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What's up everyone and welcome back to the Epstein Chronicles.
This episode we're picking right back up where we left off with the SDNY rule 56.1
court document. The defendants purported facts 34.
Miss Maxwell, under agents, exercised no control or authority over any media organization,
including the media identified, image Roberts' response to interrogatory number six
in connection with the media's publication of portions of the January 2015 statement.
Miss Roberts statement, contributing the defendants' 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 Gow,
because his position allowed him to influence the press to publish her defamatory statement.
A sampling of Gow'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 2, 2015? Answer, yes.
Question, do you recall the terms of that agreement? Answer, well, it was a reestablishment
of an existing agreement. So if we go back to the original agreement, it was to provide public
relation services to Miss Maxwell in the matter of Roberts and her activities.
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 her 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
March 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 opinions 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 advertise your excellent 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 defendant's facts. Agreed, but noting that the defamation calls of action against
defendant did not accrue until defendant, defender, and January of 2015. The same year Ms. Roberts filed
suit against defendant for defamation. The defendants reported facts that complaint alleges that the
January 2015 statement contained the following deliberate falsehoods. A, that Roberts sworn allegations
against Galen 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 Austrich. She and Austrich thereafter rented an apartment
and fought 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 Austrich rented an apartment for the couple on bento drive and
royal Palm Beach. Although Ms. Roberts agreed to marry Austrich, 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 Austrich testified that he proposed to Ms. Roberts on Valentine's Day,
see Austrich 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 Austrich.
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 Austrich, 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 Survivors Charter School.
Survivors Charter School was an alternative school designed to assist students who had been
unsuccessful at more traditional schools. Ms. Roberts remained enrolled at Survivors 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 Survivors 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 Codes
W32 and W47. With Drull Codes 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 Survivors 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 4 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 4 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. See McCauley Declaration Exhibit 27 Ms. Roberts obvious gap in her school attendance
her presence verified by Epstein's pilot on flight logs and an abundance of witness testimony
all corroborate her story that she Ms. Roberts was flying domestic and internationally with Epstein
at least 32 times between 1211 of 2000 and 7208-01 and 621-02 and 821-02 defendant traveling
with Ms. 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 Galen 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 defendant's purported
facts 39. During the year 2000 Ms. Roberts worked at numerous jobs in 2000 while living with her
fiance Ms. Roberts held five different jobs at avoculture breeding and research center southeast
employee management company the club at Marolago oasis outsourcing and Neiman Marcus her
taxable earnings that year totaled nearly $9,000 Ms. Roberts cannot now recall either of the
southeast employee management company or the oasis outsourcing job Ms. Roberts statement
controversy defendant's facts Ms. Roberts disputes this statement during 2000 Ms. Robert
shared an apartment with her then boyfriend James Michael Austridge and his friend Mario
see McCauley Declaration exhibit two although Austridge testified that he proposed to Ms. Roberts
on Valentine's Day see Austridge 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 legal age to
marry while Ms. 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 Ms. Roberts cannot recall two
companies listed honor 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 Ms. Roberts is testified that she believes she worked at Taco Bell
at an aviary then Mar-a-Lago see McCauley Declaration at exhibit five Austria also testified
that Ms. Roberts work 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 Ms. Roberts SSA records because they were most likely paid through payroll companies see McCauley
Declaration at exhibit 46 Ms. 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 2000 is $99.48 see McCauley Declaration
at exhibit 46 the defendant's purported facts Ms. Roberts employment at the Mar-a-Lago spa began in
the fall of 2000 Ms. 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 Ms. Roberts for a job there Mar-a-Lago closes every mother's day
and reopens on November 1 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 Ms. 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 Ms. Roberts statement contraverting defendants
facts Ms. Roberts disputes this statement defendant cannot simply infer Ms. Roberts employment
and claim it to be undisputed the Mar-a-Lago club produced 177 pages of records in response to
defendant subpoena however not one page indicated Ms. 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 Ms. Roberts was terminated in 2000 job postings
and job descriptions produced by Mar-a-Lago from 2002 and later are irrelevant to Ms. Roberts
employment because they are from after she worked there Ms. 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 want to lessy
testified that it was summer when defendant approached Ms. Roberts at Mar-a-Lago because he
specifically remembered that day I was sweating like hell in in the car waiting for Ms. Maxwell to
come out of the massage see McCauley declaration at exhibit one a lessy deposition defendants
reported facts 41 Ms. Roberts represented herself as a masseuse for Jeffrey Epstein while working at
the Mar-a-Lago spa and reading a library book about massage Ms. Roberts met Ms. Maxwell Ms. Roberts
thereafter told her father that she got a job working for Jeffrey Epstein as a masseuse Ms.
Roberts father took her two 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 Ms. Roberts was excited about her job as a masseuse about traveling with
them and about meeting famous people Ms. Roberts represented that she was employed as a masseuse
beginning in January 2001 Ms. Roberts never mentioned Ms. Maxwell to her then fiancee ostrich
Ms. Roberts father never met Ms. Maxwell Ms. Roberts statement contraverting defendants facts Ms.
Roberts denies defendants false 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 Ms. 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 6124 she was approached by defendant who told her she can make money as a masseuse a profession
in which Ms. Roberts had no experience see McColley declaration at exhibit 5 Sky Roberts
Virginia Roberts father verified Ms. Roberts account that defendant recruited his daughter to learn
massage therapy see McColley declaration at exhibit 17 Ms. Roberts father drover to Jeffrey
Epstein's house the address of which was given to her by the defendant see McColley declaration
at exhibit 5 Ms. 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 Ms. Roberts
money and a better life to be compliant in the sexual demands of defendant and Epstein see McColley
declaration at exhibit 5 the minor Ms. 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 McColley declaration at exhibit 1 and 5 Epstein's
house manager Juan Alessi described defendant's methodical routine of how she prepared a list of
places ahead of time then drove to each place for the purpose of recruiting girls to massage Epstein
McColley 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
Ms. Roberts at Epstein's house on the very same day that he witnessed defendant recruit Ms.
Roberts from Mar-a-Lago see McColley 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
McColley declaration at exhibit 16 Schoberg testified that she answered phones for one day before
defendant proposition to rub feet for a hundred bucks an hour see McColley declaration at exhibit 16
the following day Schoberg was paired with defendant's assistant Emmie Taylor who provided her
with massage training on Epstein Schoberg at 13 and 15 Ms. Roberts then boyfriend Ostrich
testified that he could not recall the name of the person who recruited Ms. Roberts however he
did say she was recruited by someone to work for Epstein as a massage therapist but that Ms.
Roberts did not have any experience see McColley declaration at exhibit 2 neither Ms. Roberts
nor Ms. 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 McColley declaration at exhibit 16
the defendant's purported facts 42 Ms. Roberts resumed a relationship with convicted felon
Anthony Figueroa in spring 2001 while living with Ostrich Ms. Roberts lied to and cheated on him
with her high school boyfriend Anthony Figueroa Ms. Roberts and Ostrich thereafter broke up
and Figueroa moved into the bento compartment with Ms. Roberts when Ostrich returned to the bento
compartment to check on his pets and retrieve his belongings Figueroa and Ms. Roberts presence
punched Ostrich in the face Figueroa and Ms. Roberts fled the scene before police arrived
Figueroa was then convicted felon and drug abuser on probation for possession of a controlled
substance Ms. 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 Ms. Roberts
dating history as a young teen there is no relation to the allegations made within Ms. Roberts
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 forth in Ms. Roberts objections to designated
testimony the alleged information would be excluded by multiple rules of evidence and contested by
Ms. Roberts see McCauley declaration at exhibit five more over it was the defendant who solicited
avenue Figueroa to recruit high school aged girls for Epstein see McCauley declaration at exhibit four
defendants purported facts Ms. 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 Ms. Roberts and Figueroa hosted a party with a number
of guests during the party according to Ms. Roberts someone entered Ms. Roberts room and stole
$500 from her shirt pocket Ms. 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 Ms. Roberts contacted the police to report that her former landlord
had left her belongings by the roadside and had litter a mattress on fire again Ms. 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 Ms. Roberts statement
contraverting the defendant's facts this statement is misleading in several respects and irrelevant
the fact that Ms. 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 defendant implies that anytime someone calls the police for one
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 canote 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 Ms. 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 Ms. 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 going to wrap up this episode
here and in the next episode dealing with 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
The Vault: The Epstein Files
