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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 dive right back into

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those core documents and we're going to take a look

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at the Southern District of New York Local Rule fifty

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six Dot one Plaintiffs Statement of contested Facts and Plaintiff's

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undisputed Facts Case number fifteen DASH CV DASH zero seven

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four three three d RWs Virginia Roberts Plaintiff First Glenn Maxwell,

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the defendant, 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. Defendants Purported Facts one. Miss Maxwell's response to

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publication of Miss roberts false allegations the March twenty eleven statement.

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In early twenty eleven, Miss Roberts and two British tabloid

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interviews made numerous false and defamatory allegations against Miss Maxwell

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In the articles. Miss w Roberts made no direct allegations

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that Miss Maxwell was involved in any improper conduct with

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Jeffrey Epstein, who pleaded guilty in two thousand and seven

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to procuring a minor for a prostitution. Nonetheless, Miss Roberts

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suggested that miss Maxwell worked with Epstein and may have

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known about the crimes for which he was convicted. Miss

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Roberts statement controverting defendants facts. Miss Roberts denies that the

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allegation she made against Miss Maxwell or false. Furthermore, Miss

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Roberts did give an interview to journalist Aaron Churcher in

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which Miss Roberts accurately and truthfully described Defendant Maxwell's role

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as someone who recruited or facilitated the recruitment of young

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females for Jeffrey Epstein. C McCauley declaration at Exhibit thirty four.

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Miss Roberts was also interviewed by the FBI in twenty eleven,

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and she discussed Defendant's involvement in the sexual abuse c

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McCauley declaration at Exhibit thirty one. FBI redacted three h two.

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Those statements were not false and defamatory, but instead truthful

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and accurate. Defendants purported facts two. In the articles, Miss

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Roberts alleged she had sex with Prince Andrew, a well

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known businessman, a world renowned scientist, a respected liberal politician,

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and a foreign head of state. Miss Robert's statement controverting

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defendant facts. Miss Roberts does not contest this fact, but

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believes that it's irrelevant. Defendants Purported Facts three. In response

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to the allegations, Miss Maxwell's British attorney working with mister

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gow issued a statement on March ninth, twenty eleven, denying

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the various allegations about Miss Maxwell that have appeared recently

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in the media. These allegations are all entirely false. Miss

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Robert's statement controverting defendant facts. Miss Roberts denies that mister

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Bardon issued a statement. Instead, it appears to have the

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contact as Ross gou in a reference to Devonshire Solicitors

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Defendants Purported Facts for the statement Read and full statement

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on behalf of Glenn Maxwell by Devonshire Solicitors pr Any, Wednesday,

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March ninth, twenty eleven. Glean Maxwell denies the various allegations

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about her that have appeared recently in the media. These

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allegations are entirely false. It is unacceptable that letters sent

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by Miss Maxwell's legal representatives to certain newspapers pointing out

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the truth and asking for the allegations to be withdrawn

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have simply been ignored in the circumstances, Miss Maxwell is

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now proceeding to take legal action against those newspapers. I

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understand newspapers need stories to sell copies. It is well

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known that certain newspapers live by the adage why let

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the truth get in the way of a good story. However,

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the allegations made against me are abhorrent and entirely untrue,

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and I asked that they stop, said Glenn Maxwell. A

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number of newspapers have shown a complete lack of accuracy

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in their reporting of this story and a failure to

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carry out the most elementary investigation or any real due diligence.

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I am now taking action to clear my name. Miss

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Robert's statement controverting defendants facts. The document speaks for itself,

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although it is unclear if the original included the italics

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that are inserted by the defendant above. Defendants purported facts

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five Miss Robert's gratuitous and lurid accusations. In an unrelated

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action in two thousand and eight, to alleged victims of Epstein,

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brought an action under the Crime Victim Rights Act against

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the United States Government purporting the challenge Epstein's plea agreement.

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They allege the government violated their CVR rights by entering

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into the agreement miss Robert's statement controverting defendant facts. While

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we would stipulate to the statement in this paragraph starting

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with the words in two thousand and eight, we do

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not stipulate to the opening sentence fragment Maxwell places in

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bold defendants purported facts six. Seven years later, on December thirtieth,

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twenty fourteen, Miss Roberts moved to join the CVR action,

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claiming she too had her CVR rights violated by the government.

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On January first, twenty fifteen, Miss Roberts filed a corrected

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joined her motion Miss Roberts's statement controverting defendants facts agreed

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Defendants Purported Facts seven. The issue presented in her Joined

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her motion was narrow whether she should be permitted to

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join the CVR A action as a party under Federal

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Rule of Civil Procedure twenty one, specifically whether she was

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a known victim of mister Epstein and the government owed

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them CVR duties. Yet, the bulk of the motion consists

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of copious factual details that Miss Roberts and her co

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movement would prove if allowed to join. Miss Roberts gratuitously

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included provocative and lurid details of her alleged sexual activities

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as an alleged victim of sexual trafficking. Miss Roberts statement

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controverting defendants facts. Miss Roberts denies that the issues presented

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in here joined her motion were narrow. The issues presented

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by the jointer motion and related pleadings were a multiple

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and complex requiring numerous details about Miss Robert's sexual abuse

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and the perpetrators of her abuse. In a pleading explaining

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why the motion was filed, Miss Roberts lawyers specifically listed

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nine separate reasons why Jane Doe number three's allegations that

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Dershowitz had sexually abused her were relevant to the case

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and appropriately included in the relevant findings. One to establish

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that Jane Doe three had been sexually abused by Jeffrey

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Epstein and his co conspirators, including co conspirator Alan Dershowitz,

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which would make her a victim of a broad sex

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trafficking conspiracy covered by the Federal Crime Victim's Rights Act

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US Code eighteen, Section thirty seven seventy one, and therefore

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entitled to participate in the case. Two to support her

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then pending discovery requests that asked specifically for information related

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to the contacts by Dershowitz with the government on behalf

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of Jeffrey Epstein. Three to support the victim's allegation that

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the government automotive for failing to afford victims with their

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rights in the criminal process, specifically pressure from Dershowitz and

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other members of Epstein's legal defense team to keep the

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parameters of the non prosecution agreement secret, to prevent Jane

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do three and other victims from objecting to and blocking

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judicial approval of the agreement. Four to establish the breadth

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of the NPA's provision extending immunity to any potential co

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conspirators of Epstein, and the scope of the remedy that

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the victims, including not only Jane do three, but also

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other similarly situated minor victims who had been sexually abused

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by Dershowitz, might be able to obtain for violations of

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their rights. Five to provide part of the factual context

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for the scope of the interface between the victims, the government,

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and en Epstein's defense team, in interface that was relevant

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

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to raise a fact sensitive equitable defense, which must be

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considered in the factual context of the entire interface between Epstein,

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the relevant prosecutorial authorities, and the federal offense victims. Six

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To prove the applicability of the crime fraud misconduct exception

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to the attorney client privilege that was being raised by

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the government in opposition to the victim's motion for production

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of numerous documents. Seven To bolster the victim's argument that

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their right to be treated with fairness US Code eighteen,

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Section three seven seven one a eight had been violated

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through the government secret negotiations with one of their abusers.

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Eight To provide notice and lay out the parameters of

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potential witness testimony for any subsequent proceedings or trial, ie

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the scope of the testimony that Jane Do three was

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expected to provide in support of Jane Doe one and

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Jane Do two, the already recognized Miss Roberts in the

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action n Nine. To support Jane Doe three's argument for

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equitable estoppel to toll the six year statute of limitation

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being raised by the government in opposition to her motion

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to join IE that the statute was told while she

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was in hiding in Australia due to the danger posed

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by Epstein and his powerful friends, including prominent lawyer Alan Dershowitz,

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Jane Doe's number one and number two United States number

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nine zero eight CV eight zero seven three six d

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E two ninety one at eighteen through twenty six, and

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N seventeen s D. Florida twenty fifteen. Miss Roberts lawyers

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had attempted to obtain a stipulation from the government on

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point number one above victim status, but the government had declined.

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Judge Marra's ruling concluded that certain allegations were not necessary

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at this juncture. In the proceedings d E three twenty

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four at five. Judge Maras specifically added, however, that Chaine

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DO three is free to reassert these factual details through

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proper evidentiary proof, should petitioners demonstrate good faith basis for

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believing that such details are pertinent to a matter presented

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for the court's consideration. D three twenty four at six.

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The CVR litigation continues and no trial has been held

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as of the filing of this brief. As such, the

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extent to which these factual details will be used at

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trial has not yet been determined. See docket sheet chain

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Doe's number one and two versus the US number nine

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zero eight CV eight zero seven three six. All right, folks,

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we're gonna wrap up part one here and in the

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next episode we'll pick up well part two. All of

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the information that goes with this episode can be found

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in the description box. What's up, everyone, and welcome back

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to the Epstein Chronicles. In this episode, we're gonna pick

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right back up where we left off with Virginia's statement

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of contested facts and plaintiff's undisputed facts Defendants purported facts

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number eight. At the time they filed the motion, Miss

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Roberts and their lawyers knew that the media had been

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following the Epstein criminal case and the CVRA action. While

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they deliberately filed the motion without disclosing Miss Robert's name,

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claiming the need for privacy and secrecy, they made no

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attempt to file the motion under seal. Quite the contrary,

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they filed the motion publicly Miss Robert's statement controverting defendants

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facts see Miss Roberts response to point seven above. Defendants

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purported facts number nine. As the District Court noted in

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ruling on the jointer motion, Miss Robert's name several individuals,

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and she offers details about the type of sex acts

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performed and where they took place. The court ruled that

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these lurid details are unnecessary. The factual details regarding whom

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and where the Jane Dooes engaged in sexual activities are

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immaterial and impertinent, especially considering that these details involved non

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parties who were not related to the respondent government. Accordingly,

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these unnecessary details shall be stricken. The court then struck

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all Miss roberts factual allegations relating to her alleged sexual

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activities and her allegations of misconduct by non parties. The

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court said the striking of the lurid details was a

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sanction for Miss Roberts in proper inclusion of them in

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the motion Miss Robert's statement controverting the defendants facts see

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Miss Roberts response to point seven above. Defendants Reported Facts

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number ten. The District Court found not only that the

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lurid details were unnecessary, but also that the entire joinder

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motion was entirely unnecessary. Miss Roberts and her lawyers knew

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the motion, with all of its lurid details was unnecessary

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because the motion itself recognized that she would be able

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to participate as a fact witness to achieve the same

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result she sought as a party. The court denied Miss

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Robsrobert's joined her motion Miss Roberts statement controverting defendants facts.

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See Miss roberts response to point number seven above, Defendants

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purported Facts. One of the non parties Miss Roberts's name

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repeatedly in the joinder motion was Miss Maxwell. According to

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the lurid details the Miss Roberts included in the motion,

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Miss Maxwell personally was involved in a sexual abuse in

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sex trafficking scheme created by Epstein. Miss Maxwell approached Miss

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Roberts in nineteen ninety nine, when Miss Roberts was fifteen

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years old, to recruit her into the scheme. Miss Maxwell

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was one of the main women Epstein used to procure

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underage girls for sexual activities. Miss Maxwell was a primary

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co conspirator with Epstein in his scheme. She persuaded Miss

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Roberts to go to Ebstein's mansion in a fashion very

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similar to the manner in which Epstein and as other

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co conspirators coerced dozens of other children at the mansion.

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When Miss Roberts began giving Epstein a massage. He and

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Miss Maxwell turned it into a sexual encounter. Epstein, with

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the assistance of Miss Maxwell, converted Miss Roberts into a

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sex slave. Miss Maxwell was also a co conspirator in

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Epstein's sexual abuse. Miss Maxwell appreciated the immunity she acquired

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under Epstein's plea agreement because the immunity protected her from

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prosecution for the crime she committed in Florida, Miss Maxwell

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participated in the sexual abuse of Miss Roberts and others.

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Miss Maxwell took numerous sexually explicit pictures of underage girls

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involved in sexual activities, including Miss Roberts. She shared photos

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

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abuse ring, Miss Maxwell connected Epstein with powerful individuals so

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that Epstein could traffick Miss Roberts to these persons. Miss

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Roberts was forced to have sexual relations with Prince Andrew

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in Miss Maxwell's apartment in London. Miss Maxwell facilitated Miss

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Roberts sex with Prince Andrew by acting as a madam

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for Epstein. Miss Maxwell assisted in internationally trafficking Miss Roberts

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and numerous other young girls for sexual purposes. Miss Roberts

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was forced to watch Epstein, Miss Maxwell and others engage

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in a legal sexual acts with dozens of underage girls.

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Miss Roberts statement controverting defendants facts c. Miss Roberts response

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to point seven above. Miss Roberts can test the reference

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to allurid details. Moreover, the testimony from numerous witnesses corroborates

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the statements Miss Roberts maid interjoined her motion. Cemaculley declaration

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at Exhibit sixteen. Cemaculley declaration at Exhibit four, CEEMO Callie

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declaration at Exhibit fourteen, Seemacullie declaration at Exhibit twelve, Seemaculley

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declaration at Exhibit thirteen, CEEMA Callie declaration Exhibit fifteen, SEEMA

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Callie Declaration, Exhibit ten, SEEMA Callie Declaration Exhibit eight, CEEMO

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Callie Declaration Exhibit one, CEEMO Calley declaration Exhibit thirty, CEEMA

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Calley Declaration Exhibit thirty three. CEE McCauley declaration at Exhibit

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thirty eight, McCauley at Exhibit twenty eight, McCauley at Exhibit

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twenty nine, McCauley at Exhibit forty, and McAuley at thirty two.

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See McCauley at Exhibit thirty nine, and then finally ce

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McCauley declaration at Exhibit forty one. The defendants purported facts twelve.

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In her jointer motion, Miss Roberts also alleged she was

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forced to have sex with Harvard law professor Alan Dershowitz,

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model scout Jean Luke Brunel, and many other powerful men,

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including numerous prominent American politicians, powerful business executives, foreign presidents,

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a well known prime minister, and other world leaders. Miss

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Robert's statement controverting defendants facts see a response to point

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number seven and eleven above. Defendants Purported Facts Number thirteen.

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Miss Roberts said, after serving for four years as a

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sex slave, she managed to escape to a foreign country

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and hide out from Epstein and his co conspirators for years.

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Miss Robert's Statement Controverting Defendant's facts agreed that Miss Roberts

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made this statement and has since discovered evidence that indicates

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she was mistaken on the exact timeframe of her abuse

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and was with defendant and Jeffrey Epstein from the years

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two thousand to two thousand and two. Defendants Purported Facts.

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Miss Roberts suggests the government was part of Epstein's conspiracy

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when it secretly negotiated a non prosecution agreement with Epstein

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precluding federal prosecution of Epstein and his co conspirators. The

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government secrecy miss Roberts alleged, was motivated by its fear

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that Miss Roberts would raise powerful objections to the agreement

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that would have shed tremendous public light on Epstein and

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other powerful individuals. Miss Robert's statement controverting the defendant's facts.

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Miss Roberts did not suggest that the government was part

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of Epstein's conspiracy to commit sex offenses. The CVR case

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deals with whether the government failed in their responsibility to

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the victims to inform the victims that the government was

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working out an NPA, and it is Miss roberts belief

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that the government did fail to so inform the victims

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and intentionally did not inform the victims because the expected

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serious objection from many of the victims might prevent the

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government from finalizing an NPA with Epstein. CEE McCauley declaration

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at Exhibit fifty joined her motion Roberts zero zero three

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one nine dashed zero zero three three three. The defendants

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purported facts fifteen. Notably, the other Jane Doe, who joined

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Miss Roberts's motion, who alleged she was sexually abused many

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occasions by Epstein, was unable to corroborate any of Roberts's allegations.

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Miss Robert's statement controverting the defendant's facts. This is untrue.

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The other Jane Doe, could corroborate many of Miss Roberts's

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allegations based on the similar pattern of abuse that she

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suffered by Epstein. She did not know. Miss Roberts, though redacted,

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who was deposed in this case and who is a minor,

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corroborates the same pattern of abuse. Seemacaulley declaration at Exhibit seven.

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Defendants purported facts sixteen. Also, notably, in her multiple and lengthy,

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consensual interviews with Miss Churcher three years earlier, Miss Roberts

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told Miss Churcher of virtually none of the details she

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described in the joint motion. Miss Robert's statement controverting defendants facts.

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This is untrue. Furthermore, defendant does not offer any citation

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or evidence on this point. Defendant statement here is knowingly false.

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Having read the articles and taken miss Roberts deposition, defendant

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knows that Miss Roberts did reveal details in twenty eleven

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consistent with those in the jointer motion. Seemacauley declaration at

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Exhibit thirty one FBI redacted three oh two Roberts zero

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zero one two three five Dash one two four six

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The Defendants Purported Facts seventeen. Miss Maxwell's response to Miss

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roberts lurid accusation. The January twenty fifteen statement, as Miss

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Roberts and her lawyers expected before Judge Merra in the

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CVRA action, could strike the lurid details the Miss Roberts

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allegations in the joinder motion. Members of the media obtained

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copies of the motion. Miss Robert's statement controverting defendants facts

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see Miss Roberts response to point number seven above. Defendants

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Purported Facts eighteen. At mister Barden's direction, on January three,

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twenty fifteen, Mister Goo sent to numerous representatives of British

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media organizations an email containing a quotable statement on behalf

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of Miss Maxwell. The email was sent to more than

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six and probably less than thirty media representatives. It was

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not sent to non media representatives. Miss Robert's statement controverting

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the defendant's facts. Defendant falsely claims that the mister Barden's direction.

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On January three, twenty fifteen, mister Goo sent to numerous

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representative of British media organizations an email containing a quotable

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statement on behalf of Miss Maxwell. This is a blatant

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falsehood about the document that is at the heart of

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this litigation. Record evidence shows that Gao sent that email

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at Defendant's direction, not at mister Barton's direction. Indeed, on

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the evening before his deposition, mister Gall produced an email

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exchange he had had with the defendant in which the

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defendant directs mister Gao to the press statement. Chronologically, this

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email comes at the end of various other email exchanges

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between the defendant and Gao that discusses issuing a press release.

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The subject line of this email that defendant wrote to

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Gall states urgent this is the statement, thereby instructing Gau

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to release this statement to the press. Shortly after defendant

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sent this email to Gao directing him to release the statement,

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Goo distributed the statement to multiple media outlets. Neither defendant

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nor Goo have produced any email in which Barton directed

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Gao to issue Sho you this press release, nor can

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they despite sending it herself and despite it being responsive

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to six court ordered search terms. Defendant failed to produce

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this email. Her press agent Gow produced this the evening

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before this deposition on November seventeenth, twenty sixteen. At the deposition,

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mister Gow authenticated this email and confirmed that the defendant

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authorized the statement. Question when you sent that email? Were

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you acting pursuant to Miss Maxwell's retention of your services? Answer? Yes,

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I was. Question this also appears to be an email

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chain with you and miss Maxwell? Is that correct? Answer?

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It does appear to be so. Question did you send

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the top email of the chain that says okay? Gee?

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00:22:43,559 --> 00:22:46,799
Going with this answer? I did? Question? And did you

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receive from miss Maxwell the bottom email of that chain? Answer?

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I believe so well. I believe yes, yeah, it was

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forwarded from miss Maxwell. Yes, mister Dyer, sorry, I don't

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quite understand that answer the witness that I did receive

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it from Miss Maxwell. Mister Dyer, okay. Question the subject

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line does have forward, which to me indicates it's a forward.

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Do you know where the rest of that email chain is? Answer?

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My understanding of this is it was a holiday in

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the UK, but mister Barton was not necessarily accessible at

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some point in time. So this had been sent to

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him originally by miss Maxwell, and because he was unavailable,

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she forwarded it to me for immediate action. I therefore responded, Okay, Glane,

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I'll go with this. It's my understanding that this is

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the agreed statement. Because the subject of the second one

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is urgent. This is the statement, so I take that

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as an instruction to send it out as a positive command.

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This is the statement. C. McCaulay declaration at Exhibit six. Together,

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the email and Gal's testimony unequivocally established that defendant, not Barden,

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directed and commanded GOUTI published the defamatory statement. Accordingly, the

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first sentence of Defendant's paragraph eighteen is false. The second

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statement this email was sent to more than six and

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probably less than thirty media representatives, omits the fact that

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not only did Gao admit to emailing the statement to

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the press, but he also read it to over thirty

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media representatives over the phone. Question do you recall reading

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the statement to the press or the media over the phone?

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00:24:23,400 --> 00:24:25,799
Answer It's very possible that I would have done so.

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00:24:27,119 --> 00:24:31,839
Question do you do you remember discussing that with the Guardian? Answer? No,

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00:24:32,039 --> 00:24:34,799
I don't, I'm not saying I didn't, but I don't recall.

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00:24:35,279 --> 00:24:37,400
You have to bear in mind, if you'd be so kind,

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that I've been speaking to over thirty journalists and media

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outlets about this, and I can't recall every single detail

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of every single conversation seem Acauli declaration at Exhibit six.

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Thus the second sentence of defendant's paragraph eighteen is also false.

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All right, folks, we are going to wrap up right here,

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and then the next episode we'll pick up where we

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left off. All of the information that goes with this

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this episode can be found in the description box