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The Epstein Chronicles
Mega Edition: Virginia Roberts Responds To Maxwell's Summary Judgement Request (Part 1-3) (6/7/26)
00:45:56
Virginia Giuffre’s response to Ghislaine Maxwell’s motion for summary judgment was a direct challenge to Maxwell’s attempt to dismiss the case without a trial. In her filing, Giuffre argued that Maxwell’s statements denying any wrongdoing were not...
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What's up everyone? And welcome back to the Epstein Chronicles. On today's episode, we're going to begin taking a look at Virginia Roberts response to Ghislaine Maxwell's motion for a summary judgment. And this goes right along with the Virginia Roberts deposition that we just went through over the past week or so. This document is pretty big, but not quite as big as the deposition. So. So it won't take us as long to get through this one. But with that said, it is still relatively lengthy. So why don't we just dive right in and get started. Case 15 CV07433 RWS Virginia Roberts vs Ghislaine Maxwell Preliminary Statement There can be no question that disputed issues of material facts preclude granting summary judgment when in one count defamation case, defendant presents the court with a 68 page memorandum of law, a 16 page statement of purported facts, and approximately 700 pages of exhibits. The sheer scope of Defendant's response, if anything, conclusively demonstrates that volumes of disputed facts surround the core question of whether defendant abused Ms. Roberts. Indeed, defendant acknowledges a dispute between the parties as to whether she abused Ms. Roberts. See Motion for Summary Judgment at 1. Motion to Dismiss at 1. This Court already said that this disputed factual question is central to this case. Either Plaintiff is telling the truth about her story and the Defendant's involvement, or Defendant is telling the truth and she was not involved in the trafficking and ultimate abuse of Plaintiff. The answer depends on facts. Defendant statements are therefore actionable as defamation. Whether they ultimately prove to meet the standards of defamation, including but not limited to falsity, is a matter for the fact Finder. Order denying Defendant's motion to dismiss at 10. While this fact remains in dispute, summary judgment is foreclosed. But even turning to Defendant's claims, the avalanche of aspersions she casts upon Ms. Roberts and and her counsel should not distract the court from the fact that the instant motion cannot come within sight of meeting the standard for an award of summary judgment. The most glaring and emblematic example of the Defendant's far fetched claims appears in her attempt to move away from her defamatory statement by arguing that it was her attorney and not her who issued the defamatory statement for the press to publish, though she is forced to admit the statement was was made on her behalf. This is an untenable position to take at trial and an impossible argument to advance at summary judgment stage as both the testamentary and documentary evidence positively refute that argument. Defendant incorrectly asked this court to make a factual finding that her defamatory press release was actually a legal opinion issued not by her but by her lawyer to the media despite documentary evidence showing otherwise. Defendant also argues that she has proven the truth of her statement calling Ms. Roberts a liar with respect to the statements Ms. Roberts made about Defendant to the contrary, evidence both documentary and testimonial from numerous witnesses corroborate Ms. Roberts account of Defendant's involvement in the sexual abuse and trafficking of Ms. Roberts. Just to briefly highlight a few Johanna Schoberg testified that Defendant recruited her under the guise of legitimate assistant position but asked her to perform sexual massages for Epstein and punished her when she didn't cause Epstein to orgasm. Tony Figueroa testified that Defendant contacted him to recruit high school age girls for Epstein and also testified that Maxwell and Epstein participated in multiple threesomes with Virginia Roberts. Even more shockingly, the butler for Defendant close friend witnessed firsthand a 15 year old Swedish girl who crying and shaking because Defendant was attempting to force her to have sex with Epstein and she refused. This is a fraction of the testimony that will be elicited at trial about Defendant's involvement in the sexual abuse of trafficking. Ms. Roberts Defendants primary argument in support of her contention that she did not abuse and traffic Ms. Roberts as a minor child is that employment records show that Ms. Roberts was either 16 or or 17 when defendant recruited her from her job at Mar a Lago for sex with Epstein. Not 15 years old as Plaintiff originally thought. Call this yes, I'm a sex trafficker but only of 16 year old girls. Defense Defendant does not explain why sexual abuse of a 15 year old differs in any material way from the sexual abuse of a 16 or 17 year old. All instances involve a minor child who cannot consent and who is protected by federal and state laws. The fact remains that the defendant recruited Ms. Roberts while she was a minor child for sexual purposes and then proceeded to take her all over the world on convicted pedophile Jeffrey Epstein's private jet the Lolita Express as well as to his various residences and even to her own London house flight logs even reveal 23 flights that defendant shared with Ms. Roberts. Although defendant claims she was unable to remember even a single one of those flights, inconsequential details that Ms. Roberts may have originally remembered incorrectly do not render her substantive claims of abuse by Defendant false, much less deliberate lies. At most, these minor inaccuracies in the context of a child suffering from a troubled childhood and sexual abuse create nothing more than then a fat question on whether defendant statements that Ms. Roberts lied when she accused Defendant of abuse is substantially true, thereby precluding summary judgment. See Mitra Sports International Limited versus Home Box Office, Inc. 22 F. Supp. 3d 240, 255 SDNY 2014. Because determining whether COI is is substantially true would require this court to decide disputed facts, summary judgment is not appropriate. Defendant has tried to spin these inconsequential mistakes of memory into talismanic significance and evidence of some form of bad faith litigation. But this claim falls under the weight of the evidence. As the Court knows, the clear weight of the evidence establishes Defendants heavy and extensive involvement in both Jeffrey Epstein's sex trafficking ring and in recruiting Ms. Roberts, living with her and Jeffrey Epstein in the Same Homes while Ms. Roberts was a minor and traveling with Ms. Roberts and Jeffrey Epstein, including 23 documented flights. Even the House staff testified that defendant and Ms. Roberts were regularly together. See the declaration of Sigrid McCauley at Exhibit 1. Alessi's deposition at 1034 9. After that day, do you recall that she started coming to the house more frequently? Yes, she did. In fact, did she start coming to the house approximately three times a week? Yes, probably. It is also undisputed that a witness deposed in this case have testified about Defendant's role as as a procurer of underage girls and young women for Jeffrey Epstein. At the very least, a trier of fact should determine whether the evidence establishes whether or not Ms. Roberts claims of Defendant being involved in her trafficking and abuse are true. Defendant's summary judgment motion should be denied in its entirety. Part 2 Undisputed facts the record evidence in this case is shows that Defendant shared a household with convicted pedophile Jeffrey Epstein for many years. While there, she actively took part in recruiting underage girls and young women for sex with Epstein, as well as scheduling the girls to come over and maintaining a list of girls and their phone numbers. Ms. Roberts was indisputably a minor when Defendant recruited her to have sex with convicted pedophile Jeffrey Epstein. Thereafter, Ms. Roberts flew on Epstein's private jets, the Lolita Express with defendant at least 23 times. It is an undisputed fact that multiple witnesses deposed in this case have testified that Defendant operated as convicted pedophile Jeffrey Epstein's procurer of underage girls. 1. It is an undisputed fact that Johanna Shuberg testified Defendant lured her from her school to have sex with Epstein on under the guise of hiring her for a job answering phones. Ms. Shuberg's account of her experiences with Defendant are chillingly similar as with Ms. Roberts. Defendant, a perfect stranger, approached Ms. Shuberg while trolling Ms. Shuberg's school grounds. She lured Ms. Shuberg into her and Epstein's home under the guise of a legitimate job of answering phones, a pretext that lasted only a day. A a young college student nearly 2,000 miles away from home. Defendant soon instructed Ms. Shuberg to massage Epstein and made it clear that Shuberg's purpose was to bring Epstein into orgasm during these massages so that Defendant did not have to. And when did you first meet Ms. Maxwell? 2001. March. Probably end of February. Beginning of March. And how did you meet her? She approached me while I was on campus at Palm Beach Atlanta College. And how long did you work in that position answering phones and doing. Just one day. And what happened that second time you came to the house? At that point, I met Emmy Taylor, and she took me up to Epstein's bathroom, and he was present, and her and I both massaged Epstein. She was showing me how to massage, and then she. He took. He got off the table. She got on the table. She took off her clothes, got on the table. And then he was showing me moves that he liked. And then I took my clothes off. They asked me to get on the table so I could feel it. Then they both massaged me. Who did Emmy work for? Ghislaine. Question. Did Maxwell ever refer to Emmy by any particular term? She called her her slave. Did Jeffrey ever tell you why he received so many massages from so many young girls? He explained to me that in his opinion, he needed to have three orgasms a day. It was biological, like eating. Was there anything you were supposed to do in order to get the camera? The witness, and remember this witness is Johanna Shuberg. I did not know that there were expectations of me to get the camera until after she had purchased the camera for me and I was over there giving Jeffrey a massage. I didn't know that she was in possession of the camera until later. She told me, called me after I had left and said, I have the camera for you, but you cannot receive it yet because you came here and didn't finish your job and I had to finish it for you. And did you. What did you understand her to mean? She was implying that I did not get Jeffrey off. And. And so she had to do it. Question and when you say get Jeffrey off, do you mean bring him the orgasm? Answer yes. Question Based on what you knew, did Maxwell know the type of massages Jeffrey was getting? Typically involved sexual acts? The witness yes.
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Podcast Host / Narrator
Question what was Maxwell's main job with respect to Epstein the witness? Well beyond companionship. Her job as it related to me, was to find other girls that that would perform massages for him and herself. Ms. Shuberg also testified about sexual acts that occurred with her, Prince Andrew and Ms. Roberts when she and defendant were staying at Epstein's Manhattan mansion. Tell me how it came to be that there was a private picture taken. I just remember someone suggesting a photo and they told us to get on the couch and so Andrew and Virginia sat on the couch and they put the puppet, the puppet on her lap. And so then I sat on Andrew's lap and I believe on my own volition and they took the puppet's hands and put it on Virginia's breast and so Andrew put his on mine. Ms. Shuberg's testimony corroborates Ms. Roberts account of the how defendant recruited her and others under a ruse of a legitimate job in order to bring them into the household to have sex with Epstein. Ms. Shuberg's testimony also corroborates Ms. Roberts account of being lent out to Prince Andrew by the defendant as even the interaction Ms. Shuberg witnessed included a sexual act. Prince Andrew using a puppet to touch Ms. Robert's breast while using a hand to touch Ms. Shuberg's breast. Alright folks, we're gonna wrap up with part one there in the next episode on this topic we'll pick up with part two. All of the information that goes with this episode can be found in 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 Virginia Roberts and her response to Ghislaine Maxwell seeking a summary judgment. 2. It is an undisputed fact that Tony Figueroa testified that defendant would call him to bring over underage girls and that the defendant and Epstein would have threesomes with Ms. Roberts. Tony Figueroa testified that plaintiff told him about the threesomes Ms. Roberts had with defendant and Epstein, which included the use of strap ons. Question, and tell me everything that you remember about what Ms. Roberts said about being intimate with Ms. Maxwell and Mr. Epstein at the same time. Figueroa responds, I remember her talking about like, strap ons and stuff like that, but I mean, like I said, all the details are not really that clear, but I remember her talking about, like, how they would always be using that stuff like that. Question. She and Ms. Maxwell and Mr. Epstein would use strap ons. Figueroa responds, huh. Question. Other than sex with the prince, is there anyone else that Jeffrey wanted Ms. Roberts to have sex with that she relayed to you? Mainly, like I said, Just Ms. Maxwell and all the other girls Ms. Maxwell wanted. Jeffrey wanted Virginia to have sex with Ms. Maxwell. End him. Yeah. And did she tell you whether she had ever done that? Yeah, she said she did. And what did she describe having happened? I believe I already told you that. With the strap ons and dildos and everything. Redacted. Redacted. Figueroa also testified that defendant called him to ask if he had found any other girls for Epstein, thereby acting as a procurer of girls for Epstein. When Ghislaine Maxwell would call you during the time that you were living with Virginia, she would ask you what specifically? Just if I found other girls to bring to Jeffrey. Okay. Pretty much every time there was a conversation with any of them, it was either asking Virginia where she was at or asking her to go get girls. Or asking me to go get girls. OK, well, tell me, when did Ms. Maxwell ask you to bring a girl? Never in person. It was like, literally like on the phone. Maybe like once or twice. Alright. Did Ms. Maxwell call you frequently? No. Alright. How many times did you think Ms. Maxwell called you at all? I just say that probably just a few. A couple of times. Maybe once or twice. One or two. The majority of the time it was pretty much his assistant. How do you know Ms. Maxwell's voice? Because she sounds British. So someone with a British accent called you once or twice and asked for. Well, she told me who she was. Ok. And what did she say when she called you and asked you to bring girls. She just said, hi, this is Ghislaine. Jeffrey was wondering if you had anybody that could come over three. It is an undisputed fact that Ronaldo Rizzi testified that defendant took the passport of a 15 year old Swedish girl and. And threatened her when she refused to have sex with Epstein. Ronaldo Rizzi was the house manager for one of defendant's close friends, Eva Dubin. Mr. Rizzo testified through tears how while working at Dubin's house, he observed defendant bring a 15 year old Swedish girl to Dubin's house in distress. The 15 year old girl tearfully explained to him that defendant tried to force her to have sex with Epstein through threats and stealing her passport. How old Was this girl? 15 years old. Describe to me what the girl looked like, including her demeanor and anything else you remember about her when she walks into the kitchen. Very attractive, beautiful young girl. Makeup, very put together, casual dress, but seemed to be upset, maybe distraught. And she was shaking. And as she sat down she. She sat down and sat in the stool exactly the way the girls that I mentioned to you sat at Jeffrey's house with no expression and with her head down. But we could tell that she was very nervous. What do you mean by distraught and shaking? What do you mean by that shaking? I mean literally quivering. What did she say? She proceeds to tell my wife and I that. And this is not. This is blurting out, not a conversation like I'm having casual conversation that quickly. I was on an island. I was on the island and there was Ghislaine, there was Sarah. She said they asked for sex. I said no. And she is just rambling and I'm like, what? And she said, I asked her, I said what? And she says yes, I was on the island. I don't know how I got from the island to here last afternoon or in the afternoon. I was on the island and now I'm here. And I said, do you have a. This is not making any sense to me. And I said, this is nuts. Do you have a passport? Do you have a phone? And she says no. And she says Ghislaine took my passport. And I said what? And she says, Sarah took her passport and her phone and gave it to Ghislaine Maxwell. And at that point she said she was threatened. And I said threatened? She said, yes, I was threatened by Ghislaine Maxwell not to discuss this. And I'm just shocked. So the conversation. And she is just rambling on and on. Again, like I said, how she got here, she doesn't know how she got here. Again, I asked her, did you contact your parents? And she says no. At that point she says, I'm not supposed to talk about this. I said, but I said, how did you get here? I don't understand. We were totally lost for words. And she said that before she got there, she. She was threatened again by Jeffrey and Ghislaine not to talk about what I had just mentioned earlier. And she said that she was used for sex. And during this time that you're saying she is rambling is her demeanor continues to be what you described it? Yes. Was she in fear? Yes. Could you tell? Yes. She was shaking uncontrollably. Now, just to interject here, how do you let that even occur? How does Mr. Rizzo let that occur and not directly grab this girl and take her to the nearest police station? Or if you really want to go down as a hero, don't you just break Jeffrey Epstein's face right then and there? I know I would have. It would have been well worth it. 4. It is an undisputed fact that Lynn Miller testified that she believed defendant became Robert's new mama. Lynn Miller is Robert's mother. She testified that when Robert started living with Defendant, defendant became Robert's new mama incredulously. Defendant testified that she barely remembered Ms. Roberts. 5. It is an undisputed fact that Detective Joseph Riccari testified that he sought to investigate defendant in relation to his investigation of Jeffrey Epstein. Detective Ricari led the Palm Beach Police investigation of Epstein. He testified that the defendant procured girls for Epstein and that he sought to question her in relation to his investigation, but could not contact her due to the interference of Epstein's lawyer. Cross reference of Jeffrey Epstein's residence revealed which affiliated names it revealed Nadia Marcinkova, Ghislaine Maxwell, Mark Epstein, also the cross reference. Any previous reports from the residents as well. During your investigation, did you learn of any involvement that Nadia Marcinkova had with any of the activities that you are investigating? The other name that is on here as a cross reference is Ghislaine Maxwell. Did you speak with Ghislaine Maxwell? I did not. Did you ever attempt to speak with Ghislaine Maxwell? I wanted to speak with everyone related to this home, including Ms. Maxwell. My contact was through Gus attorney Gus Fronsten at the time, who initially had told me that he would make everyone available for an interview and subsequent conversations later. No one was available for an interview and everybody had an attorney and I was not going to be able to speak with them. Okay. During your investigation, what did you learn in terms of Ghislaine Maxwell's involvement, if any? The witness, Ms. Maxwell, during her research, was found to be Epstein's longtime friend. During the interviews, Ms. Maxwell was involved in seeking girls to perform massages and work at Epstein's home. 6. It is an undisputed fact that pilot David Rogers testified that he flew defendant and Ms. Roberts at least 23 times on Epstein's jet, the Lolita Express, and that GM on the flight log stands for Ghislaine Maxwell. Notably, at defendant's deposition, Defendant refused to admit that she flew with Ms. Roberts and denied that she appeared on Epstein's pilot's flight logs. However, David Rogers, Epstein's pilot, testified that the passenger listed on his flight logs bearing the initial's GM was in fact Ghislaine Maxwell and that he was the pilot on at least 23 flights in which Defendant flew with Plaintiff. The dates of those flights show that Ms. Roberts was was an underage child on many of them when she flew with defendant. 7. It is an undisputed fact that Sarah Kellen, Nadia Marcinkova and Jeffrey Epstein invoked the Fifth Amendment when asked about defendants trafficking girls for Jeffrey Epstein. Both Sara Kellen and Nadia Marcinkova lived with Jeffrey Epstein for many years. They both invoked the fifth Amendment. When asked about Defendants participation in in recruiting underage girls for sex with Epstein, Marcinkova testified, as did Ghislaine Maxwell, work as a recruiter for young girls for Jeffrey Epstein when you met her. Same answer, invoking the Fifth. Have you observed Ghislaine Maxwell and Jeffrey Epstein convert what started as a massage with these young girls into something sexual? Again, she takes the Fifth. Kellen testified, as did Ghislaine Maxwell, work as a recruiter for young girls for Jeffrey Epstein when you met her. On advice of my counsel, I must invoke the fifth Amendment and the sixth Amendment privilege. Isn't it true that Ghislaine Maxwell would recruit underage girls for sex and sex acts with Jeffrey Epstein? On advice of my counsel, I must invoke my fifth and and sixth Amendment privilege. Similarly, Jeffrey Epstein invoked the fifth Amendment when asked about Defendants involvement in procuring underage girls for sex with him? Question. Maxwell was one of the main women whom you used to procure underage girls for sexual activities. True.
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Podcast Host / Narrator
The witness. Fifth question. Maxwell was a primary co conspirator in your sexual abuse scheme. True. Epstein. Maxwell was a primary co conspirator in your sex trafficking scheme. True. Epstein. Fifth. Maxwell herself regularly participated in your sexual exploitation of minors. True. Fifth. Eight. It is an undisputed fact that Juanalesi testified that defendant was one of the people who procured over 100 girls he witness visit Epstein and that he had to clean defendant sex toys. Juana Lessee was Epstein's house manager. He testified as follows. Question. And over the course of that 10 year period while Ms. Maxwell was at the house, do you have any approximation as to the number of different females, females that you were told were massage therapists that came to the house? Alessi, I cannot give you a number, but I would say probably over a hundred. In my stay there, I don't think I asked that. Right. The question that I was looking to ask. So let me go back. Did you go out looking for the girls? No. Question to bring? Never. Question. As the massage therapist, Alessi? Never. Who did Ms. Maxwell, Mr. Epstein and their friends. Because their friends relay to other friends they knew a massage therapist and they would send to the house. So it was referrals. Did you have occasion to clean up after the massages? Yes. Okay. And that is after both a massage for Jeffrey Epstein as well as cleanup after a massage that Ghislaine Maxwell may have received? Yes. Question. And on occasion, after. In cleaning up after a massage of Jeffrey Epstein or Ghislaine Maxwell, did you have occasion to find vibrators or. Or sex toys that will be left out? Answer. Yes, I did. All right, we're gonna wrap up with episode two right there. And in the next episode, on 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 continue talking about Virginia Roberts and her response to Ghislaine Maxwell and Maxwell's request for a summary judgment. 9. It is an undisputed fact that defendant was unable to garner a single witness throughout discovery who can testify that she did not act as the procurer of underage girls and young women for Jeffrey Epstein. Defendant has not been able to procure a single witness, not one, to testify that Defendant did not procure girls for sex with Epstein or or participate in the sex. Even one of her own witnesses, Tony Figueroa, testified that she both procured girls and participated in the sex. Another one of the defendant's witnesses, Ms. Roberts mother, named defendant as Ms. Roberts new mama. Indeed, those who knew her well, who spent considerable time with her in Epstein's shared household, like Juana Lessee, Alfredo Rodriguez and Joanna Schuberg, have testified that she was Epstein's procuress. Others who live with her, Jeffrey Epstein, Nadia Marcinkova, and Sarah Kellen, invoked the Fifth Amendment so as not to answer questions on the same no one testified to the contrary. Documentary evidence also shows that defendant trafficked Ms. Roberts and procured her for sex with the convicted pedophile Jeffrey Epstein while she was underage. 1. The flight logs Defendant has never offered a legal explanation for what she was doing with and why she was traveling with a minor child on 21 flights while she was a child, including six international flights aboard a convicted pedophile's private jet all over the world. Her motion for summary judgment as well as previous briefing papers are absolutely silent on those damning documents. 2. The photographs throughout the mountain of briefing and even in her own deposition testimony, Defendant never offered an explanation regarding Ms. Roberts photographs of her defendant and Epstein. She never offered a legal explanation for why Prince Andrew was photographed with his hand around Ms. Roberts bare waist while she was a minor child while posing with Defendant inside Defendant's house in London. This particular photograph corroborates Ms. Roberts claims and there is no other reasonable explanation why an American child should be in the company of adults, not her kin, in the London house owned by the girlfriend of a now convicted sex offender. Ms. Roberts also produced pictures of herself taken when she was in New York with defendant Ann Epstein and from a trip to Europe with defendant N. Epstein. And Ms. Roberts has produced a number of pictures of of herself taken at Zorro Ranch, Epstein's New Mexico ranch, two of which are below. Finally, among other nude photos which included full nudes of defendant, Ms. Roberts produced images of females that the Palm beach police confiscated during the execution of the warrant, including one photograph revealing the bare bottom of a girl who appears to be prepubescent Ms. Roberts we will only submit in its redacted form the Victim identification letter. In 2008, the United States Attorney's Office for the Southern District of Florida identified Ms. Roberts as a protected victim of Jeffrey Epstein's abuse. The U.S. attorney mailed Ms. Roberts a notice of her rights as a crime victim under the CVRA. 4. New York Presbyterian Hospital records Ms. Roberts has provided extensive medical records in this case, including medical records from the time when Defendant was sexually abusing and trafficking her. Ms. Roberts produced records supporting her claim of being sexually abused in New York, resulting in both the Defendant and Epstein taking Plaintiff to New York Presbyterian Hospital in New York while she was a minor. The dates on the hospital records Show she was 17 years old. 5. Judith Lightfoot Psychological Records as the Court is aware, Defendant propounded wildly over broad requests for production concerning the past 18 years of Ms. Roberts medical history. The Defendant repeatedly argued to the Court that it was essential to procure every page of those records in a fanfare of unnecessary motion practice. Defendant's Motion to Compel the Defendant's motion for sanctions at 10. Ms. Maxwell has been severely prejudiced by Plaintiff's failure to provide the required identifying information and documents from her health care providers. Ms. Roberts and her counsel took on the considerable burden and significant expense of retrieving and producing over 250 pages of medical records from over 20 providers spanning two continents and nearly two decades. Now that those records have been collected, defendant's 68 page motion makes no reference to a single medical record produced by Ms. Roberts, nor a single provider, nor a single treatment, nor a single medication prescribed after Defendant's repeated motion practice stressing the essentiality of these records. This may surprise the court, but not not Ms. Roberts. Defendant's request unearthed documents that are highly unfavorable to defendant that corroborate Ms. Roberts claims against her. Years before this cause of action arose, Ms. Roberts sought counseling from a psychologist for the trauma she continued to experience after being abused by Defendant and Epstein. A 2011 psychological treatment record written by her treating psychologist unambiguously describes defendant as Ms. Roberts abuser. Ms. Roberts was approached by Ghislaine Maxwell who said she could help her get a job as a massage therapist, seem respectable, was shown how to massage, etc. Groff Epstein told to undress and perform sexual acts on person. Ms. Maxwell promised her 200 bucks after a job. Therefore, years after defendant defamed her, Ms. Roberts confided in her treating psychologist that Maxwell recruited her for sexual with Epstein. 6. Message pads Detective Riccari, the lead investigator of the criminal investigation into Epstein and his associate, Crime Sex, recovered carbon copies of handwritten messages taken by various staff, including Defendant, at Epstein's Palm beach residence. These were collected both from trash pulls from the residence and during the execution of the search warrant where the Pads were found laying and out in the open in the residence. The search warrant was executed in 2005 and the message pads collected include messages recorded in 2004 and 2005. Numerous witnesses have described these copies of collected messages accurately reflect those taken by various staff at the Palm Beach Epstein Mansion between 2004 and 2005. The messages raise a question of fact as to Maxwell's involvement in the sexual abuse of minors and are relevant to refute Maxwell's denial of any involvement with Epstein during relevant time periods and accordingly her denial of knowledge of certain events. While there were hundreds of these messages recovered during the investigation, this small sample demonstrates the undeniable reality that there exists a genuine issue of material fact with respect to defendants involvement in and knowledge of the activities described by Roberts which Maxwell has said were untrue and obvious lies. This sample reveals that Maxwell took messages at the residence including from underage girls who were calling to schedule a time to come over to see Epstein. This demonstrates that Maxwell was at Epstein's Palm Beach Mansion in 2004 and 2005, incidentally a time period she has denied being around the house in her deposition. C. Roberts 001-4120-014350-01449 the messages also reveal that multiple girls were leaving messages that were being taken and memorialized and left out in the open for anyone to see. Certain messages also make clear that a number of these girls were in school. In addition to taking messages herself and the staff working under her direction taking these relevant messages, staff employees were taking and leaving messages for the defendant. This is evidence that Maxwell was in the house at relevant times, including times that she has now testified under oath that she was not there. Other messages demonstrate Epstein and Maxwell's friends, including Jean Luc Brunel leaving messages relating to underage females. The following are descriptions of a sampling of message pads that create a genuine dispute of material facts. One message pad reflects redacted who is identified in the Palm beach police report as a minor contacting Jeffrey Epstein for work, explaining that she does not have any money. The term work was often used by members of Jeffrey Epstein's sexual trafficking ring to refer to sexual massages. C. Roberts at 05660 she stated she was called by Sarah for her return to work for Epstein. Stated work is the term used by Sarah to provide the massage and underwear. Roberts001462 7-5-No year to JE from I need work. I mean I don't have money. Do you have some work for me? Other message pads Reflect redacted who is a minor calling and leaving a message at the Palm beach mansion that she has recruited another girl for Jeffrey Epstein. The second massage demonstrates that Jeffrey Epstein required different girls to be scheduled every day of the week. The third shows an offer to have two minor girls come to the home at the same time to provide sexual massages. These types of massages indicate the lack of secrecy of the fact that multiple young females were visiting every day and at least raises a question of fact whether Maxwell was knowledgeable and involved as Roberts has said, or whether Roberts was lying and Maxwell was not at all involved or aware of this activity as defendant would attempt to have the world believe Roberts 001428 updated Jeffrey from hasgirl for tonight. Roberts 0014327904 Mr. Epstein from redacted redacted is available on Tuesday. No one for tomorrow. Mr. Epstein from me and can come tomorrow anytime or redacted alone. Roberts 001-4521 undated Jeffrey from redacted has a girl for tonight. Other message pads demonstrate that there was a pattern and practice of using young females to recruit additional females to provide sexual massages on a daily basis. Roberts 001413 je from N redacted hasn't confirmed for 11 yet so she is keeping Redacted on hold in case redacted doesn't call back. Roberts 001-448-8205JE from redacted redacted confirmed at 4pm who is scheduled for the morning. I believe redacted wants to work. This message pad reflects that a friend of Jeffrey Epstein is sending him a 16 year old Russian girl for purposes of sex. Roberts 001563 send for Jeffrey from Jean Luc. He has a teacher for you to teach you how to speak Russian. She is 2 times 8 years old and not blonde. Lessons are free and you can have your first today if you call this message pad directly refutes Maxwell's sworn testimony that she was not present during the year 2005 at Jeffrey Epstein's Palm beach mansion. Because this show's redacted leaving a message for Jeffrey at the Palm beach home that she was going to work out with the defendant on September 10, 2005. The police were only able to retrieve a fraction of these message pads during their trash pull, but even in the few they recovered, it shows Maxwell was regularly at the Palm beach home during the time period she claimed she was not. To the contrary, she was both sending and receiving messages like this one reflect her presence at the mansion. Roberts 001-412-9105 during the year Maxwell says she was never around. JE from I went to Sarah and made her water bottle and I went to workout with gm. These message pads further corroborate that defendant lied in her testimony and she was in fact in regular contact with Jeffrey Epstein during the years 2004 and and 2005. For example, the message from Larry demonstrates that defendant is at the Palm beach mansion so frequently that people including Epstein's main pilot Larry Vasoski are leaving messages for Maxwell at the Palm Beach House. Roberts 001-435-72504 Mr. Epstein from Ms. Maxwell tell him to call me. Roberts 001-4498, 2205JE from GM Roberts 001-453-42504 for Ms. Maxwell from Larry returning your call. This message pad shows that the defendant was clearly actively involved in Jeffrey Epstein's life and the activities at his Palm beach mansion. Robert 001454 Jeffrey from Ghislaine would be helpful to have redacted come to Palm beach today to stay here and help train the new staff with Galain.
- [42:40]
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This message pad clearly reflects an underage female noted by the police redaction of the name leaving a message asking if she can come to the house at a later time because she needs to stay in school. Roberts 001417 Jeffrey 220 8:05 she is wondering if 2:30 is okay. She needs to stay in school. The message pad reflects a message from redacted who was under the age of 18 at the time she was going over to Jeffrey Epstein's home to provide sexual massages according to the Palm beach investigative report. Roberts 001-423-4505 to Jeffrey Epstein from It is okay for redacted to stop by and drop something. The message pads reflect the pattern of underage girls noted by the police. Redaction of the name on the message pad calling the Palm beach mansion to leave a message about sending a female over to provide a sexual massage. Roberts 001-423-1104 to Mr. J.E. redacted from I have a female forum Roberts 001-426-0905 JE to JE from I have a female forum this message pad reflects the pattern and practice of having young girls bring other young girls to the house to perform sexual massages. Indeed, the redacted reflected in this message pad corresponds in name to the redacted that Tony Figueroa testified he initially brought to Jeffrey Epstein's during the time period that the defendant was requesting that Tony find him some young females to bring to Jeffrey Epstein's home. See Figueroa at 184 and 185. The Palm Beach Police report reflects that also brought 17 year oldacted to the home to perform sexual massages. C. Roberts O5641 thereafter recruited a number of other young girls to perform sexual massages as reflected in the Palm beach police report. Roberts 001-427-1203JE from redacted wants to know if she should bring her friend with tonight. This message pad reflects sexual massages being scheduled for the same day which corroborates Virginia Roberts redacted and Johanna Shuberg's testimony that Jeffrey Epstein required that he have multiple orgasms in a day which occur during these sexual massages. Roberts 001 499-0305 je from I left a message for redacted to confirm for 11:00am and redacted for 4:30pm this message pad shows a friend of Jeffrey Epstein's discussing with him how he had sex with an 18 year old who had also been with Jeffrey Epstein. Robert 001456 updated Je from Jean Luc he just did a good one 18 years she spoke to me and said I love Jeffrey. Law enforcement was able to confirm identities of underage victims through the use of the names and telephone numbers in these message pads. Question the next line down is what I wanted to focus on 4-5-2005 this trash what evidence is yielded from this particular trash pool? The witness the trash pool indicated that there were several messages with written items on it. There was a message from HR indicating that there would be an 11 o' clock appointment. There were other individuals that had called during that day and this is Detective Ricari answering these questions. Answer and when you would when you would see females names and telephone numbers would you take those telephone numbers and match it to a person? Witness we would do our best to identify that person was. Question and is that one way in which you discovered the identities of some of the other what soon to became known as the victims? The Witness Correct. Question do you find names of other witnesses and people that you knew to have been associated with the house in those message pads? The witness yes. Question and so what was the evidentiary value to you of the message pads collected from Jeffrey Epstein's home in that search warrant? Rickari it was very important to corroborate what the victims had already told me as to calling in and for work. Alright folks, we're gonna wrap up this episode here. In the next episode we're gonna pick up where we left off and start talking about the Black book. All of the information that goes with this episode can be found in in the description box.
- [47:58]
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