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The Epstein Chronicles
Mega Edition: Virginia Roberts Responds To Maxwell's Summary Judgement Request (Part 7-9) (6/7/26)
00:43:06
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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- [00:01]
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- [01:31]
Legal Analyst
What's up everyone and welcome back to the Epstein Chronicles. In this episode, we're going to continue talking about the Virginia Roberts response to Ghislaine Maxwell's attempt to get a summary judgment. 3. Defendant cannot invoke the pre litigation privilege because she has no claim for good faith litigation. Finally, Defendant cannot prevail in asserting this qualified privilege because because in order to invoke this privilege, she must have a meritus claim for good faith anticipated litigation. Khalil specifically states that for the qualified privilege to apply, the statements must be made pertinent to a good faith anticipated litigation and it does not protect attorneys asserting wholly unmerited claims unsupported in law and fact in violation of counsel's ethical obligations. Khalil, 24 NY3D at 7, 18, 720. Defendant has neither emeritus claim nor good faith anticipated litigation. Defendant cannot have a Meredith's claim for good faith anticipation litigation against the Press or Ms. Roberts because Ms. Roberts reports of her sexual abuse are true. Defendant knows that they are true and Defendant made a knowingly false statement or when she called Ms. Roberts a liar. Under these circumstances Defendant has no claim to make in good faith relating to either Ms. Roberts statements or their coverage in the press, thereby making her defamatory statements wholly outside the protection of this qualified privilege. At the very least, the issue of whether Defendant has claims against the press on the grounds that she did not abuse Ms. Roberts is a question of fact for the jury to to decide. 5. Defendant has not and cannot show that her defamatory statement is substantially true. Defendants next claims that her press release calling Ms. Roberts a liar about her past sex abuse was somehow substantially true. Here again, this is a highly disputed claim on its face. To determine whether it's substantially true or not requires extensive fact finding, such as whether a defendant recruited Ms. Roberts and as a minor child for sex with Defendants live in boyfriend and convicted pedophile Jeffrey Epstein. Accordingly, summary judgment is not appropriate. See Mitra Sports International Limited versus Home Box Office, Inc. 22 F. Supp. 3d 240, 255 SDNY 2014 denying summary judgment because it would require the court to decide disputed facts and to determine whether the statement at issue was substantially True. Da Silva vs. Time, Inc. 908 F. 184, 187 SDNY 1995 denying motion for summary judgment because there was a genuine issue of material act as to whether defamatory photo and caption were not true. Stating in the instant case of Da Silva's contention that she was a reformed prostitute at the time of photography and publication provides a rational basis upon which a fact finder could conclude that the photograph was not substantially true. Additionally, Defendant has remarkably not submitted any evidence that she did not recruit Ms. Roberts for sex with Epstein. Nora's defendant offered any evidence that her role in Epstein's household was not to recruit girls and young women for Jeffrey Epstein. Accordingly, summary judgment is inappropriate. See Stern v. Cosby, 645 F.2d 258, 277 SDNY 2009. Because defendant had not submitted any evidence to show that statement 11 is substantially true, her motion for summary judgment as to statement 11 is denied. Further, much of the purported evidence upon which Defendant relies on to allege the truth of her defamatory statement is merely hearsay, including inadmissible hearsay statements made by Alan Dershowitz, who Defendant did not depose in this case and whom Ms. Roberts has not had the opportunity to cross examine. Hearsay cannot establish the truth of a defamatory statement as a matter of law at summary judgment. Lopez v. Univision Communications, Inc. 45 F.2d 348. 359SDNY 1999. Denying summary judgment and holding Defendant's evidence as to what they were told by representatives of NYU and Keene College to the extent offered for the truth of the matters asserted is admissible hearsay and an insufficient basis upon which to grant summary judgment of dismissal on the grounds that the statements were substantially true. Finally, many of the facts upon which Defendant bases her argument that her defamatory statement was true are wholly claims made against Ms. Roberts and the defamatory statement for example, defendant supports her contention that she did not recruit Ms. Roberts for sex with Epstein based on the fact that Ms. Roberts lived independently of her parents before meeting Epstein and Maxwell. Of course, the child outside the supervision of of her parents makes it much more likely she would be recruited by Defendant into sex trafficking. But that is for the jury to decide. The fact does not go to whether or not the defendant's statement calling Ms. Roberts a liar is true because Ms. Roberts never made any claims relating to where she lived prior to meeting Defendant. Moreover, it is immaterial with whom she was living. The fundamental and overarching fact remains that defendant recruited Ms. Roberts for sex with Epstein when she was a minor child. Defendant next proffers Ms. Roberts Limited high school enrollment and short term jobs that she held as evidence that she and Epstein did not abuse her. The logic of this position is unclear. The fact that Ms. Roberts worked at Taco Bell for a few days hardly establishes she was not abused by Defendant and Epstein. Indeed, if anything, even it shows the vulnerability of Ms. Roberts to enticements that a billionaire and his wealthy and powerful girlfriend could offer. In any event, what to make of such fact is something for the jury to consider. They are irrelevant. For the same reason as above, Ms. Roberts never made any claims about her studies or her prior employment. Indeed, neither Ms. Roberts statement about being recruited by Defendant as a child nor Defendants refushen even mentions Ms. Roberts lack of schooling or lack of a stable home as a child purported facts that have nothing to do with Ms. Roberts claims of sexual abuse against the defendant and nothing to do with the defendant calling Ms. Roberts a liar for such claims, and they do not establish the substantial truth of the Defendant's statement. Tellingly, Defendant cites to no case in any jurisdiction that even suggests otherwise. 6 Plaintiff does not need to establish malice for her defamation claim, but in the event the court rules otherwise, there is more than sufficient record evidence for a reasonable jury to determine Defendant acted with actual malice. Defendant's next and again quite remarkable argument is that Ms. Roberts somehow will be unable to establish actual malice in this case, one would think that a sex trafficker calling one of her victims a liar would be a quintessential example of actual malice. Defendant's spurious case citations and misplaced argument do not detract from this core fact. Though Defendant does not mention the legal standard for actual malice until she is 48 pages into her 68 page brief, the legal definition of actual malice as defined by the United States Supreme Court and reiterated by the 2nd Circuit should be the light by which all of Defendants purported facts and argument should be viewed. Actual malice means that a statement was published with knowledge and the statement was false or with reckless disregard of whether it was false or not. By vs. Disson, 607 F. Appx. 1820 Second Circuit, 2015 quoting New York Times Co. Vs. Sullivan, 376 U.S. 254, 280. 84 Supreme Court, 11 L. Ed.2d 686, 1964. Defendant argues that Ms. Roberts is a limited purpose public figure while Ms. Roberts disputes that claim. The issue is entirely irrelevant here because Ms. Roberts will prove at trial with overwhelming evidence that Defendant made her statement calling Ms. Roberts a liar with malice, fully knowing as a sex trafficker that that it was false. Put another way, defendant knew that Ms. Roberts was telling the truth when she described how Defendant recruited her for sex as an underage girl and then sexually trafficked her with her then boyfriend, Jeffrey Epstein. The Second Circuit instructs that on a motion for summary judgment, a court cannot try issues of fact. It can only determine whether there are issues to be tried. If, as to the issue on which summary judgment is sought, there is any evidence in the record from any source from which a reasonable inference could be drawn in favor of the non moving party, summary judgment is improper. Chambers vs. TRM Copy Centers Corporation, 43 F.3d 29, 37 Second Circuit, 1994. As the moving party, Defendants have the burden of demonstrating an absence of clear and and convincing evidence substantiating Plaintiff's claims. Desall v. Knoedler Gallery, LLC, 139 F. Supp. 3d 618, 640 SDNY 2015 citing Chambers, defendant fails to meet her burden of demonstrating an absence of clear and convincing evidence substantiating, Ms. Roberts claims that defendant acted with actual malice. Ms. Ms. Roberts will easily be able to meet any trial burden of clear and convincing evidence of actual malice. Tellingly, Defendant does not even attempt to address the documentary evidence nor the testimonial evidence showing she was a recruiter of girls for Epstein. As shown above, far beyond showing that a reasonable inference could be drawn in her favor, which is all that is required at this point to defeat defendant's motion, Ms. Roberts will easily be able to meet her trial burden of clear and convincing evidence of actual malice. Of course, a plaintiff need only show actual malice on the part of a defendant if that plaintiff is a public figure or a limited public figure, which Ms. Roberts is not, as explained infra. Alright, we're gonna wrap up right there and in the next episode, we're gonna pick up where we left off with Part seven. The court need not reach the issue at this time of whether Ms. Roberts is a limited purpose public figure. 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 gonna pick up where we left off with Virginia Roberts and her response to Ghislaine Maxwell's attempt to get a summary judgment. So. So let's dive right back in. The court need not reach the issue at this time of whether Ms. Roberts is a limited purpose public figure. For the reasons just explained, Ms. Roberts will easily be able to prove actual malice at the trial. In this case, defendant argues that Ms. Roberts is a public figure who must prove actual malice.msj 49. Given the overwhelming proof of of the second part of the statement, the court need not spend time considering the first. If the court wishes to nonetheless consider the issue at this time, it is not appropriate for disposition. At the summary judgment stage of the case, the defendant bears the burden of demonstrating that the plaintiff is a limited purpose public figure. C. Lerman v. Flint Distribution Co. 745 F.2d 123, 136 through 137, 2nd Circuit 1984.
- [13:57]
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- [14:20]
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- [14:27]
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- [15:29]
Legal Analyst
articulates the legal test for finding that a plaintiff is a limited purpose public figure, but glosses over the fact that all prongs of the test must be met in order for a court to make that finding. CEG Contemporary Mission, Inc. Vs. New York Times Co. 842 F.2d 612, 617 Second Circuit, 1988. This court set forth a four part test for determining whether someone is a limited purpose public figure. Herbert v. Lando, 596 F. Supp. 1178, 1186 S.D.N.Y. 1984. The Second Circuit recently summarized the criteria Affidavit in part, Revised in Part 781 F.2d 298 2nd Circuit 1986 Nels v. Hillsdale College, 178 F. Supp. 2d 771, 778 E. D. Michigan, 2001 finding plaintiff was not a limited public figure for failing one element of the Lerman test and thus denying Defendant's motion for a summary judgment, the defendant has proven all of the elements but the third affidavit at 65F. Appendix 984, 6th Circuit, 2003. Of course, proof that Ms. Roberts or anyone else is a limited purpose public figure requires proof of a set of facts from which Ms. Roberts believes defendant has not shown in satisfaction of the four part test. Significantly, this court should pause here to note that the details of Jane Doe no. 3's sexual exploitation and abuse as anonymously set forth in her CVRA joinder motion, caused the defendant to identify with Certainty Jane Doe no. 3 as Ms. Roberts. Yet at her deposition, defendant claimed to barely remember her at all. Defendant's ability to immediately and positively identify the anonymous individual making claims of sexual abuse, if anything, shows the defendant was intimately aware of Ms. Roberts sexual exploitation and to be sure, Ms. Roberts never asked to be sexually abused or trafficked by defendant or the convicted pedophile Jeffrey Epstein when she was a child. Legally, she did not even have the capacity to consent. Defendant cannot recruit a minor child for sexual exploitation and then afterwards argue that her victim is injected herself into the public controversy when coming forward about the abuse that she has suffered. Moreover, the defendant has not made a sufficient showing that Ms. Roberts has regular and continuing access to the news media. The policy rationale behind this prong is that the public figures generally enjoy significant access to the media. One reporter wrote some articles on Ms. Roberts in 2011. Thereafter, it was not until 2015 that Ms. Roberts spoke to someone in the news about these issues and that the interview was granted after the defendant's defamatory remarks. Such limited contacts precludes the finding that Ms. Roberts is a limited public figure. See Hutchinson v. Proxmire, 443 U.S. 111, 99 Supreme Court 2675, 61 L. Ed. 2d 411, 1979, finding plaintiff maintained no regular and continuing access to the media and thus was not a public figure. It is also unclear how Defendant plans to show that Ms. Roberts successfully invited public attention to her views. To be sure, Ms. Roberts decided to start Victims Refused Silence, a not for profit organization whose mission is to change the landscape of the war on sexual abuse and human trafficking. Our goal is to undertake an instrumental role in helping survivors break the silence associated with sexual abuse. To fulfill this mission, we aim to enhance the lives of women who have been victimized. The website lists the National Trafficking Hotline and provides a state by state resource for local organizations where victims can seek help. Unsurprisingly, Defendant cites no cases that hold that maintaining a website makes one a public figure. See Mitra Sports International Ltd. V. Home Box Office, Inc. 22 F. Supp. 3d 240, 252 SDNY 2014, finding plaintiff was not a limited public figure and denying Defendant's motion for summary judgment. Corporate policy denouncing child labor on its website does not show that mitray aimed to influence the public's views on the controversy. More important, Defendant does not explain how Ms. Roberts was using the website to influence public views on whether she had been abused by Defendant, the subject at issue in this lawsuit. Interestingly, defendant has spent $17,875.49 on an expert witness to tell the court and the jury that hardly anyone searches on the Internet using search terms such as victims refuse, silence, sex slave. One of the defendants six briefs raising Daubert issues specifically argues that Dr. Anderson estimates on the cost of remediating Ms. Roberts online reputation are improper because Dr. Anderson included nearly unused search phrases when evaluating Internet content. Ken Rebuttal report states, there seems no reason to believe that such a person would use this item. Indeed, these are terms unlikely to be used by anyone unfamiliar with this litigation. Why, for instance, would it be necessary to push down offending webpages in the results that the search engines provide for the term Victims refuse silence sex slave when this term is likely Never used? C. McCauley Declaration at Exhibit 25 can report at 10 and 33. Defendant cannot argue to the court that Ms. Roberts has successfully invited public attention to her views through her VRs website while simultaneously filing a Daubert motion that argues the search terms such as victims refused silence sex slave are likely never used, thus making the website unsuccessful and inviting public attention. In any event, Defendant has failed to set forth with precision the allegedly undisputed fact and supporting evidence she uses to support her argument. Moreover, it is preferable to reduce the public figure question to a more meaningful context by looking to the nature and extent of an individual's participation in the particular controversy giving rise to the Defamation Greenberg v. CBS, Inc. 69 A. D. Dot.2d 693, 704, 419 N.Y.S.2d 988, 995, 1979 citing Gertz v. Robert Welch, Incorporated, 418 U.S. 323, 345, 352. 94 Supreme Court 29, 97, 41 L. Ed.2d 789. The context here is highly significant. Ms. Roberts never chose to participate in Defendant and Epstein's underage sex ring, a controversy that gave rise to Defendant's defamation. In arguing that Ms. Roberts thrust herself into the public spotlight, Defendant conveniently leaves out the fact that it is by her doing that Ms. Roberts is in this controversy in the first place. No minor child willingly becomes a participant in sexual abuse, and it is perverse for the abuser to argue that that her victim deliberately became a subject of public attention when speaking out about that abuse for the purpose of advancing justice and helping other victims. For all these reasons, the Court should simply decline to decide the public figure issue at this juncture. But if it chooses to reach the issue, it should reject defendant's unsupported argument. Section 8 the January 2015 statement was not substantially true, and Ms. Roberts has produced clear and convincing evidence of its falsity. As a final argument, Defendant argues that her January 2015 statement was substantially true. Given that the statement argues that Ms. Roberts lied when she said she was sexually trafficked by the defendant. The reader of Defendant's motion might reasonably expect to see some evidence presented showing that Defendant was not a sex trafficker. Instead, the reader is treated to technical quibbles. For example, the lead argument shows the substantial truth of Defendant's statement is the argument that Ms. Roberts was not 15 years old, but all of 16 or 17 years old when she was trafficked. As the court knows and can take judicial notice of, Florida law makes age 18 the age of consent. Accordingly, it is no moment that that Ms. Roberts may have been mistaken about the exact year the sex trafficking started. Call this the yes, I'm a sex trafficker but only of 16 year old girls defense. To even describe the defense is to show how meritless it is. More broadly at issue are the statements Ms. Roberts made regarding Defendants involvement in and knowledge of the sexual abuse and sex trafficking of Ms. Roberts and other minor girls through a recruitment scheme executed by Defendant and Jeffrey Epstein. In response to those various statements, Defendant publicly claimed that the allegations made by Ms. Roberts against Ghislaine Maxwell are untrue. Defendant continued that Ms. Roberts claims are obvious lies and should be treated as such. Defendant, through her statement intended to convey that Ms. Roberts was lying about everything she had said against Defendant in the allegations. In sum, in essence, those statements made by Ms. Roberts, about which Defendant released a public statement to exclaim, were untrue and obvious lies. 1. The defendant approached Ms. Roberts while Ms. Roberts was an underage minor working at Mar A Lago Country Club and recruited the then minor, Ms. Roberts to the house of Jeffrey Epstein under the pretense of providing a massage to Jeffrey Epstein for money. 2. That Ms. Roberts followed defendant's instructions and was driven to Jeffrey Epstein's house where she was greeted by Defendant and later introduced to Jeffrey Epstein. 3. That Ms. Roberts was led upstairs to be introduced to Jeffrey Epstein in his bedroom and while there, defendant demonstrated how Ms. Roberts should provide a massage to Jeffrey Epstein. 4. Defendant and Epstein converted the massage into a sexual experience, requesting that Ms. Roberts remove her clothing, after which time a sexual encounter was had. 5. The defendant and Epstein expressed approval for Ms. Roberts and offered her money in exchange for this erotic massage turned full sexual encounter. 6. The defendant and Epstein offered Ms. Roberts the promise of money and a better life in exchange for Ms. Roberts acting sexually compliant and subservient to their demands. 7. That Ms. Roberts, after that first sexual encounter, was repeatedly requested to serve as Epstein and or Defendant sexually and or others. 8. That Ms. Roberts was taken on Epstein's private planes on numerous occasions and trafficked nationally and internationally for the purpose of servicing Epstein and others, including the defendant, sexually. 9. The defendant was Epstein's primary manager of the recruitment and training of females who Epstein paid for sexual purposes. 10 defendant participated in sexual encounters with females, including Ms. Roberts, and 11 that Ms. Roberts and other recruited females were encouraged by Defendant N. Epstein to bring other young females to Epstein for the purpose of servicing him sexually. Defendant, by way of her January 2015 statement, declared that Ms. Roberts lied about each and every one of these allegations regarding the defendant. In fact, Defendant clarified further this position in her deposition when she said repeatedly that everything Ms. Roberts said about Defendant was totally false.
- [28:04]
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- [28:23]
Legal Analyst
Q U-T.com Spinquest is a free to play social casino. Void where prohibited. Visit spinquest.com for more details. The clarification in her deposition is identical in intention to the reasonable interpretation of her statement that Defendant made publicly, which has formed the basis of this defamation action that Ms. Roberts was lying about everything she said about the defendant and that the defendant was not at all involved in this activity that she is accused and engaging in. While her public statement could not have been more clear as her deposition testimony further underscored, Defendant intended the world to believe that nothing Ms. Roberts said about the defendant was true and that the defendant was not at all involved with any of the things she was accused of. Defendant has decided in this motion to minutely dissect the nuance of Ms. Roberts various statements to cause the court to reach a far fetched conclusion. The defendant insidiously false statement was somehow substantially true. Ironically, this repositioning amounts to nothing more than an admission by the defendant of the defamatory nature of her statement. Alright folks, we're going to wrap up right there and in the next episode 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 picking up where we left off with the Virginia Roberts response to Ghislaine Maxwell's attempt to get a summary judgment. A When Ms. Roberts initially described her encounters with the defendant and Epstein. She mistakenly believed the first encounter occurred during the year 1999. Discovery has resulted in the production of records, including Ms. Roberts employment records from Mar a Lago which she did not possess at the time she was recounting her interactions with the defendant. Those records establish that the initial encounter wherein defendant recruited Ms. Roberts occurred during the year 2000 and not 1999. Ms. Roberts was 16 years old before August 9, 2000 and turned 17 on that date. It is unclear from the limited records available whether the Defendant approached and recruited Ms. Roberts before or just after Roberts 17th birthday. However, what has now been established through numerous witnesses is that Defendant approached and recruited a minor child for the purposes of enticing that minor over to the house of Jeffrey Epstein, a currently registered sex offender. The exact lure of Ms. Roberts by defendant enticement of being paid money to give a billionaire a massage at his mansion was used by Epstein and his many associates and employees to recruit dozens and dozens of of other underage girls. There is no doubt that the crux of Ms. Roberts statements on this point is that the Defendant recruited her when she was only a minor child unable to consent to sex, not precisely how far under the age of consent she was. Defendant's public claim that Ms. Roberts account of this approach and recruitment element was untrue and obvious lies is not substantially true, but is itself an obvious lie as Ms. Roberts will prove to the jury at trial. Defendant's January 2015 statement claiming as untrue and an obvious lie the allegation that she regularly participated in Epstein's sexual exploitation of minors and that the government knows such fact is not substantially true but instead completely false. Defendant next argues that she accurately denied that she regularly participated in Epstein's sexual exploitation on minors and that the government knows such as a fact. It's not clear whether Defendant is nitpicking this statement by contesting whether she regularly participated in Epstein's sexual exploitation or whether she did participate but the government was unaware of the extent of her involvement. Call this the yes, I'm a sex trafficker, but only on Tuesday's and Thursday's defense. Here again, to simply recount the claim is to see its absurdity contrary to Defendant's misleading, cherry picked fragments of information that she has chosen to use to support her point. There is an abundance of evidence clearly linking Defendant to Epstein's sexual exploitation of minors. As the court is aware, numerous message pads were recovered from Epstein's home indicating Defendant's involvement in and knowledge of Epstein's illegal exploitation. Additionally, numerous employees and others have testified about Defendants high ranking position in the hierarchical structure of the sexual exploitation scheme. In fact, multiple individuals in addition to Ms. Roberts have testified about Maxwell's involvement in the exploitation of minors, including Ms. Roberts. Defendant also argues that one government investigator, Palm Beach, Florida Detective Ricari may not have been aware of her involvement in the sex trafficking. Defendant fails to cite another passage in Detective Ricari's deposition where he noted that he was aware of Defendant's involvement with Epstein and the sexual exploitation of children. But even assuming Recari was unaware, which Ms. Roberts strongly disputes, Defendant would have at most a yes, I'm a sex trafficker but I successfully hid it from one of the cops defense. Again, not a likely claim. More broadly, Ms. Roberts statement about what the government knew about sex trafficking was made in pleadings filed in a federal court case attacking the decision of the U.S. attorney's Office for the Southern District of Florida to offer Jeffrey Epstein immunity from prosecution for federal sex trafficking crimes. Accordingly, to present an even arguable claim for summary judgment, Defendant would have to show that the U.S. attorney's office and its investigators from the FBI did not know about defendant sex trafficking. This proof would need to include, for example, evidence that the FBI did not learn about defendant sex trafficking when, among other things, Ms. Roberts told FBI agents about it when she met them in Australia and in 2011. Here again, the defendant has no evidence to even begin making such a showing. C. Defendant's January 2015 statement claiming as untrue or an obvious lie that Maxwell And Epstein converted Ms. Roberts into a sexual slave is not substantially true. Defendant next argues that she accurately disputed Ms. Roberts statement that the defendant held her as a sex slave, relying on dictionary definitions of slave that define the term to refer to a confined person who is the legal property of another. MSJ at 59, citing Merriam Webster, etc. Defendant claims Ms. Roberts was not confined to the property of the defendant. Call this the yes, I'm a sex trafficker, but I didn't use chains defense. And once again, to even describe the defense is to refute it. Defendant does not explain why the jury would be required to use the held in chains definition of slave in evaluating her statement Merriam Webster, 11th edition, 2006. It also defines slave as one that is completely subservient to a dominating influence, a definition that fits Ms. Roberts circumstances to a T. As Ms. Roberts has explained in detail, she was recruited as a minor child by the defendant who then dominated her and used her for sexual purposes. That testimony alone creates a genuine issue of fact on this point, from the context of all of Ms. Roberts statements about the defendant, Ms. Roberts has never said or implied that she was physically placed in a cage. Instead, she has described the vast disparity of power and the influence of Defendant and Epstein, the fear of disobedience, the typical locations of the abuse being in a private plane, a huge mansion man with Epstein's employed servants, a private island or some inescapable place abroad in the presence of the defendant, in addition to the continued and fraudulent promise of a better future, as those things that kept her retained in a situation of sexual servitude while not physical chains, Ms. Roberts was groomed as a minor and trained as and these factors became her invisible chains. Indeed, as Ms. Roberts, expert on sex trafficking Professor Coonan, has explained, popular understanding of the term sex slave might still connote images of violent pimps, white slavery, or of victims chained 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 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 McAuley Declaration at Exhibit 23 Koonin Expert Report at 20. If this Court takes as true, which it must for the purpose of this motion, that Ms. Roberts was trafficked and used exclusively for sexual purposes by the Defendant and Epstein, then the court must also reach the conclusion at this stage that Maxwell's assertion that Ms. Roberts description of being a sex slave is untrue or obvious lies is not substantially true. There undoubtedly remains a genuine issue of material fact on this point and in fact, Defendant's position taken in this motion is tantamount to an admission of the truth of Plaintiff's statement about Defendant on this point, any statement misdirection regarding Professor Alan Dershowitz is nothing more than an irrelevant distraction to the facts of this case and matters not on the defense of whether Defendant's statement was substantially true. Defendant next contends that she accurately recounted that Alan Dershowitz had denied having sex with Ms. Roberts. MSJ at 60 call this the yes, I'm a sex trafficker, but she was not trafficked to the professor defense. While it is accurate that Ms. Roberts made allegations against Professor Dershowitz, those allegations are not at issue in this case. Defendant in her defamatory statement claimed that the allegations made by Ms. Roberts against Ghislaine Maxwell are untrue. See McAuley Declaration at Exhibit 26 GM 00068 in her deposition, defendant maintained the position that she cannot speculate on what anybody else did or didn't do. Declaration at Exhibit 11 Maxwell 422 2016. In fact, regarding Ms. Roberts claims about others, Defendant unequivocally stated, I can only testify to what she said about me, which was 100% false. See McCauley Declaration at 11. Defendant Maxwell makes additional misstatements about Dershowitz production in a defamation action filed against him in her desperate attempt to have Dershowitz jump aboard and help bail out her sinking canoe. Ms. Roberts can and if necessary, will refute Dershowitz claim he was not a beneficiary of Epstein and Defendant sex trafficking. That is not relevant at this stage. Whatever may or may not have happened with Dershowitz and Ms. Roberts sworn statement that he sexually abused her is alone enough to create disputed facts on the issue of whether Defendant's statements about him are substantially true has no bearing whatsoever on the truth or falsity of the statements Ms. Roberts made about the defendant. This case is not about whether Ms. Roberts has ever made untruthful allegations against anyone, which she contends she is not, but about whether her allegations about Defendant were true or whether those specific allegations were untrue. Obvious lies as Defendant publicly proclaimed. These issues are disputed and must go to the jury. E. Contrary to the Defendant's position, there is a genuine issue of material fact as to whether she created or distributed child pornography or or whether the government was aware of the same. Defendant next argues that she did not create child pornography and that the government knew this. Call this the until you find the photos, I'm innocent defense. Of course, as noted earlier, Defendant's claim requires that she show the government in context. The FBI and the U.S. attorney's office for the Southern District of Florida knew that she had no child pornography. Yet Defendant has offered no such evidence, much less evidence so powerful as to warrant summary judgment on this point. This point is disputed from the simple fact that Ms. Roberts herself testified that Defendant took many photographs of her naked see McCauley Declaration at Exhibit 5, Roberts deposition at 232-392-3379. This is consistent with with the Palm beach butler Alfredo Rodriguez testimony that he personally saw photos of naked children on the defendant's computer. See McAuley Declaration at Exhibit 21 Rodriguez deposition at 150, 1017, 306, 1306 and 24. Another housekeeper, Wanalesi, also saw photos of young nude females on the defendant's computer, although he wasn't aware or sure whether to consider it pornography. See McCauley Declaration at Exhibit 1. Finally, Detective Riccari found a collage of nude photos of young females in Epstein's closet and turned the photos over to the FBI and the U.S. attorney's Office. While the U.S. attorney's office will not share the photos obtained from Recari's investigation, it is thus undisputed that the government possesses photos of nude young females confiscated from Epstein's Palm beach mansion. Indeed, the police video disclosed through a Freedom of Information request shows naked images of women throughout the house, including a full nude of the defendant. At a minimum, there is a clear, genuine issue of material fact in this regard.
- [42:59]
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- [43:23]
Legal Analyst
to play social casino void where prohibited. Visit spinquest.com for more details. F Defendant did act as a Madam for Epstein to traffic Ms. Roberts to the rich and the famous. Defendant next argues that she did not act as a Madam for Epstein. MSJ at 63 the gist of the argument seems to be that the Defendant believes trafficking one girl to Epstein does not a Madam make. Call this Yes, I was Virginia's Madam, but no one else's defense. This argument fails linguistically on the very dictionary definitions that Defendant cites elsewhere, but not here. See Merriam Webster, 11th edition, 2006 defining madam as the female head of prostitution. Once again, Defendant conceals the relevant facts on this issue. First, multiple witnesses have testified to Defendants recruiting, maintaining, harboring and trafficking girls for Epstein. In fact, Defendant herself was unable to deny procuring Ms. Roberts for Epstein. While Defendant has attempted to fumble her way through explaining some plausible reason for bringing a 16 or 17 year old to Epstein, her explanations are, to put it blandly, unpersuasive. As with other issues, the jury will have to decide who to believe. One of the individuals Ms. Roberts was trafficked to was Prince Andrew trafficking that took place in the Defendant's own townhouse in London. There exist flight logs evidencing Ms. Roberts flying to London alongside Defendant and Epstein on Epstein's private plane and the photo of Ms. Roberts, defendant and the Prince without Defendant ever offering a legal, reasonable explanation for that photo being taken or for traveling with a year old girl overseas. Defendant begins to meander somewhat aimlessly on this point, shifting Plaintiff's burden to substantiate Plaintiff's claim that Defendant was Epstein's Madam, which at this point at issue into whether or not Plaintiff has conclusively proven the identities and accurate job titles of the other men to whom Plaintiff was lent for sex by Epstein. No matter how hard Defendant tries to reframe the case, drag other people in or split hairs, she is unable to contest the facts. Facts showing she was more than a Madam but a full fledged sex trafficker. Ms. Roberts told the truth when she said the Defendant recruited her as a minor under the pretense of giving her a massage and converted her into a traveling sex slave, consistent with Defendant and Epstein's pattern of practice. As the Court astutely acknowledged early on, at the center of this case is the veracity of a contextual world of facts more broad than the allegedly defamatory statements. Either transgressions occurred or it did not. Either Maxwell was involved or she was not. If Defendant was involved, then her January 2015 statement was defamatory. Ms. Roberts will prove to the jury through overwhelming evidence, her prior allegations about Defendant's involvement. The court should give Ms. Roberts that opportunity and deny the Defendant's motion for summary judgment. For the foregoing reasons, this Court should deny Defendant's motion for summary judgment in all respects. This was signed by Sigrid McCauley and it was dated January 31, 2017. Alright folks, that's going to conclude our look at Virginia Roberts response to Ghislaine Maxwell's attempt to get a summary judgment. And if you're not disgusted yet, just wait. Plenty more is on the way. All of the information that goes with this episode can be found in the Description box.
- [47:08]
Bluff
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- [47:31]
Legal Analyst
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