Speaker 1: What's up, everyone, and welcome back to the Epstein Chronicles.
In this episode, we're going to dive into some more
court documents and we're going to start taking a look
at Klaine Maxwell's reply to Virginia Roberts disputing her soul
called undisputed facts. So let's get busy. Case number fifteen
DASH CV DASH zero seven four three three DASH RWs
Virginia Roberts versus Gallayne Maxwell. The defendants replied a plaintiff
Statement of contested facts and Plaintiff's undisputed facts pursuing to
Local Civil Rule fifty six dot one. Pursuing to Rule
fifty six point one of the local Civil Rules of
this Court, Defendant Gallain Maxwell submits this reply to a
plaintiff Statement of contested Facts and Plaintiff's undisputed facts Response
Document five eighty six DASH one Introduction. Plaintiff's response fails
under both the federal rules of evidence and the local
civil rules of proceidure. First, plaintiff largely failed to provide
any citation to evidence which would be admissible to challenge
defendant statement of material undisputed facts, and therefore miss Maxwell's
undisputed facts should be deemed admitted. Second, rather than set
forth additional material facts as to which it is contended
that there exists a genuine issue to be tried Local
Civil Rule fifty six Dot one B, Plaintiff instead set
forth her own purportedly undisputed facts. Because plaintiff did not
cross move for some rejudgment, her supposedly undisputed facts are
not permitted by the rules and should be stricken Section one.
Miss Maxwell's reply in supportive statement of undisputed facts one
undisputed fact number one. In early twenty eleven, plaintiff, in
two British tabloid interviews, made numerous false and defamatory allegations
against Miss Maxwell. In the articles, plaintiff made no direct
allegations at Miss Maxwell was involved in any improper conduct
with Jeffrey Epstein, who had pleaded guilty in two thousand
and seven to procuring a minor for prostitution. Nonetheless, plaintiff
suggested that Miss Maxwell work with Epstein and may have
known about the crime for which he was convicted. Examples
A and B. Reply Plaintiffs cites no admissible evidence to
contest these undisputed facts. McAuley Example thirty four in an
email from Sharon Churchyard, a plaintiff. It is Miss Churcher's
hearsay and therefore inadmissible in any event. It does not
speak to the contents of Plaintiff's interviews with Churcher. McAuley declaration.
Example thirty one is an FBI interview, also in admissible hearsay,
which again does not describe plaintiff's interviews in news articles.
In the absence of contrary evidence, undisputed fact one should
be deemed admitted. Two undisputed fact number two. In the articles,
plaintiff alleged she had sex with Prince Andrew, a well
known businessman, a world renowned scientist, a respected liberal politician,
and a foreign head of state. Examples A through B
at five a reply. Plaintiff does not contest these facts,
and they therefore should be deemed admitted. Three undisputed fact three.
In response to the allegation, Miss Maxwell's British attorney, working
with mister Gow, issued a statement on March ninth, twenty eleven,
denying the various allegations about Miss Maxwell that have appeared
recently in the media. These allegations are entirely false. Example
C A reply Plaintiff denies that mister Barden issued a
statement but offers no admissible evidence to refute this point. Further,
she acknowledged that the statement was issued by Devonshire solicitors
mister Barden's law firm four undisputed fact four. The statement
read and full, London, March tenth, twenty eleven. Kallainne Maxwell
denies the various outlegy dellegations about her that have appeared
recently in the media. These allegations are entirely false. It
is unacceptable that letters sent by miss Maxwell's legal representatives
to certain newspapers pointing out the truth and asking for
the allegations to be withdrawn have simply been ignored. In
the circumstances, Miss Maxwell is now proceeding to take legal
action against those newspapers. I understand that newspapers need to
sell copies. It is well known that certain newspapers live
by the adage why let truth get in the way
of a good story. However, the allegations made against me
are abhorrent and are entirely untrue, and I ask that
they stop, said Glayne Maxwell. A number of newspapers have
shown a complete lack of accuracy in their reporting of
this story and a failure to carry out the most
elementary investigation or any real due diligence. I am now
taking action to clear my name, she said a reply.
Plaintiff does not dispute the contents of the twenty eleven statement,
and therefore it should be deemed admitted five undisputed Fact
number five Plaintiff's gratuitous and lurid accusations. In an unrelated action.
In two thousand and eight, to alleged victims of Epstein
brought an action under the Crime Victim's Rights Act against
the United States Government purporting to challenge Epstein's plea agreement.
They alleged that the government violated their CVR rights by
entering into an agreement example d at two. A reply
Plaintiff stipulates to the facts contained in paragraph five, and
therefore they should be deemed admitted number six undisputed fact
number six. Seven years later, on December thirtieth, twenty fourteen,
Miss Roberts moved to join the CVR action, claiming she
too had her CVR rights violated by the government. On
January first, twenty fifteen, Miss Roberts filed the corrected joinder
motion example d at one O nine reply plaintiff agreed
to this paragraph seven Undisputed Fact number seven. The issue
presented in her joint her motion was narrow whether she
should be permitted to join the CVRA action as a
party under Federal Rule of Civil Procedure twenty one, specifically
whether she was a known victim of mister Epstein and
the government owed them CVR duties. Yet, the bulk of
emotion consists of copious factual details that plaintiff and her
co movement would prove if allowed to join. Miss Roberts
gratuitously included provocative and lurid details of her alleged sexual
activities as an alleged victim of sexual trafficking. A reply,
plaintiff does not dispute that Judge Marra made the findings
detailed in Undisputed Fact seven. Further, she admits that the
government refused to stipulate that she had been sexually abused
by Jeffrey Epstein and his co conspirators, including co conspirator
Alan Dershowitz, which would make her a victim of a
broad set trafficking conspiracy. Although she now admits there were
other reasons for inclusion of such lurid details, those reasons
were rejected by Judge Mara, as she does not offer
any admissible evidence to contradict the findings made by Judge Marra.
This fact, specifically, Judge Mara's findings should be deemed admitted.
In any event, we request under Federal rule evid. Two
one c two that the Court take judicial notice of
the contents of Judge Mara's ruling and disorder number eight
undisputed fact number eight. At the time they filed the motion,
Miss Roberts and her lawyers knew that the media had
been following the Epstein criminal case and the CVR action.
While they deliberately filed the motion without disclosing Miss Robert's name,
claiming the need for privacy and secrecy, they made no
attempt to file the motion under seal. Quite the contrary,
they filed the motion publicly example d at one and one.
A reply. Plaintiff offers no admissible evidence to refute these facts,
and they therefore should be deemed admitted. Specifically, she does
not offer any evidence to dispute that she knew the
media had been following Epstein and the CVRA action, nor
does she dispute that her attorneys made no attempt to
file the motion under seal rather filing it publicly. The
facts are thus admitted number nine undisputed Fact number nine.
As the District Court noted in ruling on the joint
or motion, miss Roberts names several individuals, and she offers
details about the type of sex acts performed and where
they took place. The Court ruled that these lurid details
are unnecessary. The factual details regarding whom and where the
jane those engaged in sexual activities are immaterial and impertinent,
especially considering that these details involved non parties who were
not related to the respond in government. Accordingly, these unnecessary
details shall be stricken unstruck all of Miss Roberts's factual
allegations relating to her alleged sexual activities and her allegations
of misconduct by non parties. The Court said the striking
of the lurid details was the sanction for Miss Roberts
in proper inclusion of them in the motion. A reply
plaintiff offers no admissible evidence to refute these facts, and
they therefore should be deemed admitted see Reply to Undisputed
Fact seven, Supra. In any event, we request under Federal
rule of evidence two one C two that the Court
take judicial notice of the contents of Judge Marra's ruling
and disorder number ten undisputed Fact number ten. The District
Court found not only that the lurid details were unnecessary,
but also that the entire joinder motion was entirely unnecessary.
Miss Roberts and her lawyers knew the motion, with all
its lurid details was unnecessary because the motion itself recognized
that she would be able to participate as a fact
witness to achieve the same result she sought as a party.
The Court denied Plaintiff's joined or motion id at seven
through ten number eleven undisputed Fact number eleven. One of
the non parties Miss Roberts named repeatedly in the joinder
motion was Miss Maxwell. According to the lurid details of
Miss Roberts included in the motion, Miss Maxwell personally was
involved in a sexual abuse and a sex trafficking scheme
created by Epstein. Miss Maxwell approached plaintiff in nineteen ninety nine,
when plaintiff was fifteen years old, to a recruiter into
the scheme. Miss Maxwell was one of the main women
Epstein used to procure underage girls for sexual activities. Miss
Maxwell was a primary co conspirator with Epstein in his scheme.
She persuaded plaintiff to go to Ebstein's mansion in a
fashion very similar to the manner in which Epstein and
his other co conspirators coerced dozens of other children at
the mansion. When plaintiff began to giving Epstein a massage,
he and Miss Maxwell turned it into a sexual encounter. Epstein,
with the assistance of Miss Maxwell, converted plaintiff into a
sex slave. Plaintiff was a sex slave from about nineteen
ninety nine through two thousand and two. Miss Maxwell also
was a co conspirator in Epstein's sexual abuse. Miss Maxwell
appreciated the immunity she acquired under Epstein's plea agreement because
the immunity protected her from prosecution from the crimes she committed.
In Florida, Miss Maxwell participated in the sexual abuse of
plaintiff and others. Miss Maxwell took numerous sexually explicit pictures
of underage girls involved in sexual activities, including the plaintiff.
She shared those photos with Epstein as part of her
role in Epstein's sexual abuse ring. Miss Maxwell connected Epstein
with powerful individuals so that Epstein could traffic Plaintiff to
these persons. Plaintiff was forced to have sexual relations with
Prince Andrew in Miss Maxwell's apartment in London. Miss Maxwell
is illitated Plaintiff sex with Prince Andrew By acting as
a madam for Epstein. Miss Maxwell assisted in internationally trafficking
Plaintiff and numerous other young girls for sexual purposes. Plaintiff
was forced to watch Epstein, Miss Maxwell, and others engage
in illegal sexual acts with dozens of underage girls. Reply,
Plaintiff offers no admissible evidence to refute the facts actually
stated in the paragraph ie the lurid details as coined
by Judge Marra were included in her CVR jointer motion.
Plaintiff claims to offer admissible evidence to corroborate the statements
she made in the joint motion. Setting aside for the
moment that most of the cited documents are inadmissible hearsay
as address later, such evidence should be disregarded because none
of the offered documents speak to fact that these lurid
details were actually included in the jointer motion, as a
simple reading of example D reveals. Because Plaintiff does not
refute that point, the fact that the details were in
the jointer motion should be deemed admitted. In any event,
we request under Federal Rules of Evidence Tool one C
two that the Court take judicial notice of the contents
of Plaintiff's CVRA jointerer motion. What's up, everyone, and welcome
back to the Epstein chronicles. We're going to pick back
up with Glenn Maxwell's response to Virginia Roberts response to
Gleann Maxwell's undisputed facts number twelve. Undisputed fact number twelve
In the joint motion, plaintiff also alleged she was forced
to have sex with the Harvard professor Alan Dershowitz, model
scout Jean Luke Brunel, and many many other powerful men,
including numerous prominent American politicians, powerful business executives, foreign presidents,
a well known prime minister, and other world leaders. A reply, again,
plaintiff offers no evidence that these lurid details were included
in the joint motion, as indeed they were, and thus
the fact that they were should be deemed admitted. Thirteen
undisputed fact number thirteen. Plaintiffs said, after serving for four
years as a sex slave, she managed to escape to
a foreign country and hide out from Epstein and his
co conspirators for years. Reply, Plaintiff does not dispute that she
made the statement in her joint or motion, and it
is admitted number fourteen undisputed fact Number fourteen. Plaintiffs suggested
the government was part of Epstein's conspiracy when it secretly
negotiated a non prosecution agreement with Ebstein precluding federal prosecution
of Abstein and his co conspirators. The government secrecy, plaintiff alleged,
was motivated by its fear that plaintiff would raise powerful
objections to the agreement that would have shed tremendous public
light on Epstein and other powerful individuals. Reply. Plaintiff does
not contest the quoted contents of the joint or motion,
but rather offers argument regarding plaintiff's purported belief. Plaintiff did
not submit an affidavid attesting to such belief, and therefore
no admissible evidence was cited or offered. The facts should
therefore be deemed admitted fifteen undisputed fact number fifteen. Notably,
the other Jane Doe who joined plaintiff's motion, who alleged
she was sexually abused on many occasions by Epstein was
unable to corroborate any of Plaintiff's allegations, ideas seven to
eight reply. Plaintiff states the facts are untrue, but offers
no admissible evidence to support that statement. She has no
affidavid or other statement from the other Jane Doe, who
was represented by Plaintiff's council and therefore had the ability
to furnish such an avidavid. Indeed, Plaintiff acknowledges that the
other Jane Doe does not know Miss Roberts these facts
must be deemed admitted redacted, who is not the other
Jane Doe, is irrelevant to the undisputed fact asserted. She
also offers no corroboration of the same pattern of abuse,
and in fact does not remember any such facts as
already briefed see Document five sixty seven at twelve through
fourteen sixteen Undisputed Facts sixteen. Also, notably, in our multiple
and lengthy, consensual interviews with Miss Churcher three years earlier,
plaintiffs told Miss Churcher of virtually none of the details
she described in the joinder motion a reply Plaintiff's protestations,
aside the Churcher articles attached to Miss Churchers sworn Affidavid
filed in this case at document two sixteen and two
sixteen one through two sixteen and two eighteen failed to
include the vast majority of details included in plaintiffs CVRA
joined her motion as any side by side comparison will reveal.
Plaintiff's simple facile responses is that she did reveal details
in twenty eleven consistent with those in the joinder motion.
She offers no admissible evidence of these details she revealed
to Miss Churcher, instead citing to a heavily redacted interview
she purportedly gave to the FBI, not Miss Churcher. The
purported FBI report in itself is hearsay, not to mention,
redacted and prepared years after any supposed interview of plaintiff
mcaulay Declaration Example thirty one. Because plaintiff offers no admissible
evidence to contradict the discrepancies between the church Er articles
and the joint or motion, these facts should be deemed admitted.
Number seventeen undisputed Fact seventeen. Miss Maxwell's response to Plaintiff's
lurid accusations. The January twenty fifteen statement as plaintiff and
her lawyers expected before District Judge Mara in the CVRA
action could strike the lurid details of Plaintiff's allegation in
the joint or motion. Members of the media obtain copies
of the motion example g A reply Plaintiff cites no
contrary evidence and therefore the fact should be deemed admitted
eighteen undisputed Fact Number eighteen. At mister Barden's direction, on
January second, twenty fifteen, mister Gal sent to numerous representatives
of British media organizations an email containing a quotable statement
on behalf of Miss Maxwell. The email was sent to
more than six and probably less than thirty media representatives.
It was not sent to non media representatives. A reply
plaintiff disputes as blatant falsehood without admissible evidence, that it
was mister Barden who directed that the January second emails
be sent to media organizations. She then goes on to
quote the very section of mister Gal's deposition in which
he surmises but does not know indicated by his statement
it was his understanding that it was something that had
been sent to Maxwell by Barden. Indeed, mister Barden clears
up this confusion in his declaration, in which he unequivocally
swore number ten. In liaison with mister Goo and my client,
on January two, twenty fifteen, I prepared a further statement
denying the allegations, and I instructed mister Goo to transmit
it via email to members of the British media who
had made inquiry about Plaintiff's allegations about Miss Maxwell. Attached
as Exhibit A one is an email containing a true
and correct copy of this statement. The statement was issued
on my authority, although it is possible others suggested or
contributed content. I prepared the vast majority of the statement
and ultimately approved and adopted all of the statement as
my work. Ten. Mister Goal surmises as to how the
statement was forwarded to him and by whom, does not
controvert the sworn testimony of mister Bardon himself. Again, without
admissible evidence to the contrary, the facts must be deemed admitted.
With regard to the number of media representatives to whom
he sent the email, mister Gal testified it was between
six and thirty. His further testimony offered by plaintiff that
he spoke to over thirty journalists does not contradict that statement.
Nowhere does plaintiff offer testimony that he read the statement
to over thirty journalists. Instead, mister gal acknowledged it was
very possible that he had ever read the statement to
press or media over the phone, not that he read
it to over thirty journalists. Plaintiffs selective cutting and pasting
undercuts her so called evidence that the facts in paragraph
eighteen are false and thus they ought to be deemed
admissible nineteen undisputed fact number nineteen. Among the media representatives
were Martin Robinson of The Daily Mail, p Peachey of
The Independent, Nick Summerland of The Mirror, David Brown of
The Times and Nick Always and Joanne Pew of the BBC,
and David Mercer of the Press Association. These representatives were
selected based on their request after the jointer motion was
filed for a response from Miss Maxwell to Plaintiff's allegation
in the motion a reply. While plaintiff decries the second
sentence is false, her cited evidence contradicts her conclusion. Mister
Gau testified that anytime there was an incoming query, it
was either dealt with on the telephone by referring them
back to the two statements, or someone would email them
the statement, so no one was left unanswered McAuley declaration
example six. As his testimony makes clear, mister Gow sent
the statement to those journalists who made inquiry. He did
not send it to anyone who did not. Based on
the admissible evidence, this fact remains undisputed Number twenty. Undisputed
fact number twenty. The email to the media members read,
please find detached the quotable statement on behalf of Miss Maxwell.
No further communication will be provided by her on this matter.
Thanks for your understanding, Best Ross Jane Doe. Three is
Virginia Roberts, so not a new individual. The allegations aaid
by Victoria Roberts against Glainne Maxwell are untrue. The original
allegations are not new and have been fully responded to
and shown to be untrue. Each time the story is retold,
it changes with new salacious details about public figures and
world leaders. And now it is alleged by miss Roberts
that Alan Dershowitz is involved in having sexual relations with her,
which he denies. Miss roberts claims are obvious lies and
should be treated as such and not publicized as news
as they are defamatory Glaine Maxwell's original response to the
lies and defamatory claims remains the same. Maxwell strongly denies
allegations of an unsavory nature which have appeared in the
British press and elsewhere, and reserves her right to seek
redress at the repetition of such old defamatory claims. Reply
Plaintiff does not dispute the contents of the email, and
therefore it should be deemed admitted. Twenty one undisputed fact
number two twenty one. Mister Barden, who prepared the January
twenty fifteen statement, did not intend it as a traditional
press release solely to disseminate information to the media, so
he intentionally did not pass it through a public relations
firm such as mister Gal's firm Acuity Reputation. Reply Plaintiff
makes two responses as to the first sentence. She asserts,
without evidentiary support, the court should not consider the Barton declaration.
This argument is frivolous for the reasons given on pages
eight eleven and twelve and eighteen nineteen of reply brief
in support of motion for some rejudgment. It is a
declaration provided by an attorney with knowledge of the facts
mister Barden disclosed by defendant in a rule twenty six
witnesses whom Plaintiff chose not to depose. As to the
second sentence, Plaintiff offers two pieces of evidence which she
argues disputes the facts in question. They do not that
mister Gal forwarded this statement prepared by mister Barden to
the media is not disputed. Rather, as mister Barden asserted
in his declaration, and Plaintiff failed to cite contradictory evidence,
he was the one who prepared the vast majority of
the statement and instructed mister Goo to transmit it via
email to members of the British media. He likewise averse
that he did not intend the January twenty fifteen statement
as a traditional press release solely to disseminate information to
the media. This is why I intentionally did not request
that mister Gow or any other public relations specialists prepare
or participate in preparing the statement. Plaintiff fails to contradict
mister barden sworn statement undisputed Fact number twenty two. The
January twenty fifteen statement served two purposes. First, mister Barden
intended that it mitigate the harm to miss Maxwell's reputation
from the press republication of plaintiff's false allegations. He believed
these ends could be accomplished by suggesting to the media that,
among other things, they should subject plaintiff's allegations to inquiry
and scrutiny. For example, he noted in the statement that
plaintiff's allegations change dramatically over time, suggesting that their obvious
lies and therefore should not be publicized as news. Reply,
this paragraph, eliciting mister Barden's intent, is uncontroverted by plaintiff.
She fails to cite any contradictory admissible evidence, instead making
legal arguments. Her arguments are not admissible evidence e g.
It is her statement, and she directed that it be
sent to the media in public lacks any citation to
record evidence. Plaintiff's list of evidence, she contends corroborates. Plaintiff's
claims should be ignored as they do not pertain to
mister Barden's purposes. In drafting the January second statement number
twenty one undisputed fact number twenty one, mister Barden, who
prepared the January twenty fifteen statement, did not intend it
as a traditional press ReLU solely to disseminate information to
the media, so he intentionally did not pass it through
the public relations firm, such as mister Gal's firm Acuity Reputation.
Reply Plaintiff makes two responses. As to the first sentence,
she asserts, without evidentiary support, that the Court should not
consider the Barden declaration. This argument is frivolous for the
reasons given on page eight, eleven, twelve, eighteen, and nineteen
of the reply brief in support of motion for a
summary judgment. It is a declaration provided by an attorney
with knowledge of the facts mister Barden disclosed by the
defendant in her rule twenty six witnesses whom Plaintiff chose
not to depose. As to the second sentence, Plaintiff offers
two pieces of evidence which she argues disputes the facts
in question. They do not that mister Gal forwarded the
statement prepared by mister Barton to the media is not disputed. Rather,
as mister Barden asserted in his declaration, and Plaintiff failed
to cite contradictory evidence, he was the one who prepared
the vast majority of the statement and instructed mister Goo
to transmit it via email to members of the British media.
Example at ten, he likewise avers that he did not
intend the January twenty fifteen statement as a traditional press
release solely to disseminate information to the media, and this
is why I intentionally did not request that mister Goo
or any other public relations specialist prepare or participate in
preparing the statement. Plaintiff fails to contradict mister Barden's sworn
statement number twenty two Undisputed fact number twenty two. The
January twenty fifteen statement served two purposes. First, mister Bardon
intended that it mitigate the harm to Miss Maxwell's reputation
from the press's republication of plaintiff's false allegations. He believed
these ends could be accomplished by suggesting to the media that,
a along other things, they should subject plaintiff's allegations to
inquiry and scrutiny. For example, he noted in the statement
that plaintiff's allegations change dramatically over time, suggesting that their
obvious lies and therefore should not be publicized as news. Reply,
this paragraph, eliciting mister Barton's intent, is uncontroverted by plaintiff,
she fails to cite any contradictory admissible evidence, instead making
legal arguments. Her arguments are not admissible evidence e g.
It is her statement, and she directed that it be
sent to the media and public lacks any citation to
record evidence. Plaintiff's list of evidence, she contends corroborates Plaintiff's claims,
should be ignored as they do not pertain to mister
Bardon's purposes. In drafting the January second statement Undisputed Fact
Number twenty three second, mister Bardon intended the January twenty
fifteen statement to be a shot across the bow the media,
which he believed had been unduly eager to publish plaintiff's
allegations without conducting an inquiry of their own. Accordingly the statement,
he repeatedly noted that plaintiff's allegations were defamatory in this sense.
The statement was intended as a cease and assist letter
to the media recipients, letting the media recipients understand the
seriousness with which Miss Maxwell considered the publication of plaintiff's
obviously false allegations and the legal indefensibility of their own conduct.
Reply again Plaintiff disputes mister Barton's intent without citation to
record evidence. Plaintiff claims that Barden did not note anything
in the statement, but the statement itself contains the phrase
Miss Roberts claims or obvious lies and should be treated
as such and not publicized as news as their defamatory
Plaintiff's unsupported arguments should be ignored, and these facts pertaining
to mister Bardon's intent deemed admitted Fact number twenty four
Consistent with two purposes. Mister Gal's emails preface the statement
with the following language please find attached to quotable statement
on behalf of Miss Maxwell. The statement was intended to
be a single, one time only, comprehensive response quoted in
full to Plaintiff's December thirtieth, twenty fourteen allegations that would
give the media Miss Maxwell's response. The purpose of the
preparatory statement was to inform the media recipients of this
intent reply. Plaintiff again disputes any statement related to mister
Barden's purpose or intent, but offers no evidence contradicting his
purpose or intent. She simply points out that Miss Maxwell
retained mister Goo in early twenty fifteen, and that he
works for a public relations firm which is non responsive
to the fact that issue mister Bardon's intent with respect
to language included in the statement. No one is contested
that it was mister Gow who actually forwarded this statement
to select members of the media who had requested a response.
The facts that fourth should be deemed admitted undisputed. Fact
number twenty five. Plaintiff's activities bring light to the rights
of victims of sexual abuse. Plaintiff has engaged in numerous
activities to bring attention to herself, to the prosecution and
punishment of wealthy individuals such as Apstein, and to her
claimed interest of bringing light to the rights of victims
of sexual abuse. Reply Plaintiff offers no evidence to dispute
the facts cited, and so they should be deemed admitted. Undisputed.
Fact twenty six. Plaintiff created an organization, Victims Refuse Silence, Incorporated,
a Florida corporation, directly related to her alleged experience as
a victim of sexual abuse. Reply Plaintiff does not dispute
this statement. Twenty seven undisputed Fact number twenty seven. The
goal of Victims Refused silence was and continues to be
to help survivors surmount the shame, silence, and intimidation typically
experienced by victims of sexual abuse. Towards this end, Plaintiff
has dedicated her professional life to helping victims of sexual trafficking.
Reply Plaintiff agrees twenty eight undisputed fact Number twenty eight.
Plaintiff repeatedly has sought out media organizations to discuss her
alleged experience as a victim of sexual abuse. This reply
statement at fifty one through fifty four and two through eleven,
and referenced and exhibits Document two sixty one, two two
sixteen and example n kk L and MM Reply. Plaintiff
denies this contention, points to an email from Sharon Churcher
seeking to interviewer, and asserts that it was the media
that sought her out the weight of evidence cited by
defendant at paragraphs fifty one through fifty four. In addition,
the plaintiff's own documents belie this assertion. She d through
her attorneys, sought out a videotaped interview with ABC News.
She sent her book manuscript to publishers and literary agents,
and expressed anticipation and frustration that her exclusive contract with
the Mail prevented her for a period of time from
marketing her a book. Plaintiff disputed none of these activities
she freely engaged in for years, and thus these facts
should be admitted. Twenty nine. On December thirtieth, twenty fourteen,
plaintiff publicly filed an entirely unnecessary joined her motion laden
with unnecessary lurid details about being sexually abused as a
minor victim by wealthy and famous men and being trafficked
all over the world as a sex slave. Reply. Plaintiff
argues that her lurid details were necessarily legal. Judge Mora, however,
has already held that they were not, and her legal arguments,
unsupported by any actual evidence in this case, cannot serve
to controvert his findings. As quoted thirty, the plaintiff's alleged
purpose in filing the jointer motion was to vintigate her
rights under the CVRA. Exposed the government secretly negotiated non
prosecution agreement with Epstein, shed tremendous public light on Epstein
and other powerful individuals that would undermine the agreement and
support the cvra's Plaintiff's request for documents that would show
how Epstein used as powerful political and social connections to
secure a favorable plea deal and the government's motive to
hate Epstein and his co conspirators. Example d At one,
six and seven, and ten. Reply Plaintiff fails to offer
any evidence to controvert the contents of her CVRA joined
her motion, and thus the fact should be deemed admitted.
Number thirty one undisputed Fact Number thirty one Plaintiffs written
the manuscript of a book she has been trying to publish,
detailing her alleged experience as a victim of sexual abuse
and sex trafficking in Epstein's alleged scheme. Reply Plaintiff directs
the court to her response to paragraph fifty two and
suggests the factual statement is misleading. She, however, offers no
contradictory admissible evidence, and thus the fact should be deemed admitted.
Thirty two undisputed Fact thirty two republication alleged by plaintiff.
Plaintiff was required by interrogatory number six to identify any
false statements attributed to miss Maxwell that were published globally,
including within the Southern District of New York, as plaintiff alleged,
and paragraph nine of count one of her complaint. In response,
Plaintiff identified the January twenty fifteen statement and nine instances
in which various news media published portions of the January
twenty fifteen statement in news articles or broadcast stories reply
her arguments aside, Plaintiff offers no admissible evidence to controvert
the interrogatory request under a response which was limited to
nine instances in which the press published portions of the
January twenty fifteen statement. For example, plaintiff does not point
to one single news story that published the entirety of
the January twenty fifteen statement. In the absence of contrary evidence,
the fact should be deemed admitted. Thirty three. In none
of the nine instances was there any publication of the
entire January twenty fifteen statement. Reply. Plaintiff does not and
cannot point to any of the nine publications she disclosed
or any of the other publications that published the entire
January twenty fifteen statement, and this fact thus must be
deemed admitted. Thirty four. Miss maxwell Ender agents exercised no
control or authority over any media organization, including the media
identified in Plaintiff's response to interrogatory number six in connection
with the media's publication of portions of the January twenty
fifteen statement. Reply, plaintiff profited evidence. Testimony from mister Gal
fails to support her argument and fails to controvert the
Bardon declaration as cited by the defendant. Nothing in the
testimony establishes as plaintiff argues that the defendant hired Gal
because his position allowed him to influence the press to
publish her defamatory statement. The testimony is irrelevant to the
factual point. Gal's testimony at most relates to why Miss
Maxwell engaged mister Gal. It does not bear on the
factual point, ie that Miss Maxwell, mister Gal or mister
Barden did not exercise any control or authority over the
media in the media's republication of portions of the statement.
On this point, Plaintiff has failed to introduce any contrary evidence. Accordingly,
the fact should be deemed admitted. Thirty five Plaintiff's defamation
action against Miss Maxwell. Eight years after Epstein's guilty plea,
Plaintiff brought this action, repeating many of the allegations she
made in her CVR joined her motion. Reply Plaintiff agrees
thirty six. The complaint alleged that the January twenty fifteen
statement contained the following deliberate falsehoods. A that Roberts sworn
allegations against Maxwell are untrue. B that the allegations have
been shown to be untrue. C that Robert's claims are
obvious lies. A reply Plaintiff agreed thirty seven. Plaintiff lived
independently from her parents with her fiance long before meeting
Epstein or Maxwell. After leaving the Growing Together drug rehabilitation
facility in nineteen ninety nine, plaintiff moved in with the
family of a fellow patient, example l at seven and
eight and twelve through fourteen. There she met and became
engaged to her friend's brother, j James Michael Ostrich ID
at nineteen. She and Ostrich thereafter rented an apartment in
the Fort Lauderdale area with another friend and both worked
at various jobs in the area. Later, they stayed briefly
with plaintiff's parents in the Palm Beach locks A Hatchie,
Florida area, before Ostrich rented an apartment for the couple
on ben Oak Drive in Royal palm Beach id At seventeen,
nineteen twenty five through twenty seven. Although plaintiff agreed to
marry Ostrich, she never had any intention of doing so.
Example n at one twenty seven and one twenty eight
reply Plaintiff offers argument without an affidavid or any other
contradictory evidence regarding whether a plaintiff voluntarily lived independently or
whether a reasonable person could assert that she was engaged.
Mister Ostrich and Plaintiff agreed that they were engaged and
testified accordingly as cited. In the absence of admissible eviane.
To the contrary, the facts as described by her fiance
in his deposition should be deemed admitted. All right, folks,
we're going to wrap up this episode right here, and
in the next episode we're gonna pick up where we
left off. All of the information that goes with this
episode can be found in the description box.