Mega Edition: Virginia Roberts Responds To Ghislaine Maxwell's Rule 56.1 Statement Of Facts (Part 1-2) (3/30/26)

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

In this episode, we're going to dive right back into those core documents

and we're going to take a look at the Southern District of New York,

local rule 56.1, plaintiff statement of contested facts

and plaintiffs undisputed facts.

Case number 15, dash CV, dash 07433-RWS.

Virginia Roberts, plaintiff, briskland Maxwell, the defendant.

Southern District of New York's local rule 56.1,

plaintiff statement of contested facts and plaintiffs undisputed facts.

Defendants purported facts.

One, Miss Maxwell's response to publication

of Miss Roberts' false allegations, the March 2011 statement.

In early 2011, Miss Roberts and two British tabloid interviews

made numerous false and defamatory allegations against Miss Maxwell.

In the articles, Miss Roberts made no direct allegations

that Miss Maxwell was involved in any improper conduct with Jeffrey Epstein,

who pleaded guilty in 2007 to brocuring a minor for prostitution.

Nonetheless, Miss Roberts suggested that Miss Maxwell worked with Epstein

and may have known about the crimes for which he was convicted.

Miss Roberts' statement, contraverting defendants' facts.

Miss Roberts denies that the allegations she made against Miss Maxwell are false.

Furthermore, Miss Roberts did give an interview to journalist Sharon Churcher

in which Miss Roberts accurately and truthfully

described defendant Maxwell's role as someone who recruited or facilitated the recruitment

of young females for Jeffrey Epstein.

See McCauley Declaration at Exhibit 34

Miss Roberts was also interviewed by the FBI in 2011,

and she discussed defendants' involvement in the sexual abuse.

See McCauley Declaration at Exhibit 31, FBI redacted 302.

Those statements were not false and defamatory, but instead truthful

and accurate. Defendants purported facts, too. In the articles,

Miss Roberts alleged she had sex with Prince Andrew, a well-known businessman,

a world-renowned scientist, a respected liberal politician, and a foreign head of state.

Miss Roberts' statement, contraverting defendants' facts.

Miss Roberts does not contest this fact, but believes that it's irrelevant.

Defendants purported facts, three. In response to the allegations,

Miss Maxwell's British Attorney, working with Mr. Gow issued a statement on March 9, 2011,

denying the various allegations about Miss Maxwell

that have appeared recently in the media. These allegations are all entirely false.

Miss Roberts' statement, contraverting defendants' facts.

Miss Roberts denies that Mr. Barton issued a statement, instead it appears to have the contact

as Ross Gow and a reference to Devonshire solicitors. Defendants purported facts.

For the statement, red and full, statement on behalf of Glan Maxwell by Devonshire solicitors,

PR any Wednesday, March 9, 2011. Glan Maxwell denies the various allegations about her that

have appeared recently in the media. These allegations are entirely false. It is unacceptable that

letters sent by Miss Maxwell's legal representatives to certain newspapers pointing out the truth

and asking for the allegations to be withdrawn have simply been ignored.

In the circumstances, Miss Maxwell is now proceeding to take legal action against those newspapers.

I understand newspapers need stories to sell copies. It is well known that certain newspapers

live by the adage while at the truth get in the way of a good story. However, the allegations made

against me are abhorrent and entirely untrue and I ask that they stop, said Glan Maxwell.

A number of newspapers have shown a complete lack of accuracy in their reporting of this story

and a failure to carry out the most elementary investigation or any real due diligence.

I am now taking action to clear my name.

Miss Robert's statement, Controverting Defendants Facts, the document speaks for itself,

although it is unclear if the original included the italics that are inserted by the defendant above.

Defendants purported facts. 5. Miss Robert's gratuitous and lurid accusations

in an unrelated action. In 2008, two alleged victims of Epstein brought an action under the

Crime Victim Rights Act against the United States government, purporting the challenge Epstein's

plea agreement. They allege the government violated their CVRA rights by entering into the agreement.

Miss Robert's statement, Controverting Defendants Facts, while we would stipulate to the statement

in this paragraph, starting with the words in 2008, we do not stipulate to the opening sentence

fragment Maxwell places in bold. Defendants purported facts. 6. Seven years later,

on December 30, 2014, Miss Robert's moved to join the CVRA action, claiming she too, had her CVRA

rights violated by the government. On January 1, 2015, Miss Robert's filed a corrected,

joined her motion. Miss Robert's statement, Controverting Defendants Facts, agreed. Defendants purported

facts. 7. The issue presented in her joined her motion was narrow. Whether she should be permitted

to join the CVRA action as a party under federal rule of civil procedure 21, specifically,

whether she was a known victim of Mr. Epstein and the government owed them CVRA duties. Yet,

the bulk of the motion consists of copious factual details that Miss Robert's and her co-movement

would prove if allowed to join. Miss Robert's gratuitously included for a

vocative in learned details over alleged sexual activities as an alleged victim of sexual trafficking.

Miss Robert's statement, Controverting Defendants Facts. Miss Robert's denies that the issues

presented in here joined her motion were narrow. The issues presented by the joined her motion

and related pleadings were multiple and complex requiring numerous details about Miss Robert's

sexual abuse and the perpetrators of her abuse. In a pleading explaining why the motion was filed,

Miss Robert's lawyers specifically listed nine separate reasons why Jane Doe No. 3's allegations

that Dershowitz had sexually abused her were relevant to the case and appropriately included

in the relevant findings. 1. To establish that Jane Doe 3 had been sexually abused by Jeffrey

Epstein and his co-conspirators, including co-conspirator Alan Dershowitz, which would make her a victim

of a broad sex trafficking conspiracy, covered by the Federal Crime Victims Rights Act,

US Code 18, Section 3771, and therefore entitled to participate in the case. 2. To support or

then pending discovery requests that asked specifically for information related to the contacts

by Dershowitz with the government on behalf of Jeffrey Epstein. 3. To support the victim's

allegation that the government had a motive for failing to afford victims with their rights

in the criminal process specifically pressure from Dershowitz and other members of Epstein's legal

defense team to keep the parameters of the non-prosecution agreement secret to prevent Jane Doe 3

and other victims from objecting to and blocking judicial approval of the agreement.

4. To establish the breadth of the NPA's provision extending immunity to any potential

co-conspirators of Epstein and the scope of the remedy that the victims, including not only Jane Doe 3,

but also other similarly situated minor victims who had been sexually abused by Dershowitz

might be able to obtain for violations of their rights. 5. To provide part of the factual context

for the scope of the interface between the victims, the government, and Epstein's defense team.

An interface that was relevant under Judge Mara's previous ruling that the government was entitled

to raise a fact-sensitive equitable defense which must be considered in the factual context of the

entire interface between Epstein, the relevant prosecutorial authorities, and the federal offense

victims. 6. To prove the applicability of the crime fraud misconduct exception to the attorney

client privilege that was being raised by the government in opposition to the victim's motion

for production of numerous documents. 7. To bolster the victim's argument that they're

right to be treated with fairness, U.S. Code 18, Section 3771-A8, had been violated through the

government's secret negotiations with one of their abusers. Hello, it is Ryan, and we could all

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for free anytime, anywhere with daily bonuses. 8. To provide notice and lay out the parameters

of potential witness testimony for any subsequent proceedings or trial, i.e. the scope of the

testimony that Jane Doe 3 was expected to provide in support of Jane Doe 1 and Jane Doe 2,

the already recognized Ms. Roberts in the action. 9. To support Jane Doe 3's argument for

equitable, e-stopped to toll the six-year statute of limitation, being raised by the government

in opposition to her motion to join. i.e. that the statute was told while she was in hiding in

Australia due to the danger posed by Epstein and his powerful friends, including prominent lawyer

Alan Dershowitz. Jane Doe's number one and number two, United States, number nine,

zero eight, CV, eight, zero, seven, three, six, DE, 291. At 18 through 26 and N17, SD, Florida,

2015, Ms. Roberts lawyers had attempted to obtain a stipulation from the government on point

number one above victim status, but the government had declined. Judge Mara's ruling concluded that

certain allegations were not necessary at this juncture in the proceedings. DE-324 at five.

Judge Mara specifically added, however, that Jane Doe 3 is free to reassert these factual

details through proper evidentiary proof should petitioners demonstrate good faith basis for

believing that such details are pertinent to a matter presented for the court's consideration.

DE-324 at six. The CVR litigation continues and O trial has been held as of the filing of this

brief. As such, the extent to which these factual details will be used at trial has not yet been

determined. See docket sheet, Jane Doe's number one and two, versus the US number nine, zero,

eight, CV, eight, zero, seven, three, six. All right folks, we're going to wrap up part one here

and in the next episode we'll pick up, we'll part two. 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

Virginia's statement of contested facts and plaintiffs undisputed facts.

Defendants purported facts. Number eight. At the time they filed the motion, Ms. Roberts and

her lawyers knew that the media had been following the Epstein criminal case and the CVRA action.

While they deliberately filed the motion without disclosing Ms. Roberts' name,

claiming the need for privacy and secrecy, they made no attempt to file the motion under seal.

Quite the contrary, they filed the motion publicly. Ms. Roberts' statement,

contributing defendants facts. See Ms. Roberts' response to point seven above.

Defendants purported facts. Number nine. As the district court noted in ruling on the

joint remotion, Ms. Roberts' name, several individuals, and she offers details about the type

of sex acts performed and where they took place, the court ruled that these lurid details are

unnecessary. The factual details regarding whom and where the jane those engaged in sexual

activities are immaterial and impertinent, especially considering that these details involved

nonparties who are not related to the respondent government. Accordingly, these unnecessary details

shall be stricken. The court then struck all Ms. Roberts' factual allegations relating to her

alleged sexual activities and her allegations of misconduct by nonparties. The court said the striking

of the lurid details was a sanction for Ms. Roberts' and proper inclusion of them in the motion.

Ms. Roberts' statement, contributing the defendant's facts. See Ms. Roberts' response to point seven

above. Defendants purported facts. Number 10. The district court found not only that the lurid details

were unnecessary, but also that the entire joint remotion was entirely unnecessary. Ms. Roberts

and her lawyers knew the motion with all of its lurid details was unnecessary because the motion

itself recognized that she would be able to participate as a fact witness to achieve the same

result she sought as a party. The court denied Ms. Roberts' joint remotion. Ms. Roberts' statement,

contributing defendants' facts. See Ms. Roberts' response to point number seven above.

Defendants purported facts. One of the nonparties Ms. Roberts' name repeatedly in the joint

remotion was Ms. Maxwell. According to the lurid details of Ms. Roberts, included in the motion,

Ms. Maxwell personally was involved in a sexual abuse and sex trafficking scheme created by Epstein.

Ms. Maxwell approached Ms. Roberts in 1999 when Ms. Roberts was 15 years old to recruit her into

the scheme. Ms. Maxwell was one of the main women Epstein used to broker underage girls for sexual

activities. Ms. Maxwell was a primary co-conspirator with Epstein in his scheme. She persuaded Ms. Roberts to

go to Epstein's mansion in a fashion very similar to the manner in which Epstein and his other

co-conspirators coerced dozens of other children. At the mansion when Ms. Roberts began giving Epstein

a massage, he and Ms. Maxwell turned it into a sexual encounter. Epstein with the assistance of

Ms. Maxwell converted Ms. Roberts into a sex slave. Ms. Maxwell was also a co-conspirator and Epstein's

sexual abuse, Ms. Maxwell appreciated the immunity she acquired under Epstein's plea agreement

because the immunity protected her from prosecution for the crime she committed in Florida.

Ms. Maxwell participated in a sexual abuse of Ms. Roberts and others. Ms. Maxwell took numerous

sexually explicit pictures of underage girls involved in sexual activities, including Ms. Roberts.

She shared photos with Epstein. As part of her role in Epstein's sexual

abuse ring, Ms. Maxwell connected Epstein with powerful individuals so that Epstein could

traffic Ms. Roberts to these persons. Ms. Roberts was forced to have sexual relations with Prince Andrew.

In Ms. Maxwell's apartment in London, Ms. Maxwell facilitated Ms. Roberts' sex with Prince Andrew

by acting as a Madame for Epstein. Ms. Maxwell assisted in internationally trafficking Ms. Roberts

and numerous other young girls for sexual purposes. Ms. Roberts was forced to watch Epstein,

Ms. Maxwell, and others engaged in illegal sexual acts with dozens of underage girls. Ms.

Roberts' statement controversy defendants facts. Ms. Roberts responds to point seven above. Ms.

Roberts contests the reference to alert details. Moreover, the testimony from numerous witnesses

corroborates the statements Ms. Roberts made in her joineder motion.

C. McCauley declaration at exhibit 16. C. McCauley declaration at exhibit 4.

C. McCauley declaration at exhibit 14. C. McCauley declaration at exhibit 12.

C. McCauley declaration at exhibit 13. C. McCauley declaration exhibit 15.

C. McCauley declaration exhibit 10. C. McCauley declaration exhibit 8.

C. McCauley declaration exhibit 1. C. McCauley declaration exhibit 30.

C. McCauley declaration exhibit 33. C. McCauley declaration at exhibit 38.

McCauley at exhibit 28. McCauley at exhibit 29. McCauley at exhibit 40.

and McCauley at 32. See McCauley at Exhibit 39, and then, finally, see McCauley declaration at

Exhibit 41. The defendants purported facts, 12. In her joint promotion, Ms. Roberts also alleged she

was forced to have sex with Harvard Law Professor Alan Dershowitz, Model Scout, Jean-Luc Brunel,

and many other powerful men, including numerous prominent American politicians, powerful business

executives, foreign presidents, a well-known Prime Minister, and other world leaders.

Ms. Roberts statement, contributing defendants' facts, see response to point number 7 and 11 above.

Defendants purported facts, number 13. Ms. Roberts said, after serving for four years as a sex

slave, she managed to escape to a foreign country and hide out from Epstein and his co-conspirators

for years. Ms. Roberts statement, contributing defendants' facts. Agree that Ms. Roberts made

the statement, and has since discovered evidence that indicates she was mistaken on the exact

time frame of her abuse, and was with defendant and Jeffrey Epstein from the years 2000 to 2002.

Defendants purported facts. Ms. Roberts suggests the government was part of Epstein's conspiracy

when it secretly negotiated a non-prosecution agreement with Epstein, precluding federal

prosecution of Epstein and his co-conspirators. The government secrecy Ms. Roberts alleged

was motivated by its fear that Ms. Roberts would raise powerful objections to the agreement

that would have shed tremendous public light on Epstein and other powerful individuals.

Ms. Roberts statement, contributing the defendants' facts. Ms. Roberts did not suggest that the

government was part of Epstein's conspiracy to commit sex offenses. The CVRA case deals with whether

the government failed in their responsibilities to the victims to inform the victims that the

government was working out an NPA. And it is Ms. Roberts believed that the government did fail

to so inform the victims and intentionally did not inform the victims because the expected

serious objection from many of the victims might prevent the government from finalizing an NPA

with Epstein. See McCauley Declaration at Exhibit 50. Join her motion, Roberts 0-0-319-00333.

The defendants purported facts. 15. Notably the other Jane though, who joined Ms. Roberts'

motion who alleged she was sexually abused many occasions by Epstein was unable to corroborate

any of Roberts' allegations. Ms. Roberts statement, contributing the defendants' facts. This is

untrue. The other Jane though could corroborate many of Ms. Roberts' allegations based on the

similar pattern of abuse that she suffered by Epstein. She did not know Ms. Roberts though,

redacted who was deposed in this case and who was the minor corroborates the same pattern of

abuse. See McCauley Declaration at Exhibit 7. Defendants purported facts. 16. Also notably in our

multiple and lengthy consensual interviews with Ms. Churcher, three years earlier, Ms. Roberts

told Ms. Churcher of virtually none of the details she described in the joineder motion.

Ms. Roberts statement, contributing defendants' facts. This is untrue. Furthermore,

defendant does not offer any citation or evidence on this point. Defendants statement here is knowingly

false. Having read the articles and taken Ms. Roberts' deposition, defendant knows that Ms. Roberts

did reveal details in 2011, consistent with those in the joineder motion. See McCauley Declaration

at Exhibit 31. FBI redacted 302. Roberts 001-35-1246. The defendants purported facts. 17.

Ms. Maxwell's response to Ms. Roberts' lurid accusation, the January 2015 statement.

As Ms. Roberts and her lawyers expected, before Judge Mara in the CVRA action could strike the

lurid details of Ms. Roberts allegations in the joineder motion, members of the media

obtain copies of the motion. Hey, it's Cole Swindle, and when I spend 200 days a year rolling

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contraverting defendant's facts. See Ms. Roberts' response to point number seven above?

Defendants purported facts. 18. At Mr. Barton's direction on January 3, 2015, Mr. Gau

sent to numerous representatives of British media, organizations, and email containing

a quotable statement on behalf of Ms. Maxwell. The email was sent to more than six and probably

less than 30 media representatives. It was not sent to non-media representatives. Ms. Roberts'

statement, contraverting the defendant's facts. Defendant falsely claims that Mr. Barton's

direction on January 3, 2015, Mr. Gau sent to numerous representatives of British media

organizations and email containing a quotable statement on behalf of Ms. Maxwell. This is a

blatant falsehood about the document that is at the heart of this litigation. Record evidence

shows that Gau sent that email at defendant's direction, not at Mr. Barton's direction.

Indeed, on the evening before his deposition, Mr. Gau produced an email,

exchange he had had with the defendant in which the defendant directs Mr. Gau to the press statement.

Chronologically, this email comes at the end of various other email exchanges between the defendant

and Gau that discusses issuing a press release. The subject line of this email,

that defendant wrote to Gau state's urgent, this is the statement, thereby instructing Gau to

release this statement to the press. Shortly after defendant sent this email to Gau,

directing him to release the statement, Gau distributed the statement to multiple media outlets.

Neither defendant nor Gau have produced any email in which Barton directed Gau to issue this

press release, nor can they. Despite sending it herself and despite it being responsive to six

court-ordered search terms, defendant failed to reduce this email. Her press agent Gau produced

this the evening before this deposition, on November 17, 2016, at the deposition Mr. Gau

authenticated this email and confirmed that the defendant authorized the statement.

Question, when you sent that email, were you acting pursuant to Ms. Maxwell's retention of your

services? Answer, yes I was. Question, this also appears to be an email chain, with you and Ms.

Maxwell is that correct. Answer, it does appear to be so. Question, did you send the top email

of the chain that says, okay, gee, going with this? Answer, I did. Question, and did you receive

from Ms. Maxwell the bottom email of that chain? Answer, I believe so. Well, I believe, yes, yeah,

it was forwarded from Ms. Maxwell, yes. Mr. Dyer, sorry, I don't quite understand that answer.

The witness, I must spoke that. I did receive it from Ms. Maxwell. Mr. Dyer, okay? Question,

the subject line does have forward, which to me indicates it's a forward. Do you know where the rest

of that email chain is? Answer, my understanding of this is, it was a holiday in the UK, but Mr.

Barton was not necessarily accessible at some point in time. So this had been sent to him originally

by Ms. Maxwell. And because he was unavailable, she forwarded it to me for immediate action. I

therefore responded, okay, Galaine, I'll go with this. It's my understanding that this is the

agreed statement because the subject of the second one is urgent. This is the statement. So I take

that as an instruction to send it out as a positive command. This is the statement. See McCauley

Declaration at exhibit six. Together, the email and Gal's testimony unequivocally established that

defendant, not Barton directed and commanded, Gal to publish the defamatory statement.

Accordingly, the first sentence of defendant's paragraph 18 is false. The second statement,

this email was sent to more than six and probably less than 30 media representatives omits the

fact that not only did Gal admit to emailing the statement to the press, but he also read it to

over 30 media representatives over the phone. Question, do you recall reading the statement to the

press or the media over the phone? Answer, it's very possible that I would have done so.

Question, do you, do you remember discussing that with the guardian answer? No, I don't. I'm not

saying I didn't, but I don't recall. You have to bear in mind if you'd be so kind that I've

been speaking to over 30 journalists and media outlets about this and I can't recall every single

detail of every single conversation. See McCauley Declaration at exhibit six. Thus, the second sentence

of defendant's paragraph 18 is also false. All right, folks, we're going to wrap up right here

and then the next episode will pick up where we left off. All of the information that goes with this

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