Roberts publicly filed lured CVRA pleadings

initiated a media frenzy and generated highly publicized litigation between her lawyers and

Alan Dershowitz. On December 30, 2014, Ms. Roberts threw counsel publicly filed a jointer motion

that contained her lured allegations about Ms. Maxwell and many others including Alan Dershowitz,

Prince Andrew, and Jean-Luc Brunel. The jointer motion was followed by a corrected motion and

two further declarations in January and February 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 attorneys

Edwards and Cassel sued Dershowitz who counterclaimed. This litigation in turn caused additional

media attention by national and international media organizations. Ms. Roberts statement

Controverting the defendant's facts. See Ms. Roberts paragraph seven,

Supra, explaining why the allegations were necessary and appropriate for multiple reasons.

Ms. Roberts disputes defendants, 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 council 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' refuse 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,

Controverting 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-profit's mission when she had the opportunity to do so.

Ms. Roberts 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 1, 5, 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 5.

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 Kellan 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 31, 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.