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Speaker 1: What's up, everyone, and welcome back to the Epstein Chronicles.

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In this episode, we're going to pick right back up

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where we left off with the Southern District of New

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York Local Rule fifty six point one, Plaintiff's Statement of

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contested facts and Plaintiff's undisputed Facts Number nineteen. Among the

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media representatives were Martin Robinson of The Daily Mail, Ppeach

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of The Independent, Nick Summerland of The Mirror, David Brown

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of The Times, and Nick Always and Joanne Pew of

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the BBC, and David Mercer of the Press Association. These

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representatives were selected based on their request after the joinder

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motion was filed for a response from Miss Maxwell to

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Miss roberts allegations. In the motion miss Robert's statement controverting

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defendant facts. Miss Roberts agrees to the first sentence. The

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second sentence is a false. Accordingly, there is no record

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evidence that gu or anyone else selected journalists for a response,

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or that there was any selection process whatsoever. To the

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country testified that anyone who inquired received a reference to

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the January twenty fifteen tofamatory response question to the extent

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you can recall or could estimate how many other emails.

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Do you believe you sent bearing that statement that's in

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Exhibit two. Answer, I really can't remember, but certainly more

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than six and probably less than thirty somewhere in between.

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Anytime there was an incoming query, it was either dealt

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with on the telephone by referring them back to the

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two statements of March twenty eleven and January twenty fifteen,

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or someone would email them the statement, so no one

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was left unanswered. Broadly, is the is where we were,

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but I can't remember every single person reached out to

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see McCaulay declaration at Exhibit six Defendants Purported Facts twenty.

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The email to the media members said, to whom it

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may concern, please find attached a quotable statement on behalf

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of Miss Maxwell. No further communication will be provided by

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her on this matter. Thanks for your understanding. Best Ross.

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Chained three is Virginia Roberts, so not a new individual.

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The allegations made by Victoria Roberts against Glenn Maxwell are untrue.

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The original allegations are not new and have been fully

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responded to and shown to be untrue. Each time the

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story is retold, it changes with new saalacious details about

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public figures and world leaders, and now it is alleged

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by Miss Roberts that Alan Dershowitz is involved in having

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sexual relations with her, which he denies. Miss roberts claims

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are obvious lies and should be treated as such and

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not publicized as news as they are defamatory. Glenn Maxwell's

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original response to the lies and defamatory claims remains the same.

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Maxwell strongly denies allegations of an unsavory nature which have

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appeared in the British press and elsewhere, and reserves her

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right to seek redress at the repetition of such old

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defamatory claim. James miss Robert's statement controverting defendance facts. While

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defendant cropped the body text of the email that was

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sent to the news media representatives, she completely omitted the

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headings and metadata. Miss Roberts has put an image of

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the email below in Miss Roberts paragraph CGM zero zero

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six eight Defendants purported facts twenty one. Mister Barden, who

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prepared the January twenty fifteen statement, did not intend it

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as a traditional press release solely to disseminate information to

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the media, so he intentionally did not pass it through

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a public relations firm such as mister Gales's firm Acuity Reputation.

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Miss Robert's statement controverting the defendants facts. Defendant states mister Barden,

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who prepared the statement, did not intend it as a

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traditional press release solely to dissemination information to the media.

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Miss Roberts contests this statement and all statements regarding mister

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Barden's beliefs and purposes and the like. Further, as stated

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in detail in Miss Roberts's opposition Defendant's motion for summary judgment,

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this court should not even consider the Bardon declaration. Additionally,

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there is absolutely no record evidence of Bardon's intent and

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the court should not consider it. The next sentence states,

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so he intentionally did not pass it the press release

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through a public relations firm such as mister Gales's firm

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Acuity Reputation. Again, there is zero record evidence to support

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any assertion of mister Barden's intent. To the extent that

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the sentence claims that Barton did not give the statement

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to Gal with instructions to publish it see McCauley declaration

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at Exhibit forty eight. To the extent that this sentence

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claims that the statement did not pass through a public

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relations firm, such as mister Gales's firm acuity reputation. Miss

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Roberts disputes that statement record, documentary evidence, and testimony established

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that this statement was disseminated through a public relations firm,

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namely Ross Gal's firm acuity reputation CE McCauley declaration at

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Exhibit six the defendants purported facts. The January twenty fifteen

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statement served two purposes. First, mister Bardon intended that it

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mitigate the harm to Miss Maxwell's reputation from the press

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republication of Miss Robert's false allegations. He believed these ends

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could be accomplished by suggesting to the media that, among

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other things, they should subject Miss roberts allegations to inquiry

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and scrutiny. For example, he noted in the statement that

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Miss Roberts's allegations changed dramatically over time, suggesting that they

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are obvious lies and therefore should not be publicized as news.

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Miss Robert's statement controverting defendant's facts. Miss Roberts subjects to

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this paragraph in its entirety. She disputes that the January

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twenty fifteen statement served two purposes, as this statement is

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wholly unsupported by the record, which defendant again neglects to site.

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Miss Roberts also contests the second sentence in which defendant

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colsis that mister Barton intended that it mitigate the harm

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to Miss Maxwell's reputation from the press republication of Miss

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roberts false allegations. First, Miss Roberts disputes any statement of

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Barton's intent as explained above. Second, Miss Roberts disputes that

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there was any republication by the press as a matter

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of law, as explained in our memorandum of law, opposing

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some rejudgment as the press did not republish the press

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statement under New York law. Third, Miss Roberts disputes that

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our allegations are false. Incites to the following non exhaustive

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sampling of evidence to corroborate our allegations against the defendant.

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See McAuley declaration Exhibit sixteen, McCauley declaration Exhibit four, McAuley

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declaration Exhibit fourteen, McCauley declaration, Exhibit twelve, McCauley declaration, Exhibit thirteen,

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McAuley declaration Exhibit fifteen. The excerpt of the Rogers deposition

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Sea McAuley declaration at Exhibit ten from Marsen Cova Cee

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McCauley declaration at eight for Kellen Cee McCauley declaration Exhibit

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one for Alessi Cee McCauley declaration at Exhibit forty two

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for photographs McCauley at thirty for US victim notification letter,

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McCauley at thirty three. For New York Presbyterian Hospital records,

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McCauley at thirty eight for Judith Lightfoot McCauley at thirty

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at twenty eight for message pads McAuley at twenty nine

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for the Black Book, McCauley at forty for sex slave books,

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McCauley at thirty two for the folder defendant sent to Thailand,

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McCauley at thirty nine for the Palm Beach police report

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McCauley at forty one for Epstein's flight logs. Next defendant

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states he Barton believes the's ends could be accomplished by

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suggesting to the media that, among other things, they should

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subject Miss Roberts' allegations to inquiry and scrutiny. Miss Roberts

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disputes any statements as to Barton's belief. Supra Miss Roberts

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disputes that any harm to Defender's reputation could be mitigated

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by the media's inquiry into the scrutiny of Miss Robert's allegations,

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because a deeper inquiry would only reveal additional evidence corroborating

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Miss Roberts's allegations, such as the evidence put forth in

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Miss Robert's opposition memorandum of law and detailed in the

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bulleted citation. Supra Defendant then states, for example, he Barden

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noted in the statement that Miss Roberts's allegations changed dramatically

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over time, suggesting that their obvious lies and therefore should

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not be publicized as news. First, Miss Roberts disputes that

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Barden noted anything in the statement, as that is unsubstantiated

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by the record. Evidence not to do Defendant's work for her.

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But the closest evidence Defendant has for such a statement

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his testimony from the Gou deposition, wherein gu speculates that

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Barton had a hand in drafting the press statement, an

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opinion which may or may not be based on first

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hand knowledge. See McCaulay declaration at six, Gou Deposition at

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forty five fourteen through seventeen. Question Okay and I say

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thanks Philip, because I'm aware of the fact that he

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had a hand, a considerable hand, in the drafting. This

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is wholly insufficient to show who drafted the passages quoted

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by defendant above. Regardless of those passages original author, it

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is ultimately defendant who noted anything, because it is her statement,

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and she directed that it be sent to the media

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and the public. Second, Miss Roberts disputes that our allegations

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have changed over time, dramatically or otherwise. Third Miss Roberts

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disputes that the press release suggested that our allegations are

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obvious lies. Because defendant's press release affirmatively, unambiguously stated that

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her allegations are obvious lies, there's no subtlety suggestion or

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a statement of opinion here. See Roberts versus Maxwell, one

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sixty five f supp Dot three D one for seven

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T two SDNY, twenty sixteen. These statements, as they themselves allege,

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are capable of being proven true or false, and therefore

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constitute actionable fact and not opinion. Defendants purported facts twenty three. Second,

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mister Bardon intended the January twenty fifteen statement to be

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a shot across the bow of the media, which he

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believed had been unduly eager to publish Miss Robert's allegations

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without conducting any inquiry of their own. Accordingly, in the statement,

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he repeatedly noted that Miss Robert's allegations were defamatory. In

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this sense, the statement was intended as a cease and

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assist letter to the media recipients, letting the media recipients

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understand the seriousness with which Miss Maxwell consider the publication

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of Miss Robert's obviously false allegations and the legal indefensibility

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of their own conduct. Miss Robert's statement controverting the defendant's facts.

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This paragraph is another purported statement of Defendant's council's intent.

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Defendant states second mister Barden intended the January twenty fifteen

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statement to be a shot across the bow of the media,

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which he believed had been unduly eager to publish Miss

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Roberts's allegations without conducting any inquiry of their own. Not

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only does Defendant once again refer to mister Barton's intent,

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but she also mischaracterizes the statement as a shot across

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the bow of the media. The press release did not

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threaten or give warning to the media in any way whatsoever.

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See McCauley declaration at Exhibit twenty six GM zero zero

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zero six'. Eight, Next Miss roberts disputes the sentences. Accordingly

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in the, statement he repeatedly noted That miss roberts allegations were.

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Defamatory barden did not note anything in the, statement nor

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does defendant site to any record evidence that he. Does,

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Furthermore Miss roberts denies that any of her allegations are

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defamatory in the slightest as they are all true and

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substantiated by record. Evidence Miss roberts also disputes the sentence

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in this. Sense the statement was intended as the cease

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and desist letter to the media, recipients letting the media

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recipients understand the seriousness with Which Miss maxwell considered the

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publication Of miss roberts obviously false allegations and the legal

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indefensibility of their own. Conduct, First Miss roberts objects to

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any statement Of bardon's intent as articulated. Above, Second defendant's

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conventional press release was in no way any type of

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season decist. Letter there is no record evidence in support

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of this, claim and defendant unsurprisingly cites to. None Third

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Miss roberts disputes that any media recipients would be given

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to understand the seriousness with Which Miss maxwell considered the

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publication Of miss roberts obviously false allegations and the legal

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indefensibility of their own conduct by defendant self serving press

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release as them is unsupported by the. Record, Finally Miss

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roberts rejects that her allegations are obviously, false a claim

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which is completely unsupported by record. Evidence all, right, folks

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we're gonna wrap up right, there and in the next

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episode talking about the, topic we'll pick up where we left.

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Off all of the information that goes with this episode

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can be found in the description. Box what's up, everyone

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and welcome back to The Epstein. Chronicles in this, episode

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we're diving right back into those core documents and we're

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gonna pick up where we left, off taking a look

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at The Southern district Of New York's Local rule fifty

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Six dot one Plaintiff statement of contested facts And plaintiff's

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Undisputed Facts number twenty four defendants purported facts consistent with

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those two. Purposes Mister gal's emails preface the statement with

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the following. Language please find attached the quotable statement on

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behalf Of Miss. Maxwell the statement was intended to be a,

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single one time, only comprehensive response quoted in full To Miss,

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Roberts december, thirtieth twenty, fourteen allegations that would give the

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Media Miss maxwell's. Response the purpose of the preparatory statement

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was to inform the media recipients of this. Intent Miss

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robert's statement controverting the defendants. Facts Miss roberts disputes that

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any part of the defendant's press release is consistent with

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those two Of bardon's. Purposes, Indeed Miss roberts disputes this

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and any statement relating To barton's purposes as explained. Above,

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Next Miss roberts disputes that the statement was intended to

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be a, single one time, only comprehensive response quoted in

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full To Miss, Roberts december, thirtieth twenty, fourteen allegations that

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would give the Media Miss maxwell's. Response, First Miss roberts

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disputes this and any statement relating To barton's intent as explained. Above,

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Second Miss roberts disputes that anyone intended the press release

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to be a one time only comprehensive. Response the record

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evidence as, Otherwise gal repeatedly issued this statement via email

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and over the phone for months on. End, next the

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defendant states the purpose of the preparatory statement was to

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inform the media recipients of this. Intent, First Miss roberts

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disputes this in any statement relating To barton's purpose as explained. Above,

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Second Miss roberts disputes that the press release was to

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inform the media of. Anything defendant issued a press, release

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instructed them to publish it by telling them it was

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quotable see. M macaulay declaration At exhibit forty, eight and

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hired a press agent to feed it to the. Press

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question Did Miss maxwell retain the services of your? Firm answer,

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yes she. Did question is it your belief that the

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agreement was in effect On january, two twenty. Fifteen answer.

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Yes question do you recall the terms of that? Agreement answer,

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well it was a re establishment of an existing, Agreement

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so if we go back to the original agree it

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was to provide public relations services To Miss. Maxwell in

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the matter Of roberts ender Activities seemacaulay declaration At exhibit.

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Six the record evidence shows that defendant's intent was for

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00:16:13,559 --> 00:16:16,919
the press to publish her press. Release any other interpretation

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is not only contrary to, logic but unsupported by the.

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Record the Defendants Purported facts twenty. Five Miss roberts activities

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to bring light to the rights of victims of sexual.

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Abuse Miss roberts has engaged in numerous activities to bring

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attention to, herself to the prosecution and punishment of wealthy

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00:16:36,639 --> 00:16:40,120
individuals such As, epstein and to her claimed interest of

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00:16:40,120 --> 00:16:43,240
bringing light to the rights of victims of sexual. Abuse

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Miss robert's statement Controverting defendant facts agreed to the portion

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of defendants assertion in bold Font Miss roberts is not

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engaged in activities to bring attention to. Herself, rather she

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has taken action to aid in the prosecution of her,

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00:16:58,399 --> 00:17:01,120
abusers and she seeks to bring light to the rights

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of victims of sexual. Abuse Miss robert's statement Controverting defendance.

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Facts Miss roberts Created Victims Refuse Silence incorporated in order

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00:17:11,640 --> 00:17:14,880
to help other sexually trafficked victims find the resources they

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need to recover and. Heal Defendants Purported facts twenty. Seven

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the goal Of Victims Refuse silence was and continues to

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be to help survivors surmount the shame silence and intimidation

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typically experienced by victims of sexual. Abuse towards this, End

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Miss roberts has dedicated her professional life to helping victims

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of sex. Trafficking Miss robert's Statement Controverting Defendant facts Agreed

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Defendants Purported facts twenty. Eight Miss roberts repeatedly has sought

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out media organizations to discuss her alleged experience as a

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victim of sexual. Abuse Miss robert's Statement Controverting Defendant facts.

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Denied Miss roberts was approached by numerous media outlets and

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refuse used to speak to most of. Them media organizations

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sought her, out she did not seek them. Out Seem

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acauley declaration At exhibit thirty five email From Sharon churcher

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seeking to Interview Miss. Roberts Defendants Purported facts twenty. Nine

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On december, thirtieth twenty, Fourteen Miss roberts publicly filed an

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entirely unnecessary joined her motion laden with unnecessary lurid details

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about being sexually abused as a minor victim by wealthy

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and famous men and being trafficked all around the world

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as a sex. Slave Miss Roberts Statement Controverting Defendants facts

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See Roberts paragraph seven subra listing multiple reasons why details

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were in fact. Necessary Defendants Purported facts. Thirty The miss

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roberts alleged purpose in filing the jointer motion was to

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vindicate her rights under THE. Cvra exposed governments secretly negotiated

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non prosecution agreement With, epstein shed tremendous public light On

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eppsie and other powerful individuals that would undermine the agreement

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00:19:03,920 --> 00:19:07,839
and support THE. Cvra Miss roberts's request for documents that

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would show How epstein used its powerful political and social

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00:19:12,319 --> 00:19:16,000
connections to secure a favorable plea, deal and the government's

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motive to Aid epstein and his co. Conspirators Miss robert's

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00:19:19,880 --> 00:19:24,720
statement controverting defendant facts See Miss roberts paragraph Seven, supra

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listing multiple purposes Of miss roberts lawyer's filing of the.

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Motion Defendants Purported. Facts Miss roberts has written the manuscript

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of a book she has been trying to, publish detailing

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her alleged experience as a victim of sexual abuse and

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of sex trafficking In epstein's alleged sex. Scheme Miss robert's

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statement controverting the defendant facts See Miss roberts paragraph fifty Two,

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infra explaining that the context of this statement is Misleading

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defendants reported. Facts thirty. Two republication alleged By Miss Robs.

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Roberts Miss roberts was required By interrogatory number six to

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identify any false statements attributed To Miss maxwell that were published,

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globally including within The Southern district Of New, york As

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Miss roberts, alleged and paragraph nine Of count one of her.

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00:20:15,839 --> 00:20:21,000
Complaint in, Response Miss roberts identified The january twenty fifteen

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statement and nine instances in which various news media published

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00:20:25,240 --> 00:20:29,319
portions of The january twenty fifteen statement in news articles

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00:20:29,480 --> 00:20:35,079
or broadcast. Stories Miss robert's statement controverting defendants. Facts Miss

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00:20:35,200 --> 00:20:38,720
roberts objects to this paragraph in its, entirety starting with

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the bolded heading republication alleged By Miss. Roberts there is

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no republication as a matter of law in this, case

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00:20:46,519 --> 00:20:50,839
as explained In miss roberts memorandum of. Law, Accordingly Miss

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00:20:50,960 --> 00:20:54,960
roberts is not and has not alleged, republication as noted

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00:20:55,160 --> 00:20:58,680
in her objection that it is the defendant who possesses

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the knowledge as to where the defamatory statements were. Published,

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unsurprisingly defendant failed to comply With Miss roberts' discovery request

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on the same defendant already. Knows Miss roberts provided a

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00:21:11,480 --> 00:21:15,720
sampling of defendants defamatory statements published by the news, media

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as identification of an exhaustive responsive list would be unduly. Burdensome,

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this of, course is because defendant caused her statement to

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be published in an enormous number of media. Outlets Miss

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00:21:28,400 --> 00:21:32,079
roberts' full response To interrogatory number six is. Below as

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00:21:32,119 --> 00:21:34,839
the court can, see these nine instances were a good

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faith effort to provide some, samples as it would be

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virtually impossible to provide all of. Them. Below Miss roberts

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has also put forth an exhaustive expert report and expert

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testimony From Jim jansen regarding the dissemination of defendants defamatory press.

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Release Miss roberts objects because the information an interrogatory above

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is in the possession of the, defendant who has failed

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00:22:00,680 --> 00:22:03,920
to comply with her production obligations in this, matter and

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00:22:03,960 --> 00:22:06,920
has failed to comply with her production obligations with this

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very subject. Matter see Document request number seventeen From Miss

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roberts' second request for production of documents to Defendant Glenne.

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Maxwell maxwell has not produced ALL url Or internet addresses

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for Any internet version of such publication that she directed

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her Agent rosscau. Descend Miss roberts further objects because the

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information requested above is in the possession of the defendant's,

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agent who caused the false statements to be issued to

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various media. Outlets Miss roberts has not had the opportunity

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to Depose maxwell's, agent Rosscut, therefore this answer remains. Incomplete,

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Consequently Miss roberts reserves the right to modify and or

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supplement her responses as information is largely in the possession

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of the defendant and her. Agent Miss roberts objects to

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00:22:56,759 --> 00:23:00,599
this interrogatory in that it Violates rule thirty three as its,

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subparts in combination with other, interrogatories exceed the allowable twenty five.

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Interrogatories Miss roberts objects to this request because it is

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in the public. Domain Miss roberts also objects in that

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it seeks information protected by the attorney client work product

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privilege and any other applicable privilege stated in the general.

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Objections notwithstanding such, Objections Miss roberts has already produced document

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supplements such responsive documents with the following list of, publications

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while the identification of an exhaustive responsive list would be unduly.

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Burdensome in an effort to make a good faith effort towards,

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Compliance Miss roberts provides the following, examples which are incomplete

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based on the aforementioned. Reasons then she, lists there's a

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whole bunch of articles listed here from different newspapers defendants

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purported facts thirty. Three in none of the nine instances

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was there any publication of the Entire january, two thin

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fifteen Statement Miss robert's statement controverting the defendant. Facts while

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there may be certain publications who did not print every

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word Of defendant's lengthy press, release most publications quoted the

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00:24:12,000 --> 00:24:15,440
most salient to the point parts of the defendant statement

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00:24:15,680 --> 00:24:18,079
that Call Miss roberts a. Liar in each of the

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nine articles listed, above the defamatory, statement as articulated by

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the complaint and as identified by The court as actionable is.

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Published See roberts Versus maxwell one six five F dot

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Supp dot THREE d one forty seven one fifty TWO

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sdny twenty. Sixteen statements That robert's claims against defendant are

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untrue have been shown to be untrue and our obvious

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lies have a specific and readily understood, factual meaning That

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roberts is not telling the truth about her history of

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sexual abuse and defendant's, role and that some verifiable investigation

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has occurred and come to a definitive conclusion proving that. Fact,

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second these, statements as they themselves, alleged are capable of

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being proven true or, false and therefore constitute actionable fact

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and not. Opinion Ms roberts also put forth extensive evidence

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of the mass distribution of defendants defamatory statement to over

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sixty six million viewers through her expert Witness Jim JANSEN.

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C McCaulay declaration At exhibit twenty Four Expert report Of Jim.

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Jansen All, right, folks we're going to wrap up this

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episode here and in the next episode we're going to

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pick up where we left. Off all of the information

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that goes with this episode can be found in the description.

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Box