Speaker 1: What's up everyone, and welcome back to the Epstein Chronicles.
This episode, we're picking right back up where we left
off with the SDNY Rule fifty six dot one Court
document the defendants Purported Facts thirty four. Miss Maxwell under
agents exercised no control or authority over any media organization,
including the media identified in Miss Robert's response to interrogatory
number six in connection with the media's publication of portions
of the January twenty fifteen statement, Miss Robert's statement controverting
the defendant facts. Miss Roberts disputes this statement in its
entirety as its completely devoid of record evidence. In fact,
the record establishes the contrary first defendant hired Gal because
his position allowed him to influence the press to publish
her defamatory statement. A sampling of Gus's testimony establishes just that.
Question did miss Maxwell retain the services of you or
your firm? Answer? Yes, she did. Question is it your
belief that the agreement was in effect on January two,
twenty fifteen? Answer yes. Question do you recall the terms
of that agreement? Answer well, it was a re establishment
of an existing agreement. So if we go back to
the original agreement. It was to provide public relations services
to Miss Maxwell in the matter of Roberts and her activities.
Question you can answer to the extent that anything you
testify is not protected by privilege. Answer. Miss Roberts first
came to my attention on or around March twenty eleven
when I was called into a meeting with Philip Bardon
and Miss Maxwell at Devonshire's Law office that she had
made Miss Roberts had made extremely unpleasant allegations about Miss
Maxwell's private life. We were Acuity Reputation. My firm was
called in to protect Miss Maxwell's reputation and to set
the record straight. That was and that work commenced on
or around the Arch of twenty eleven. Question does this
document fairly depict pages from your from Acuity Reputation's website?
Answer yes it does. Question do you see where it
says we manage reputation and forge opinion through public relations,
strategic communications and high level networking? Answer I do. Question
is that a truth statement? Answer? Say it again? Sorry?
Question is that a true statement? Answer it is, Yes,
I wrote that statement. Question Okay, do you see where
your website claims that your company has excellent relationships with
the media. Answer I do. Question is that a true statement? Answer? Yeah,
that's a true statement. Yeah. Question is it correct that
your advertise your excellence relationship with the media because your
services often include giving communications to the media on behalf
of your clients. Answer yes, seem Acauli Declaration Exhibit six. Gal.
In addition to testimonial evidence, the proof is also in
the result. By using Goo to issue her press release,
defendant caused her statement to be published by numerous major
news organizations with wide readership all over the globe. Accordingly,
the record evidence shows that Miss Maxwell, through her agent,
had im men's control and authority over the media, convincing
major news outlets to publish her words based on nothing
more than a single email from Gal. The defendants purported
facts Miss Roberts defamation action against Miss Maxwell eight years
after Epstein's guilty plea. Miss Roberts brought this action, repeating
many of the allegations she made in her CVRA joined
her motion Miss Robert's statement controverting defendant facts agreed, but
noting that the defamation cause of action against defendant did
not accrue until defendant defamed her In January of twenty fifteen.
The same year, Miss Roberts filed suit against defendant for
defamation the defendants purported facts. The case in plaint alleges
that the January twenty fifteen statement contained the following deliberate falsehoods.
A that Roberts sworn allegations against Glenn Maxwell are untrue.
B that the allegations have been shown to be untrue.
See that Robert's claims are obvious lies. Miss Robert's statement
controverting the defendants facts agreed. However, in discovery, defendant was
finally forced to produce the complete press release she issued
CEA McCauley declaration at Exhibit twenty six The defendants purported facts.
Miss Maxwell lived independently from her parents with her fiance
long before meeting Epstein or Miss Maxwell. After leaving the
Growing Together drug rehabilitation facility in nineteen ninety nine, Miss
Roberts moved in with the family of a fellow patient. There,
she met and became engaged to her friend's brother, James
Michael Ostrich. She and Ostrich thereafter rented an apartment in
Fort Lauderdale with another friend, and both worked at various
in that area. Later, they stayed briefly with Miss Roberts's
parents in the Palm Beach Locksahachie, Florida area, before Ostrich
rented an apartment for the couple on bent Oak Drive
in Royal Palm Beach. Although Miss Roberts agreed to marry Ostrich,
she never had any intention of doing so. Miss Robert's
statement controverting the defendant's facts. Miss Roberts did not voluntarily
live independently from her parents with her fiance. Rather, Miss
Roberts was a troubled minor child who was not truly
engaged prior to meeting defendant and Epstein. Where Miss Roberts
lived and who she lived with are not relevant to
the issues being decided in this action. Again, this is
merely a transparent distraction from the case that is actually
at issue and is being used for the sole purpose
of inserting conjecture in an effort to distract the court
and ultimately the jury. Although Ostrich testified that he proposed
to Miss Roberts on Valentine's Day see Ostrich at page nineteen,
miss Roberts was a troubled teen who could not realistically
be considered a fiance in the true sense of the word,
nor was she of legal age to marry. In fact,
as accurately described by the defendant, Miss Roberts never had
any intention of marrying Ostrich. Roberts Deposition at one twenty
seven twenty two one twenty eight, twenty one. Given that
Miss Roberts was a child with limited legal capacity at
this point, and that she did not have any intention
of marrying Ostrich, a reasonable person could not assert that
Miss Roberts was engaged. Defendants Purported Facts thirty eight. Miss
Roberts re enrolled in high school from June twenty first,
two thousand, until March seventh, two thousand and two. After
finishing the ninth grade school year at Forest Hill's High
School on June ninth, nineteen ninety nine, Miss Roberts re
enrolled at Wellington Adult School on June twenty first, two thousand,
again on August sixteenth, two thousand, and on August fourteenth,
two thousand and one. On September twentieth, two thousand and one,
Miss Roberts then enrolled at Royal Pond Beach High School.
A few weeks later, on October twelfth, two thousand and one,
she matriculated at Survivor's Charter School Survivor's Charter School was
an alternative school designed to assist students who had been
unsuccessful at more traditional schools. Miss Roberts remained enrolled at
Survivor's Charter School until March seventh, two thousand and two.
She was present fifty six days and absent thirteen days
during her time there. Miss Roberts never received her high
school diploma or her ged Miss Roberts and Figueroa went
back to school together at Survivor's Charter School. The school
day there lasted from morning until afternoon. Miss Roberts statement
controverting the defendant facts. Miss Roberts denies this statement. Either
defendant is blatantly misleading this court, or a defendant simply
does not understand how to interpret Miss Robert's school records.
The record produced by defendant is specifically titled A zero
six Assignment History, which reflects semester's start and end dates
per each one hundred and eighty day school year, not
dates that Miss Roberts physically enrolled or withdrew from school
seem Acauli declaration at Exhibit twenty seven, while grade thirty
indicates adult education. Miss roberts attendance records indicate that she
was not present at school between six twenty one of
two thousand and nine twenty of two thousand and one.
See withdrawal codes W thirty two and W forty seven.
Withdrawal codes Adult students W twenty six any student who
withdraws from school to enter the adult education program prior
to completion of graduation requirements. W thirty two Any adult
student who left the class program to enter another training program.
W forty seven any adult student who is procedurally withdrawn
at the end of the term or school year, who
will continue in the class program the next school year.
More importantly, Miss roberts school transcript clearly indicate no course
is taken for the nineteen ninety nine, two thousand, and
two thousand, two thousand and one school years. Seemacauley declaration
at Exhibit twenty seven. Miss roberts attempt to work and
resume school at Survivor's charter school as a tenth grader
in the two thousand and one two thousand and two
school year was limited to a portion of the school
year and further substantiates Miss Robert's testimony that she attempted
to get away from Epstein's abuse, along with the following
testimony by Figueroa. Question, was there a period of time
between two thousand and one and when she left in
two thousand and two where she was not working for Jeffrey? Answer? Yes,
question what period of time was that? Answer? It was
pretty much like when she was actually working as a server,
like basically because we were trying to not have her
go back there, like she did not want to go
back there, and we were trying to just work without
needing his money, you know, Seemacaulay declaration, Exhibit four. Question,
so the thing that Virginia was tired of? What was
it that Virginia was trying to get away from and
stop with respect to working at Jeffrey Epstein's house? Answer
to stop being used and abused Seemacaulay declaration at Exhibit four.
Even still, if the records are correct, which Miss Roberts
does not concede, the records indicate that Miss roberts attendance
was poor, with sixty nine days present and thirty two
days absent out of a required one hundred and eighty
days school year. That she was not enrolled at the
end of the school year. Emphasis added Seamacauley Declaration, Exhibit
twenty seven. Miss Roberts, obvious gap in her school attendance,
her presence verified by Epstein's pilot on flight logs, and
an abundance of witness testimony all corroborate her story that she,
Miss Roberts was flying domestic and internationally with Epstein at
least thirty two times between twelve eleven of two thousand
and seven, twenty eighth one and one O two and
eight twenty one oh two. Defendant traveling with Miss Roberts
on twenty three of the flights. Cemacauley declaration at Exhibits
fifteen and forty one, and that points us to the
deposition of David Rogers, who is the pilot of Jeffrey Epstein. Question.
Do you know how long Virginia had been coming over
to the house before she started traveling on an airplane
with Glen and Jeffrey the witness? Not too long. I
don't think it was long after that. Ceamacauley declaration at
Exhibit thirty seven. All right, folks, we're gonna wrap up
this episode right here, and in the next episode talking
about the topic, 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. What's up everyone,
and welcome back to the Epstein Chronicles. In this episode,
we're gonna pick right back up where we left off
with the SDNY Rule fifty six Dot one document the
Defendants Purported Facts thirty nine. During the year two thousand,
Miss Roberts worked at numerous jobs. In two thousand, while
living with her fiance, Miss Roberts held five different jobs
at Aviculture Breeding and Research Center, Southeast Employee Management Company,
the Club at mar A Lago, Oasis Outsourcing, and Neiman Marcus.
Her taxable learnings that year totaled nearly nine thousand dollars.
Miss Roberts cannot now recall either of the Southeast Employee
Management Company or the Oasis Outsourcing job. Miss Robert's statement
controverting defendants facts. Miss Roberts disputes this statement. During two thousand,
Miss Roberts shared an apartment with her then boyfriend James
Michael Ostrich and his friend Mario Siemacauli Declaration Exhibit two.
Although Ostrich testified that he proposed to Miss Roberts on
Valentine's Day, see Ostrich at page nineteen, Miss Roberts was
a troubled teen who could not realistically be considered a
fiance in the true sense of the word, nor was
she legal age to. While Miss Roberts held various jobs
in two thousand, SSA records do not show the exact
date of employment, month and day because they do not
need this information to figure Social Security benefits Seemacaulley declaration
at Exhibit forty six. The reason that Miss Roberts cannot
recall to companies listed honor SSA records, Southeast Employee Management Company,
or Oasis Outsourcing is simply because they were not her employers.
Seamacaulley declaration at Exhibit five. Had defend and bothered to
run a simple Google search, she would have ruled them
out as being payroll and benefit administration companies. Miss Roberts
has testified that she believes she worked at Taco Bell,
at an aviary, then mar A Lago Seamacaulley declaration at
Exhibit five. Austrich also testified that Miss Roberts work with
them at Taco Bell as well as a pet store
for over a month before working at mar Alago. Cemacaulley
declaration at Exhibit five. Neither Taco Bell nor the Pet
Store are listed on Miss roberts ssay records because they
were most likely paid through payroll companies Seamacauleey declaration at
Exhibit forty six. Miss Roberts also testified that she had
volunteered at an aviary, where they eventually put her on
the payroll but paid her very little. Roberts deposition at
fifty two. Aviculture Breeding and Research Center taxable earnings for
two thousand is ninety nine dollars and forty eight cents.
Seamacaulley declaration at Exhibit forty six. The defendants purported facts.
Miss roberts employment at the mar A Lago SPA began
in the fall of two thousand. Miss Roberts father Sky Roberts,
was hired as a maintenance worker at the mar A
Lago Club in Palm Beach, Florida, beginning on April eleventh,
two thousand. Mister Roberts worked there year round for approximately
three years. After working there for a period of time,
mister Roberts became acquainted with the head of the spa
and recommended Miss Roberts for a job there. Mar A
Lago closes every Mother's Day and reopens on November first.
Most of the employees at Marra A Lago, including all
employees of the SPA area such as SPA attendants, are
seasonal and work only when the club is open, i e.
Between November first and Mother's Day. Miss Roberts was hired
as a seasonal SPA attendant to work at the Marra
A Lago Club in the fall of two thousand, after
she had turned seventeen. Miss Robert's statement controverting defendant facts.
Miss Roberts disputes this statement. Defendant cannot simply infirm Miss
roberts employment history and claim it to be undisputed. The
Marra A Lago Club produced one hundred seventy seven pages
of records in response to defendant subpoena. However, not one
page indicated Miss roberts actual dates of employment, nor whether
she was a full time or seasonal employee. In fact,
the only significant record produced was a single, vague chart
entry indicating that Miss Roberts was terminated in two thousand.
Job postings in job descriptions produced by mar A Lago
from two thousand and two and later are irrelevant to
Miss roberts employment because they are from after she worked there.
Miss Roberts testified that mar A Lago was a summer
job Seemacaulley declaration at Exhibit five. In fact, her father,
Sky Roberts, testified that he referred his daughter for employment
and she did not get the job through a posting.
He drove his daughter to and from work consistent with
his full time schedule Seamacaulley declaration at Exhibit seventeen. He
believes the spa, like the kitchen dining room, was opened
to local guests in the summer Seemacaulley declaration at Exhibit seventeen,
and that his daughter was not attending school when she
worked at mar A Lago Seamacaulley declaration at Exhibit seventeen.
In addition, Juana Lessi testified that it was summer when
defendant approached Miss Roberts at mar A Lago because he
specifically remembered that day I was sweating like hell in
in the car for Miss Maxwell to come out of
the massage seem Acauley declaration at Exhibit one. A Lessie deposition.
Defendants purported facts forty one. Miss Roberts represented herself as
a massuse for Jeffrey Epstein while working at the mar
A Lagos, Spa and reading a library book about massage.
Miss Roberts met Miss Maxwell. Miss Roberts thereafter told her
father that she got a job working for Jeffrey Epstein
as a massuse. Miss Roberts's father took her to Epstein's
house on one occasion or around that time, and Epstein came
outside and introduced himself to mister Roberts. Miss Roberts commenced
employment as a traveling massuse for mister Epstein. Miss Roberts
was excited about her job as a massuse, about traveling
with him, and about meeting famous people. Miss Roberts represented
that she was employed as a massuse beginning in January
two thousand and one. Miss Roberts never mentioned Miss Maxwell
to her then fiancee Ostrich. Miss roberts father never met
Miss Maxwell. Miss Robert's statement controverting defendant's facts. Miss Roberts
denies defendant's false and factually unsupported narrative. In Florida, a
person cannot work as a massuse unless she is at
least eighteen years of age or has received a high
school diploma or high school equivalency diploma. Florida Statute Section
four eighty dash zero four to one. Miss Roberts was
a minor child under the age of eighteen when she
was working at mar A Lago as a spa attendant
Robert's deposition at sixty one and sixty one twenty four.
She was approached by defendant, who told her she could
make money as a massuse, a profession in which Miss
Roberts had no experience. See McCauley declaration at exhibit five.
Sky Roberts Virginia Roberts father verified Miss roberts account that
defendant recruited his daughter to learn massage therapy see mccauleay
declaration at exhibit seventeen. Miss Roberts his father drove her
to Jeffrey Epstein's house, the address of which was given
to her by the defendant see McCauley declaration at exhibit five.
Miss Roberts was led into the house and was instructed
by defendant on how to give a massage, during which
Epstein and defendant turned the massage into a sexual encounter
and offered Miss Roberts money and a better life to
be compliant in the sexual demands of defendant and Epstein.
See McAuley declaration at exhibit five. The miner. Miss Roberts
then began traveling with defendant and Epstein on private planes
and servicing people sexually for money, working not as a
legitimate massuse but in a position of sexual servitude Seemacaulley
declaration at Exhibits one and five. Epstein's house manager Juana
Lessi described defendant's methodical routine of how she prepared a
list of places ahead of time, then drove to each
place for the purpose of recruiting girls to massage Epstein
Seemacauley declaration at Exhibit eighteen. Alessi also stated that on
multiple occasions he drove defendant to pre planned places while
she recruited girls for a massage. He further testified that
he witnessed Miss Roberts at Epstein's house on the very
same day that he witnessed defendant recruit Miss Roberts from
mar A Lago Sea McCauley declaration at Exhibit eighteen. Johanna Schoberg,
through her sworn testimony, demonstrated that defendant recruited her in
a similar fashion by driving to the college campus where
she attended school and approached her to work at Epstein's
home answering phones seamccauley declaration at Exhibit sixteen. Schoberg testified
that she answered phones for one day before defendant propositioned
her to rub feet for one hundred bucks an hour
Seemacauley declaration at Exhibit sixteen. The following day, Schoberg was
paired with defendant's assistant, Emmy Taylor, who provided her with
massage training on Epstein Schoburg at thirteen and fifteen. Miss
Robert's then boyfriend Ostrich testified that he could not recall
the name of the person who recruited Miss Roberts. However,
he did say she was recruited by someone to work
for Epstein as a massage therapist, but that Miss Roberts
did not have any experience seem Acauley declaration at Exhibit two.
Neither Miss Roberts nor Miss Schoberg were licensed or trained
in massage, but were invited soon after being recruited to
travel with Epstein on his private plane to massage Seemacauley
declaration at Exhibit sixteen. The defendants purported facts forty two.
Miss Roberts resumed a relationship with convicted felon Anthony Figueroa
in spring two thousand and one, while living with Ostrich,
Miss Roberts lied to and cheated on him with her
high school boyfriend, Anthony Figueroa. Miss Roberts and Ostrich thereafter
broke up, and Figueroa moved into the Bento compartment with
Miss Roberts. When Ostrich returned to the Bento compartment to
check on his pets and retrieve his belongings in Miss
Robert's presence, punched Ostrich in the face. Figuaroa and Miss
Roberts fled the scene before police arrived. Figuaroa was then
convicted felon and a drug abuser on probation for possession
of a controlled substance. Miss Robert's statement controverting defendant's facts.
This entire statement is wholly irrelevant to the case being
tried and is improperly being inserted to tarnish the record.
Miss Robert's dating history as a young teen bears no
relation to the allegations made within Miss Robert's complaint against
the defendant. As previously stated, defendant is attempting to muddy
the record with nonsensical teen drama in an effort to
detract from her salacious sexual abuse of a minor child.
Such statements bear no relation to the issues presented through
her motion for some rejudgment and should be given way
reflecting the same specifically set forth in Miss Robert's objections
to designated testimony. The alleged information would be excluded by
multiple rules of evidence and contested by Miss Roberts see
McAuley declaration at Exhibit five. Moreover, it was the defendant
who solicited Anthony Figueroa to recruit high school age girls
for Epstein. Seemacaulley declaration at Exhibit four. Defendants purported facts.
Miss Roberts freely and voluntarily contacted the police to come
to her aid in two thousand and one and two
thousand and two, but never reported to them that she
was Epstein's sex slave. In August two thousand and one,
at age seventeen, while living in the same apartment, Miss
Roberts and Figaroa hosted a party with a number of guests.
During the party, according to Miss Roberts, someone entered Miss
roberts room and stole five hundred dollars from her shirt pocket.
Miss Roberts contacted the police. She met and spoke with
police officers regarding the incident and filed a report. She
did not disclose to the officer that she was a
sex slave. A second time, in June two thousand and two,
Miss Roberts contacted the police to report that her former
landlord had left her belongings by the roadside and had
litter mattress on fire. Again, Miss Roberts met and spoke
with the law enforcement officers, but did not complain that
she was the victim of any sexual trafficking or abuse
or that she was then being held as a sex slave.
Miss Robert's statement controverting the defendant's facts. This statement is
misleading in several respects and irrelevant. The fact that Miss
Roberts did not contact police on two occasions for two
specific purposes, and did not take that opportunity to also
inform the police of everything else that was going on
in her life at the time is immaterial. Defendant implies
that anytime someone calls the police for one thing, they
should tell the police about every other crime, regardless of
the relevance to the crime for which the police responded,
and regardless to the threat to herself should she report
on these powerful people. Moreover, as Professor Conan explained, popular
understanding of the term seine slave might still connote images
of violent pimps, white slavery, or a victims chained to
a bed and a brothel in the minds of some people.
To call Miss Roberts a victim of sex trafficking would, however,
very accurately convey the reality that she, along with a
great many other victims of contemporary forms of slavery, are
often exploited by the invisible chains of fraud and psychological coercion. C.
Mccauleay declaration at Exhibit twenty three coonan expert report at
twenty Miss Roberts specifically testified that she was fearful of
the defendant and Epstein, and accordingly she would not have
reported her abusers. She also knew that Epstein had control
over the Palm Beach Police see McCauley's declaration at exhibit five.
All right, folks, we're going to wrap up this episode
here and in the next episode dealing with the topic,
we're going to pick up where we left off. All
of the information that goes with this episode can be
found in the description box