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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 continue taking a look

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at Glaine Maxwell's response to Virginia Roberts Contested Facts and

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the Plaintiff's Undisputed Facts Number thirty eight. Plaintiff re enrolled

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in high school from June twenty first, two thousand, until

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March seventh, two thousand and two. After finishing the ninth

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grade high school year at Forest Hills High School on

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June ninth, nineteen ninety nine, Plaintiff re enrolled at Wellington

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Adult High School on June twenty first, two thousand, again

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on August sixteenth, two thousand, and August fourteenth, two thousand

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and one. On September twentieth, two thousand and one, Plaintiff

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then enrolled at Royal Palm Beach High School. A few

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weeks later, on October twelfth, two thousand and one, she

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matriculated at Survivor's Charter School. Survivor's Charter School was an

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alternative school designed to assist students who had been unseed

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sucessful at more traditional schools. Plaintiff remained enrolled at Survivor's

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Charter School until March seventh, two thousand and two. She

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was present fifty six days and absent thirteen days during

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her time there. Plaintiff never received her high school diploma

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or ged. Plaintiff and Figueroa went back to school together

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at Survivor's charter school example p At twenty three through

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twenty seven. The school day there lasted from morning until

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early afternoon id at twenty three through twenty seven. Plaintiff argues,

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again without evidentiary support, that the codes on the school

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records indicate semester's start and end dates rather than dates

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plaintiff was in school. Her misreading of the records is

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a parent from their face. One column is labeled entry

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date and the next withdrawal date. Neither say semester start

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date or semester end date. Moreover, the codes simply prove

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the point if entered school codes EO one and EA

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one on the designated entry date, and withdrew either prior

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to completion to enter another training program or who will

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continue in the class program the next term or school

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year on the dates designated with dawel. The school records

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display entry and withdrawal dates for Wellington High School Adult

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Program from June twenty first two thousand through August fifteenth,

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two thousand, from August sixteenth, two thousand through August thirteenth,

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two thousand and one, and from August fourteenth, two thousand

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and one through September twentieth, two thousand and one, and

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then an entry that same day, September twentieth, two thousand

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and one, at Survivor's charter school. Plaintiff would have one

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belief that the records show a school on Plaintiff's official

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transcript that she never went to Wellington High School Adult

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program that indicates that she withdrew the very day she

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concededly entered Survivor's charter school. Her intention misreading of the

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record is yet another attempt to offuscate plaintiff's lack of

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memory regarding where and when she went to school, just

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like she failed to remember eight jobs that she held

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in two thousand, whereas she claimed to have none. The

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test is admissible evidence to the country, and plaintiff offers none.

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The flight logs which show trips in early two thousand

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and one do not contradict the evidence because they are

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during the period of time she was enrolled in adult

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high school, a place where night classes were taught. And

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where one might circumstantially infer careful attendance records were not

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kept Fact number thirty nine. During the year two thousand,

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Plaintiff worked at numerous jobs. In two thousand, while living

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with her fiance, Plaintiff held five different jobs at Aviculture

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Breeding and Research Center, Southeast Employee Management Company, the Club

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mar A Lago, Oasis Outsourcing, and Neiman Marcus. Her taxable

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earnings that year totaled nearly nine thousand dollars. Plaintiff cannot

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now recall either the Southeast Employment Management Company or the

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Oasis Outsourcing jobs example at Q at four seventy and

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four seventy one reply. Plaintiff does not dispute the facts

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as presented, merely argues regarding their significance. The Social Security

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Administration records detail the five jobs at which she worked

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in two thousand. The month and day of the jobs

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are irrelevant for purposes of this recitation of facts. Likewise,

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plaintiff does not dispute the taxable earnings she made that year,

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or that she does not remember the jobs associated without

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Southeast Employment Management Company or Oasis Outsourcing, whether they were

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payroll or not. Where she made three thousand two hundred

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and twelve dollars and two thousand, thirty seven dollars that year.

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She also forgot about the job at Neeman Marcus, where

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she made four hundred and forty dollars in two thousand,

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until she was confronted with the SSA Records Colleigue declaration

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a example five number forty undisputed fact forty. Plaintiff's employment

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at mar A Lago SPA began in the fall of

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two thousand. Plaintiff's father, Sky Roberts, was hired as a

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maintenance worker at the mar A Lago club in Palm Beach, Florida,

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beginning on April eleventh, two thousand. Miss Roberts worked there

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year round for approximately three years. After working there for

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a period of time, mister Roberts became acquainted with the

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head of the spy area and recommended plaintiff for a

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job there. Mar A Lago closes every Mother's Day and

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reopens on November first. Example you at mar A Lago

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zero two one two. Most of the employees who work

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at mar A Lago, including all employees of the SPA

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area such as SPA attendants, are seasonal and work only

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when the club is open. I e November one and

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Mother's Day. Example t at seventy two and seventy three,

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plaintiff was hired as a seasonal SPA attendant to work

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at at the mar A Lago Club in the fall

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of two thousand, after she had turned seventeen the reply.

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Plaintiff's response is misleading. First, she does not dispute that

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Miss Roberts and her father began working at mar A

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Lago in April of two thousand, nor that he worked

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there for some time, became acquainted with the head of

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the Spy Are You, and recommended his daughter for a job. Second,

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plaintiff contends that job postings in job descriptions from two

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thousand and two and later are irrelevant. There are no

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such job posting cited. Rather, the job posting cited was

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from October two thousand, the same time the plaintiff was hired.

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Compare example v posting for Saturday October fourteenth and Sunday

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October fifteenth with calendar for year two thousand showing Saturday

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and Sundays in October corresponding to those dates. Finally, plaintiff

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points to her own recollection as contrary proof. Her recollection

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about when she worked at mar A Lago has shifted

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dramatically over time. First she aimed it was nineteen ninety

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eight see Jane do one O two complaint. Then it

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was nineteen ninety nine see document number one. Now in

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this response she has changed her answer to two thousand.

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Her vague recollections about what year have been off base.

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No credit should be given to her newfound recollection of

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which month that she worked there. In any event, she

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presents no admissible, credible evidence to contradict mar A Lago's

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own records. Even Plaintiff's father, a longtime employee of mar

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A Lago, admitted that the plays closed down in the summer.

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Plaintiff simply is not credible in her testimony that she

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recalls it being a summer job, and the fact that

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she did not work at the spa until at least

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November two thousand at the age seventeen, should be deemed

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admitted undisputed. Fact forty one. Plaintiff represented herself as a

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messuse for Jeffrey Epstein, while working at mar A Lago's

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spa and reading a library book about massage, met Miss Maxwell.

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Plaintiff thereafter told her father that she got a job

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working for Jeffrey Epstein as a messus. Plaintiff's father took

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her to Epstein's house on one occasion around that time,

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and Epstein came outside and introduced himself to mister Roberts.

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Plaintiff commenced employment as a traveling messuse for mister Epstein.

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Plaintiff was excited about her job as a messuse, about

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traveling with him, and about meeting famous people. Plaintiff represented

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that she was employed as a massuse beginning in January

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of two thousand and one. Plaintiff never mentioned Miss Maxwell

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to her then fiance, Ostrich. Plaintiff's father never met Miss Maxwell.

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Reply Plaintiff does not actually refute any of the facts

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set forth above, but rather spends her time discussing different facts.

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Plaintiff's father testified to what she told them that she

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was going to learn massage therapy. She does not contest

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her father's testimony that Epstein came out of the house

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and greeted her, and that her father never met Miss Maxwell.

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See a reply to Undisputed Fact number forty one. Whether

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someone can receive a massage license under Florida law without

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a high school equivalency diploma is of no moment. Plaintiff

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does not dispute she represented herself as the masseuse to

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others in her own handwriting beginning in January two thousand

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and one. Examples M and N. These facts should be

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deemed admitted. Number forty two Plaintiff resumed a relationship with

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convicted felon Anthony Figaroa in the spring of two thousand

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and one. While living with Ostrich, Plaintiff lied to and

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cheated on him with her high school boyfriend, Anthony Figaroa.

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Plaintiff and Ostrich thereafter broke up, and Figaroa moved into

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the Bento compartment with plaintiff. When Ostrich returned to the

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Bento compartment to check on his pets and to retrieve

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his belongings, Figaroa, in Plaintiff's presence, punched Ostrich in the face.

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Figaroa and plain fled the scene before police arrived. Figueroa

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was then a convicted felon and a drug abuser on

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probation for possession of a controlled substance. Reply. Plaintiff argues

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relevance regarding these facts, but contests none of them they

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should be deemed admitted. Plaintiff's slies cheating and association with

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a convicted felon and known drug abuser are all relevant

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in this defamation case concerning her reputation, purported damage to

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such reputation, and whether she was a known liar. As

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the January twenty fifteen statement contends, Number forty three, plaintiff

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freely and voluntarily contacted the police to come to her

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aid in two thousand and one and two thousand and two,

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but never reported to them that she was an Epstein's

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sex slave. In August two thousand and one, at age seventeen,

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while living in the same apartment, plaintiff and Figueroa hosted

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a party with a number of guests. During that party,

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according to the place plaintiff, someone entered Plaintiff's room and

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stole five hundred dollars from her shirt pocket. Plaintiff contacted

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the police. She met and spoke with police officers regarding

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the incident, and filed a report. She did not disclose

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to the officer that she was a sex slave. A

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second time, in June two thousand and two, plaintiff contacted

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the police to report that her former landlord had left

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her belongings by the roadside and had lit her Mattress

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on fire. Again, plaintiff met and spoke with law enforcement,

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but did not complain that she was the victim of

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any sexual trafficking or abuse or that she was being

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held as a sex slave. Reply, Plaintiff again presents no

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admissible evidence to contradict these facts, instead arguing their relevance

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they should be deemed admitted. Forty four From August two

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thousand and one until September two thousand and two, Epstein

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and Maxwell were almost entirely absent from Florida on documented

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travel unaccompanied by planingf Flight logs maintained by Epstein's private pilot,

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David Rodgers evidenced the substantial number of trips away from

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Florida that Epstein and Maxwell took unaccompanied by plaintiff between

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August two thousand and one and September two thousand and two.

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Rogers maintained the log of all flights on which Epstein

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and Maxwell traveled with them. Epstein additionally traveled with another

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pilot who did not keep such logs, and he also

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occasionally traveled via commercial flights. For substantially all of the

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thirteen months of the twenty two months from November two

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thousand until September two thousand and two, the plaintiff lived

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in Palm Beach and New Epstein. Epstein was traveling outside

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of Florida unaccompanied by Plaintiff. During this same time period,

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Plaintiff was employed at various jobs, enrolled in school, and

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living with her boyfriend. Reply, Plaintiff goes to great lengths

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to dispute facts other than those presented as undisputed fact

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forty four. Competitive recitation of the flights that plaintiff was

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on do nothing to demonstrate the thirteen months of flights

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from July two thousand and one until August two thousand

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and two that Epstein and Maxwell were on without Plaintiff,

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as reflected in the logs. Her assertions regarding the other

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flights that she took commercial or any other plane do

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nothing to establish all of the many flights she was

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not on during thirteen of the twenty two months period

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during which Epstein and Maxwell were away from Palm Beach.

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Plaintiff does not dispute that Epstein and Maxwell were on

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the flights without her. The facts as presented by defendant

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should be deemed admitted. Forty five. Plaintiff and Figeroa shared

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a vehicle during two thousand and one and two thousand

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and two, Plaintiff in Figeroa shared a nineteen ninety three

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Pontiac in two thousand and one and two thousand and two.

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Plaintiff freely traveled around the Palm Beach area in that vehicle.

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In August of two thousand and two, night if acquired

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a Dodge Dakota pickup truck from her father example p

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At sixty seven and sixty eight. Figaroa used that vehicle

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in a series of crimes before and after plaintiff left

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for Thailand. Reply again, the response has nothing to do

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with the fact stated, as plaintiff concedes, she and mister

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Figaroa had one car that they both used. In fact,

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they traveled to and from school together example p At

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sixty seven and sixty eight. She does not dispute that

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she traveled freely around the Palm Beach area in that vehicle,

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or that her car was used in a series of

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thefts while she was in Thailand. All that should be

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deemed admitted forty six undisputed fact forty six. Plaintiff held

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a number of jobs in two thousand and one and

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two thousand and two. During two thousand and one and

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two thousand and two, Plaintiff was gainfully employed at several jobs.

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She worked as a waitress at Menino's Restaurant, at TGIF's

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Friday's Restaurant, and at Roadhouse Grill. She also was employed

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at Courtyard Animal Hospital. Reply. Plaintiff admits all of the

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facts at fourth above, aside from the use of the

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word gainfully, they should be deemed admitted forty seven. In

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00:15:16,879 --> 00:15:20,679
September two thousand and two, plaintiff traveled to Thailand to

240
00:15:20,759 --> 00:15:23,960
receive massage training, and while there met her future husband

241
00:15:24,120 --> 00:15:27,720
and Elope with them. Plaintiff traveled to Thailand in September

242
00:15:27,759 --> 00:15:30,559
of two thousand and two to receive formal training as

243
00:15:30,559 --> 00:15:34,519
a massuse. Figaroa drove her to the airport. While there,

244
00:15:34,679 --> 00:15:38,960
she initially contacted Figaroa frequently, incurring a phone bill of

245
00:15:39,039 --> 00:15:42,639
four thousand dollars. She met her husband while in Thailand

246
00:15:42,679 --> 00:15:46,159
and decided to marry him. She thereafter ceased all contact

247
00:15:46,240 --> 00:15:49,879
with Figaroa from October two thousand and two until two

248
00:15:50,000 --> 00:15:53,440
days before mister Figaroa's deposition in this matter in May

249
00:15:53,480 --> 00:15:57,960
of twenty sixteen. Reply Again, Plaintiff does not refute the

250
00:15:58,000 --> 00:16:01,879
facts at fourth. She simply offers her own interpretation of

251
00:16:01,919 --> 00:16:05,759
those facts. In the absence of any country evidence, they

252
00:16:05,799 --> 00:16:10,360
should be deemed admitted forty eight undisputed fact Number forty eight.

253
00:16:10,840 --> 00:16:15,039
Detective Riccarry's investigation of Epstein fell to uncover any evidence

254
00:16:15,120 --> 00:16:18,320
that Miss Maxwell was involved in sexual abuse of miners,

255
00:16:18,559 --> 00:16:24,039
sexual trafficking, or production or possession of child pornography. Joseph

256
00:16:24,080 --> 00:16:27,200
Riccary served as the lead detective from the Palm Beach

257
00:16:27,200 --> 00:16:32,080
Police Department charged with investigating Jeffrey Epstein example GG AT ten.

258
00:16:32,720 --> 00:16:36,799
That investigation commenced in two thousand and five. Riccary worked

259
00:16:36,840 --> 00:16:39,759
only on the Epstein case for an entire year. He

260
00:16:39,840 --> 00:16:44,919
reviewed previous officer's reports and interviews, conducted numerous interviews of

261
00:16:44,960 --> 00:16:49,519
witnesses and alleged victims, himself, reviewed surveillance footage of the

262
00:16:49,519 --> 00:16:53,480
Epstein home, participated in and had knowledge of the search

263
00:16:53,519 --> 00:16:57,679
warrant executed on the Epstein home, and testified regarding the

264
00:16:57,720 --> 00:17:02,320
case before the Florida State Grand Jerry against Epstein. Detective

265
00:17:02,399 --> 00:17:06,880
Rickerrey's investigation revealed that not one of the alleged Epstein

266
00:17:07,000 --> 00:17:10,599
victims ever mentioned Miss Maxwell's name, and she was never

267
00:17:10,680 --> 00:17:14,519
considered a suspect by the government. None of Epstein's alleged

268
00:17:14,559 --> 00:17:17,839
victims said they had seen miss Maxwell at Epstein's house,

269
00:17:18,039 --> 00:17:21,119
nor said they had been recruited by her, nor paid

270
00:17:21,160 --> 00:17:24,000
any money buyer, nor told what to wear or how

271
00:17:24,000 --> 00:17:27,920
to act buyer. Indeed, none of Epstein's alleged victims ever

272
00:17:28,000 --> 00:17:30,920
reported to the government they had ever met or spoken

273
00:17:31,039 --> 00:17:34,920
to Miss Maxwell. Maxwell was not seen coming or going

274
00:17:35,160 --> 00:17:38,759
from the house during the law enforcement surveillance of Epstein's home.

275
00:17:39,240 --> 00:17:42,519
The arrest warrant did not mention Miss Maxwell, and her

276
00:17:42,640 --> 00:17:46,440
name was never mentioned before the grand jury. No property

277
00:17:46,480 --> 00:17:51,079
belonging to Maxwell, including sex toys or child pornography, was

278
00:17:51,119 --> 00:17:54,720
seized from Epstein's home during execution of the search warrant

279
00:17:55,240 --> 00:17:59,079
IDEA two fifty seven. Detective Roccari, when asked to describe

280
00:17:59,119 --> 00:18:02,720
everything that you believe you know about Klene Maxwell's sexual

281
00:18:02,759 --> 00:18:07,079
trafficking conduct, replied, I don't IDEA two seventy eight. He

282
00:18:07,119 --> 00:18:10,599
confirmed that he had no knowledge about Miss Maxwell's sexually

283
00:18:10,640 --> 00:18:15,559
trafficking anybody. Detective Raccari also has no knowledge of Plaintiff's

284
00:18:15,599 --> 00:18:21,000
conduct that is subject of this lawsuit. Reply. Plaintiff offers

285
00:18:21,039 --> 00:18:24,640
several misleading contrary facts, none of which actually address the

286
00:18:24,680 --> 00:18:28,880
facts presented herein namely, whether Miss Maxwell was ever mentioned

287
00:18:28,880 --> 00:18:31,799
by any of Epstein's alleged victims, whether she was the

288
00:18:31,839 --> 00:18:35,400
target of their investigation, and whether any of her property

289
00:18:35,480 --> 00:18:39,799
was seized from Epstein's home. Plaintiff cites to numerous inadmissible

290
00:18:39,799 --> 00:18:44,440
pieces of evidence on facts other than those. Mister Rodriguez,

291
00:18:44,559 --> 00:18:48,480
a convicted felon for obstructing justice related to the Epstein case,

292
00:18:48,839 --> 00:18:52,200
is dead and his deposition testimony is the subject of

293
00:18:52,200 --> 00:18:55,880
emotion in le Mean because Miss Maxwell has never had

294
00:18:55,920 --> 00:18:59,480
the opportunity to cross examine them Document five p. Sixty

295
00:18:59,519 --> 00:19:03,480
seven at five fourteen. Miss Rebello, likewise, is not a

296
00:19:03,519 --> 00:19:06,880
witness who has been deposed in this case, and therefore

297
00:19:07,000 --> 00:19:11,000
her testimony is not admissible against Miss Maxwell. The message

298
00:19:11,000 --> 00:19:14,440
pads are not authenticated by anyone, as will be the

299
00:19:14,440 --> 00:19:17,799
subject of a forthcoming motion in le Mean, and there

300
00:19:17,880 --> 00:19:21,039
is not one shred of evidence that any child pornography,

301
00:19:21,319 --> 00:19:24,119
as opposed to a topless photo of a very adult

302
00:19:24,119 --> 00:19:28,279
Miss Maxwell, wherever found in Epstein's home. The fact should

303
00:19:28,319 --> 00:19:32,240
be deemed admitted, as those proffered by defendant are based

304
00:19:32,279 --> 00:19:37,119
on admissible evidence. Number forty nine undisputed Fact forty nine.

305
00:19:37,400 --> 00:19:40,640
No nude photograph of plaintiff was displayed in Epstein's home.

306
00:19:40,839 --> 00:19:45,759
Epstein's housekeeper, Juana Lessi, never saw any photographs of Virginia

307
00:19:45,839 --> 00:19:50,079
Roberts in mister Epstein's house. Detective Raccari entered Epstein's home

308
00:19:50,279 --> 00:19:53,119
in two thousand and two to install security cameras to

309
00:19:53,160 --> 00:19:56,680
catch a thief, and did not observe any child pornography

310
00:19:56,920 --> 00:20:02,400
within the home, including on Epstein's desk in his office. Reply,

311
00:20:02,799 --> 00:20:05,839
plaintiff offered no evidence that a nude photograph of her

312
00:20:06,240 --> 00:20:09,359
was displayed in Epstein's home. All of the testimony she

313
00:20:09,440 --> 00:20:12,960
submits has nothing to do with the nude photograph of herself.

314
00:20:13,240 --> 00:20:17,599
The fact should be deemed admitted fifty undisputed Fact fifty.

315
00:20:17,960 --> 00:20:21,839
Plaintiff intentionally destroyed her journal and dream journal regarding her

316
00:20:21,880 --> 00:20:25,960
memories of this case. In twenty eleven, while represented by council,

317
00:20:26,559 --> 00:20:30,799
Plaintiff drafted a journal describing individuals to whom she claimed

318
00:20:30,839 --> 00:20:33,519
she was sexually trafficked, as well as her memories and

319
00:20:33,599 --> 00:20:38,759
thoughts about her experiences with Epstein. In twenty thirteen, she

320
00:20:38,799 --> 00:20:42,039
and her husband created a bonfire in her backyard in

321
00:20:42,079 --> 00:20:45,599
Florida and burned the journal together with other documents in

322
00:20:45,640 --> 00:20:50,000
her possession. Plaintiff also kept a dream journal regarding her

323
00:20:50,000 --> 00:20:54,400
thoughts and memories that she possessed in January twenty sixteen.

324
00:20:55,640 --> 00:21:00,319
To date, Plaintiff cannot locate the dream journal. Reply. Tiff

325
00:21:00,319 --> 00:21:04,759
offers no contrary, admissible evidence regarding her destruction of her journal,

326
00:21:04,880 --> 00:21:08,640
and it should be deemed admitted. Fifty one undisputed fact

327
00:21:08,720 --> 00:21:12,880
Number fifty one. Plaintiff publicly peddled her story beginning in

328
00:21:12,920 --> 00:21:17,599
two thousand and one. Plaintiff granted journalist Sharon Churchier extensive

329
00:21:17,599 --> 00:21:21,960
interviews that resulted in seven widely distributed articles. From March

330
00:21:22,000 --> 00:21:27,920
twenty eleven through January twenty fifteen, Churcher regularly communicated with

331
00:21:28,000 --> 00:21:31,799
plaintiff and her attorneys or other agents. From early twenty

332
00:21:31,880 --> 00:21:36,119
eleven to the present day, Plaintiff received approximately one hundred

333
00:21:36,119 --> 00:21:39,119
and sixty thousand dollars for her stories and pictures that

334
00:21:39,160 --> 00:21:44,880
were published by many news organizations. Reply, Plaintiff offers no

335
00:21:44,960 --> 00:21:48,319
evidence to contradict the facts asserted, and they should therefore

336
00:21:48,400 --> 00:21:53,279
be deemed admitted. Plaintiff's unsupported spin of those facts should

337
00:21:53,319 --> 00:21:58,440
be stricken undisputed Fact fifty two. Plaintiff drafted a one

338
00:21:58,519 --> 00:22:03,440
hundred and forty four page, reportedly autobiographical book manuscript in

339
00:22:03,440 --> 00:22:08,240
twenty eleven, which she actively sought to publish. In twenty eleven,

340
00:22:08,480 --> 00:22:13,240
contemporaneous with her Churcher interviews, Plaintiff drafted a book manuscript

341
00:22:13,440 --> 00:22:18,200
which purported to document plaintiff's experiences as a teenager in Florida,

342
00:22:18,559 --> 00:22:23,680
including her interactions with Epstein and Maxwell. Plaintiff communicated with

343
00:22:23,839 --> 00:22:28,759
literary agents, ghostwriters, and potential independent publishers in an effort

344
00:22:28,799 --> 00:22:32,440
to get her book published. She generated marketing materials and

345
00:22:32,480 --> 00:22:37,279
circulated those, along with book chapters to numerous individuals associated

346
00:22:37,319 --> 00:22:42,200
with publishing and the media. Reply Plaintiff sites in admissible

347
00:22:42,240 --> 00:22:46,079
evidence and attorney argument in contradiction of these facts, they

348
00:22:46,119 --> 00:22:50,480
should be ignored. The victim notification letter is inadmissible hearsay.

349
00:22:50,920 --> 00:22:56,039
The psychologist's record likewise are inadmissible hearsay. The FBI interview

350
00:22:56,319 --> 00:23:01,240
is inadmissible hearsay. Plaintiff's council then flatly misrepresents to the

351
00:23:01,279 --> 00:23:05,240
court her own client's characterizations of the book manuscript, calling

352
00:23:05,319 --> 00:23:09,799
it a fictionalized account. Plaintiff contradicting her council testified that

353
00:23:09,880 --> 00:23:13,920
the book manuscript is ninety nine percent true. Question is

354
00:23:13,960 --> 00:23:16,480
there anything Well, first of all, did you author the

355
00:23:16,640 --> 00:23:20,720
entire manuscript? Answer? Yes, I did. Question did anyone else

356
00:23:20,799 --> 00:23:24,240
author part of that manuscript? Answer? Do you mean did

357
00:23:24,240 --> 00:23:29,160
anyone else write this with me? Question? Right? Answer? No, question,

358
00:23:29,240 --> 00:23:33,160
that's all you're writing. Answer this is my writing. Question okay,

359
00:23:33,200 --> 00:23:35,960
to the best of your recollection as you sit here today,

360
00:23:36,440 --> 00:23:39,319
Is there anything in that manuscript about Glenn Maxwell that

361
00:23:39,440 --> 00:23:43,160
is untrue? Answer? I don't believe so. Like I said,

362
00:23:43,440 --> 00:23:45,319
there is a lot of stuff that I actually left

363
00:23:45,359 --> 00:23:50,000
out of here. Question mm hmm. Answer, So there is

364
00:23:50,039 --> 00:23:52,480
a lot more information I could put in there, But

365
00:23:52,559 --> 00:23:55,240
as far as Glean Maxwell goes, I would say that

366
00:23:55,279 --> 00:23:57,480
there is ninety nine percent of it would be the

367
00:23:57,519 --> 00:24:01,119
correct knowledge. Question all right, is there anything that you

368
00:24:01,440 --> 00:24:03,880
and I understand that you're doing this from memory? Is

369
00:24:03,880 --> 00:24:06,759
there anything that you recall as you're sitting here today

370
00:24:06,960 --> 00:24:09,799
about Glayton Maxwell that is contained in the manuscript that

371
00:24:09,920 --> 00:24:12,960
is not true? Answer? You know, I haven't read this

372
00:24:13,000 --> 00:24:15,359
in a very long time. I don't believe that there's

373
00:24:15,440 --> 00:24:18,279
anything in there about Glayne Maxwell that is not true.

374
00:24:19,440 --> 00:24:22,720
Plaintiff clearly now would like to spin the book manuscript

375
00:24:23,000 --> 00:24:25,799
as fictionalized, because she is well aware that the facts

376
00:24:25,799 --> 00:24:30,079
presented by her in that manuscript are contradicted by many

377
00:24:30,119 --> 00:24:34,799
other documentary and testimonial records. Yet she offers no admissible

378
00:24:34,839 --> 00:24:39,720
evidence that plaintiff intended the manuscript to be fictional. Citations

379
00:24:39,759 --> 00:24:42,839
the social scientists, who have not testified in this case

380
00:24:43,039 --> 00:24:45,799
and whose work has not been cited by any expert

381
00:24:45,920 --> 00:24:49,039
in this case, is wholly improper and should be stricken.

382
00:24:49,960 --> 00:24:55,759
Number fifty three. Plaintiff publicly filed lurid cvra pleadings, initiated

383
00:24:55,759 --> 00:24:59,920
a media frenzy and generated highly publicized litigation between A

384
00:25:00,119 --> 00:25:05,240
lawyers and Alan Dershowitz. On December thirtieth, twenty fourteen, Plaintiff,

385
00:25:05,279 --> 00:25:09,079
through Council, publicly filed a jointerer motion that contained her

386
00:25:09,160 --> 00:25:14,000
Lurid allegations about Miss Maxwell and many others, including Alan Dershowitz,

387
00:25:14,039 --> 00:25:17,359
Prince Andrew, and Jean lu Brunel. The joined Her motion

388
00:25:17,559 --> 00:25:21,680
was followed by a corrected motion and two further declarations

389
00:25:21,720 --> 00:25:26,720
in January and February twenty fifteen, which repeated many of

390
00:25:26,759 --> 00:25:31,680
Plaintiff's claims. These cvra pleadings generated a media maelstrom and

391
00:25:31,759 --> 00:25:36,480
spawned highly publicized litigation between plaintiff's lawyers Edwards En Cassel

392
00:25:36,880 --> 00:25:41,559
and Alan Dershowitz. After plaintiff publicly alleged mister Dershowitz of

393
00:25:41,680 --> 00:25:46,400
sexual misconduct, mister Dershowitz vigorously defended himself in the media.

394
00:25:46,839 --> 00:25:49,559
He called plaintiff a liar and accused her lawyers of

395
00:25:49,640 --> 00:25:54,519
unethical conduct. In response, attorneys Edwards En Cassel sued Dershowitz,

396
00:25:54,559 --> 00:25:59,079
who counterclaimed. This litigation in turn caused additional media attention

397
00:25:59,400 --> 00:26:05,519
by national and international media organizations. Reply, plaintiff offers no

398
00:26:05,599 --> 00:26:09,519
contrary facts and so they should be deemed admitted. Number

399
00:26:09,559 --> 00:26:14,240
fifty four undisputed Fact fifty four Plaintiff formed non profit

400
00:26:14,319 --> 00:26:18,200
Victims Refuse Silence to attract publicity and speak out on

401
00:26:18,279 --> 00:26:22,640
a public controversy. In twenty fifteen, Plaintiff, with the assistance

402
00:26:22,839 --> 00:26:26,880
of the same council, formed the non profit organization Victims

403
00:26:26,920 --> 00:26:30,839
Refuse Silence. According to plaintiff, the purpose of the organization

404
00:26:31,240 --> 00:26:34,920
is to promote Plaintiff's profess cause against sex slavery. The

405
00:26:34,960 --> 00:26:39,000
stated goal of her organization is to help survivors surmount

406
00:26:39,000 --> 00:26:43,400
the shame, silence, and intimidation typically experienced by victims of

407
00:26:43,440 --> 00:26:48,480
sexual abuse. Plaintiffs attempts to promote victims refuse silence at

408
00:26:48,599 --> 00:26:53,400
every opportunity. For example, plaintiff participated in an interview in

409
00:26:53,480 --> 00:26:56,319
New York with ABC to promote the charity and to

410
00:26:56,319 --> 00:27:01,759
get our mission out to the public. Reply Plaintiff offers

411
00:27:01,799 --> 00:27:06,039
no contrary evidence, and the facts should be deemed admitted. Two,

412
00:27:06,319 --> 00:27:10,119
the court should strike plaintiff's statement of undisputed facts. The

413
00:27:10,160 --> 00:27:13,920
summary judgment procedure is well established. When the summary judgment

414
00:27:14,000 --> 00:27:16,799
non movement bears the burden of proof at trial, as

415
00:27:16,839 --> 00:27:19,720
in the case at Bar, the movement may show a

416
00:27:19,759 --> 00:27:24,480
prima facie entitlement for summary judgment in one of two ways.

417
00:27:24,519 --> 00:27:27,640
The movement may point to evidence that negates the non

418
00:27:27,640 --> 00:27:32,000
movement's claims, or two, the movement may identify those portions

419
00:27:32,160 --> 00:27:36,000
of its opponent's evidence that demonstrate the absence of a

420
00:27:36,079 --> 00:27:40,880
genuine issue of material fact salahudin versus Gored four sixty

421
00:27:40,960 --> 00:27:44,440
seven f. Dot three D two sixty three, two seventy

422
00:27:44,519 --> 00:27:47,559
two and seventy three, Second Circuit, two thousand and six.

423
00:27:48,240 --> 00:27:51,279
If the movement makes the showing in either manner, the

424
00:27:51,319 --> 00:27:54,839
burden shifts to the non movement to identify record evidence

425
00:27:54,920 --> 00:27:58,960
creating a genuine issue of material fact. Local Civil Rule

426
00:27:59,000 --> 00:28:02,160
fifty six dot one A carries out this summary judgment

427
00:28:02,240 --> 00:28:06,039
procedure by requiring the summary judgment movement to set forth

428
00:28:06,279 --> 00:28:09,720
material facts as to which she contends that there is

429
00:28:09,759 --> 00:28:13,240
no genuine issue to be tried. Subsection B of the

430
00:28:13,319 --> 00:28:16,839
rule requires the party opposing some rejudgment to set forth

431
00:28:16,839 --> 00:28:20,200
the statement of additional material facts as to which it

432
00:28:20,279 --> 00:28:23,640
is contended that there exists a genuine issue to be tried.

433
00:28:24,400 --> 00:28:27,720
Miss Maxwell has moved for some rejudgment. Plaintiff has not

434
00:28:28,839 --> 00:28:32,559
as movement. Miss Maxwell is required under Local Civil Rule

435
00:28:32,640 --> 00:28:35,400
fifty six y one to enumerate the fact she is

436
00:28:35,440 --> 00:28:40,000
asserting as undisputed. As the party opposing some rejudgment, Plaintiff

437
00:28:40,079 --> 00:28:44,319
is permitted if she can to introduce admissible evidence creating

438
00:28:44,319 --> 00:28:48,599
a genuine issue a material fact see fed R Siev

439
00:28:49,240 --> 00:28:54,000
fifty six C. And one plaintiff is confused. Plaintiff believes

440
00:28:54,000 --> 00:28:57,880
she the party opposing some rejudgment, must enumerate facts she

441
00:28:58,000 --> 00:29:01,440
is asserting as undisputed, and so she has submitted her

442
00:29:01,480 --> 00:29:05,160
own rule fifty six to one statement of undisputed facts

443
00:29:05,599 --> 00:29:10,079
that gets a summary judgment procedure exactly backwards. Plaintiff's undisputed

444
00:29:10,119 --> 00:29:14,599
facts are irrelevant. Plaintiff cannot avoid some rejudgment by proposing

445
00:29:14,799 --> 00:29:18,119
undisputed facts. She may only do so by creating a

446
00:29:18,160 --> 00:29:21,839
genuine issue of material fact as to Miss Maxwell's statement

447
00:29:22,160 --> 00:29:26,599
of undisputed facts. Accordingly, this Court should strike Plaintiff's statement

448
00:29:26,920 --> 00:29:31,400
of undisputed facts. Although Miss Maxwell, as a summary judgment movement,

449
00:29:31,720 --> 00:29:35,400
has no duty to respond to plaintiffs alleged undisputed facts,

450
00:29:35,680 --> 00:29:38,880
we hasten to add that Miss Maxwell in fact opposes

451
00:29:39,119 --> 00:29:43,799
and disputes most of Plaintiff's alleged undisputed facts. For example,

452
00:29:44,160 --> 00:29:48,440
defendants undisputed Fact forty includes the statement Miss Roberts is

453
00:29:48,480 --> 00:29:51,319
hired as a seasonal SPA attendant to work at the

454
00:29:51,400 --> 00:29:53,680
mar A Lago club in the fall of two thousand,

455
00:29:53,960 --> 00:29:57,359
after she had turned seventeen. Yet Plaintiffs sets forth in

456
00:29:57,400 --> 00:30:00,519
our own Undisputed Fact fifty eight that Vergil Guina got

457
00:30:00,559 --> 00:30:03,119
a job at mar A Lago in two thousand, either

458
00:30:03,160 --> 00:30:07,440
months before or just after her seventeenth birthday. Plaintiff has

459
00:30:07,440 --> 00:30:10,640
done nothing more than set forth her dispute with defendant

460
00:30:11,039 --> 00:30:14,799
undisputed fact forty as her own undisputed fact, it makes

461
00:30:14,839 --> 00:30:19,039
no sense. See also Plaintiff's undisputed fact sixty three. The

462
00:30:19,200 --> 00:30:23,160
other alleged undisputed facts are simply plaintiff's assertion of her

463
00:30:23,200 --> 00:30:26,880
deposition testimony and hearsay of her statements to other witnesses

464
00:30:27,200 --> 00:30:32,480
couched as undisputed facts. Miss Maxwell strenuously disputes almost all

465
00:30:32,480 --> 00:30:36,359
of the alleged undisputed facts, claiming that she engaged in

466
00:30:36,440 --> 00:30:40,440
any sort of sexual acts, misconduct, or communication with plaintiff

467
00:30:40,599 --> 00:30:43,720
or others. Indeed, over the course of two days and

468
00:30:43,839 --> 00:30:48,480
thirteen hours of deposition, Miss Maxwell disputed all such allegations.

469
00:30:49,039 --> 00:30:52,400
Because none of Plaintiff's undisputed facts have anything to do

470
00:30:52,480 --> 00:30:56,000
with the issues raised by Defendant's motion for some rejudgment,

471
00:30:56,200 --> 00:31:00,000
Miss Maxwell moves to strike Plaintiff's statement of undisputed facts

472
00:31:00,640 --> 00:31:04,440
conclusion for the foregoing reasons. Miss Maxwell requests that the

473
00:31:04,480 --> 00:31:07,640
Court deem her undisputed facts admitted, and that the Court

474
00:31:07,720 --> 00:31:12,599
strikes plaintiff statement of undisputed facts. This was signed on

475
00:31:12,720 --> 00:31:16,200
February tenth of twenty seventeen, and it was signed by

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Laura Meninger. All right, folks, that's going to do it

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for this one. All of the information that goes with

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this episode can be found in the description box