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

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This episode, we're picking right back up where we left

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off with the SDNY Rule fifty six dot one Court

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document the defendants Purported Facts thirty four. Miss Maxwell under

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agents exercised no control or authority over any media organization,

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including the media identified in Miss Robert's response to interrogatory

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number six in connection with the media's publication of portions

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of the January twenty fifteen statement, Miss Robert's statement controverting

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the defendant facts. Miss Roberts disputes this statement in its

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entirety as its completely devoid of record evidence. In fact,

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the record establishes the contrary first defendant hired Gal because

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his position allowed him to influence the press to publish

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her defamatory statement. A sampling of Gus's testimony establishes just that.

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Question did miss Maxwell retain the services of you or

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your firm? Answer? Yes, she did. Question is it your

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belief that the agreement was in effect on January two,

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twenty fifteen? Answer yes. Question do you recall the terms

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of that agreement? Answer well, it was a re establishment

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of an existing agreement. So if we go back to

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the original agreement. It was to provide public relations services

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to Miss Maxwell in the matter of Roberts and her activities.

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Question you can answer to the extent that anything you

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testify is not protected by privilege. Answer. Miss Roberts first

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came to my attention on or around March twenty eleven

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when I was called into a meeting with Philip Bardon

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and Miss Maxwell at Devonshire's Law office that she had

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made Miss Roberts had made extremely unpleasant allegations about Miss

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Maxwell's private life. We were Acuity Reputation. My firm was

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called in to protect Miss Maxwell's reputation and to set

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the record straight. That was and that work commenced on

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or around the Arch of twenty eleven. Question does this

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document fairly depict pages from your from Acuity Reputation's website?

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Answer yes it does. Question do you see where it

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says we manage reputation and forge opinion through public relations,

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strategic communications and high level networking? Answer I do. Question

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is that a truth statement? Answer? Say it again? Sorry?

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Question is that a true statement? Answer it is, Yes,

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I wrote that statement. Question Okay, do you see where

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your website claims that your company has excellent relationships with

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the media. Answer I do. Question is that a true statement? Answer? Yeah,

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that's a true statement. Yeah. Question is it correct that

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your advertise your excellence relationship with the media because your

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services often include giving communications to the media on behalf

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of your clients. Answer yes, seem Acauli Declaration Exhibit six. Gal.

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In addition to testimonial evidence, the proof is also in

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the result. By using Goo to issue her press release,

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defendant caused her statement to be published by numerous major

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news organizations with wide readership all over the globe. Accordingly,

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the record evidence shows that Miss Maxwell, through her agent,

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had im men's control and authority over the media, convincing

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major news outlets to publish her words based on nothing

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more than a single email from Gal. The defendants purported

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facts Miss Roberts defamation action against Miss Maxwell eight years

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after Epstein's guilty plea. Miss Roberts brought this action, repeating

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many of the allegations she made in her CVRA joined

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her motion Miss Robert's statement controverting defendant facts agreed, but

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noting that the defamation cause of action against defendant did

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not accrue until defendant defamed her In January of twenty fifteen.

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The same year, Miss Roberts filed suit against defendant for

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defamation the defendants purported facts. The case in plaint alleges

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that the January twenty fifteen statement contained the following deliberate falsehoods.

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A that Roberts sworn allegations against Glenn Maxwell are untrue.

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B that the allegations have been shown to be untrue.

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See that Robert's claims are obvious lies. Miss Robert's statement

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controverting the defendants facts agreed. However, in discovery, defendant was

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finally forced to produce the complete press release she issued

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CEA McCauley declaration at Exhibit twenty six The defendants purported facts.

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Miss Maxwell lived independently from her parents with her fiance

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long before meeting Epstein or Miss Maxwell. After leaving the

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Growing Together drug rehabilitation facility in nineteen ninety nine, Miss

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Roberts moved in with the family of a fellow patient. There,

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she met and became engaged to her friend's brother, James

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Michael Ostrich. She and Ostrich thereafter rented an apartment in

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Fort Lauderdale with another friend, and both worked at various

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in that area. Later, they stayed briefly with Miss Roberts's

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parents in the Palm Beach Locksahachie, Florida area, before Ostrich

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rented an apartment for the couple on bent Oak Drive

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in Royal Palm Beach. Although Miss Roberts agreed to marry Ostrich,

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she never had any intention of doing so. Miss Robert's

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statement controverting the defendant's facts. Miss Roberts did not voluntarily

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live independently from her parents with her fiance. Rather, Miss

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Roberts was a troubled minor child who was not truly

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engaged prior to meeting defendant and Epstein. Where Miss Roberts

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lived and who she lived with are not relevant to

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the issues being decided in this action. Again, this is

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merely a transparent distraction from the case that is actually

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at issue and is being used for the sole purpose

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of inserting conjecture in an effort to distract the court

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and ultimately the jury. Although Ostrich testified that he proposed

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to Miss Roberts on Valentine's Day see Ostrich at page nineteen,

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miss Roberts was a troubled teen who could not realistically

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be considered a fiance in the true sense of the word,

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nor was she of legal age to marry. In fact,

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as accurately described by the defendant, Miss Roberts never had

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any intention of marrying Ostrich. Roberts Deposition at one twenty

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seven twenty two one twenty eight, twenty one. Given that

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Miss Roberts was a child with limited legal capacity at

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this point, and that she did not have any intention

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of marrying Ostrich, a reasonable person could not assert that

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Miss Roberts was engaged. Defendants Purported Facts thirty eight. Miss

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Roberts re enrolled in high school from June twenty first,

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two thousand, until March seventh, two thousand and two. After

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finishing the ninth grade school year at Forest Hill's High

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School on June ninth, nineteen ninety nine, Miss Roberts re

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enrolled at Wellington Adult School on June twenty first, two thousand,

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

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

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Miss Roberts then enrolled at Royal Pond Beach High School.

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A few weeks later, on October twelfth, two thousand and one,

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she matriculated at Survivor's Charter School Survivor's Charter School was

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an alternative school designed to assist students who had been

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unsuccessful at more traditional schools. Miss Roberts remained enrolled at

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Survivor's Charter School until March seventh, two thousand and two.

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She was present fifty six days and absent thirteen days

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during her time there. Miss Roberts never received her high

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school diploma or her ged Miss Roberts and Figueroa went

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back to school together at Survivor's Charter School. The school

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day there lasted from morning until afternoon. Miss Roberts statement

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controverting the defendant facts. Miss Roberts denies this statement. Either

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defendant is blatantly misleading this court, or a defendant simply

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does not understand how to interpret Miss Robert's school records.

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The record produced by defendant is specifically titled A zero

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six Assignment History, which reflects semester's start and end dates

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per each one hundred and eighty day school year, not

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dates that Miss Roberts physically enrolled or withdrew from school

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seem Acauli declaration at Exhibit twenty seven, while grade thirty

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indicates adult education. Miss roberts attendance records indicate that she

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was not present at school between six twenty one of

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two thousand and nine twenty of two thousand and one.

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See withdrawal codes W thirty two and W forty seven.

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Withdrawal codes Adult students W twenty six any student who

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withdraws from school to enter the adult education program prior

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to completion of graduation requirements. W thirty two Any adult

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student who left the class program to enter another training program.

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W forty seven any adult student who is procedurally withdrawn

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at the end of the term or school year, who

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will continue in the class program the next school year.

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More importantly, Miss roberts school transcript clearly indicate no course

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is taken for the nineteen ninety nine, two thousand, and

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two thousand, two thousand and one school years. Seemacauley declaration

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at Exhibit twenty seven. Miss roberts attempt to work and

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resume school at Survivor's charter school as a tenth grader

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in the two thousand and one two thousand and two

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school year was limited to a portion of the school

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year and further substantiates Miss Robert's testimony that she attempted

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to get away from Epstein's abuse, along with the following

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testimony by Figueroa. Question, was there a period of time

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between two thousand and one and when she left in

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two thousand and two where she was not working for Jeffrey? Answer? Yes,

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question what period of time was that? Answer? It was

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pretty much like when she was actually working as a server,

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like basically because we were trying to not have her

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go back there, like she did not want to go

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back there, and we were trying to just work without

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needing his money, you know, Seemacaulay declaration, Exhibit four. Question,

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so the thing that Virginia was tired of? What was

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it that Virginia was trying to get away from and

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stop with respect to working at Jeffrey Epstein's house? Answer

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to stop being used and abused Seemacaulay declaration at Exhibit four.

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Even still, if the records are correct, which Miss Roberts

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does not concede, the records indicate that Miss roberts attendance

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was poor, with sixty nine days present and thirty two

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days absent out of a required one hundred and eighty

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days school year. That she was not enrolled at the

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end of the school year. Emphasis added Seamacauley Declaration, Exhibit

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twenty seven. Miss Roberts, obvious gap in her school attendance,

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her presence verified by Epstein's pilot on flight logs, and

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an abundance of witness testimony all corroborate her story that she,

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Miss Roberts was flying domestic and internationally with Epstein at

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least thirty two times between twelve eleven of two thousand

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and seven, twenty eighth one and one O two and

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eight twenty one oh two. Defendant traveling with Miss Roberts

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on twenty three of the flights. Cemacauley declaration at Exhibits

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fifteen and forty one, and that points us to the

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deposition of David Rogers, who is the pilot of Jeffrey Epstein. Question.

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Do you know how long Virginia had been coming over

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to the house before she started traveling on an airplane

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with Glen and Jeffrey the witness? Not too long. I

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don't think it was long after that. Ceamacauley declaration at

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Exhibit thirty seven. All right, folks, we're gonna wrap up

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this episode right here, and in the next episode talking

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about the topic, we're gonna pick up where we left

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off All of the information that goes with this episode

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can be found in the description box. What's up everyone,

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and welcome back to the Epstein Chronicles. In this episode,

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we're gonna pick right back up where we left off

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with the SDNY Rule fifty six Dot one document the

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Defendants Purported Facts thirty nine. During the year two thousand,

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Miss Roberts worked at numerous jobs. In two thousand, while

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living with her fiance, Miss Roberts held five different jobs

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at Aviculture Breeding and Research Center, Southeast Employee Management Company,

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the Club at mar A Lago, Oasis Outsourcing, and Neiman Marcus.

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Her taxable learnings that year totaled nearly nine thousand dollars.

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Miss Roberts cannot now recall either of the Southeast Employee

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Management Company or the Oasis Outsourcing job. Miss Robert's statement

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controverting defendants facts. Miss Roberts disputes this statement. During two thousand,

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Miss Roberts shared an apartment with her then boyfriend James

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Michael Ostrich and his friend Mario Siemacauli Declaration Exhibit two.

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Although Ostrich testified that he proposed to Miss Roberts on

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Valentine's Day, see Ostrich at page nineteen, Miss Roberts was

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a troubled teen who could not realistically be considered a

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fiance in the true sense of the word, nor was

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she legal age to. While Miss Roberts held various jobs

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in two thousand, SSA records do not show the exact

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date of employment, month and day because they do not

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need this information to figure Social Security benefits Seemacaulley declaration

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at Exhibit forty six. The reason that Miss Roberts cannot

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recall to companies listed honor SSA records, Southeast Employee Management Company,

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or Oasis Outsourcing is simply because they were not her employers.

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Seamacaulley declaration at Exhibit five. Had defend and bothered to

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run a simple Google search, she would have ruled them

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out as being payroll and benefit administration companies. Miss Roberts

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has testified that she believes she worked at Taco Bell,

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at an aviary, then mar A Lago Seamacaulley declaration at

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Exhibit five. Austrich also testified that Miss Roberts work with

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them at Taco Bell as well as a pet store

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for over a month before working at mar Alago. Cemacaulley

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declaration at Exhibit five. Neither Taco Bell nor the Pet

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Store are listed on Miss roberts ssay records because they

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were most likely paid through payroll companies Seamacauleey declaration at

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Exhibit forty six. Miss Roberts also testified that she had

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volunteered at an aviary, where they eventually put her on

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the payroll but paid her very little. Roberts deposition at

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fifty two. Aviculture Breeding and Research Center taxable earnings for

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two thousand is ninety nine dollars and forty eight cents.

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Seamacaulley declaration at Exhibit forty six. The defendants purported facts.

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Miss roberts employment at the mar A Lago SPA began

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in the fall of two thousand. Miss Roberts father Sky Roberts,

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was hired as a maintenance worker at the mar A

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Lago Club in Palm Beach, Florida, beginning on April eleventh,

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two thousand. Mister Roberts worked there year round for approximately

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three years. After working there for a period of time,

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mister Roberts became acquainted with the head of the spa

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and recommended Miss Roberts for a job there. Mar A

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Lago closes every Mother's Day and reopens on November first.

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Most of the employees at Marra A Lago, including all

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employees of the SPA area such as SPA attendants, are

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seasonal and work only when the club is open, i e.

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Between November first and Mother's Day. Miss Roberts was hired

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as a seasonal SPA attendant to work at the Marra

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A Lago Club in the fall of two thousand, after

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she had turned seventeen. Miss Robert's statement controverting defendant facts.

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Miss Roberts disputes this statement. Defendant cannot simply infirm Miss

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roberts employment history and claim it to be undisputed. The

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Marra A Lago Club produced one hundred seventy seven pages

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of records in response to defendant subpoena. However, not one

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page indicated Miss roberts actual dates of employment, nor whether

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she was a full time or seasonal employee. In fact,

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the only significant record produced was a single, vague chart

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entry indicating that Miss Roberts was terminated in two thousand.

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Job postings in job descriptions produced by mar A Lago

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from two thousand and two and later are irrelevant to

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Miss roberts employment because they are from after she worked there.

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Miss Roberts testified that mar A Lago was a summer

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job Seemacaulley declaration at Exhibit five. In fact, her father,

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Sky Roberts, testified that he referred his daughter for employment

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and she did not get the job through a posting.

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He drove his daughter to and from work consistent with

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his full time schedule Seamacaulley declaration at Exhibit seventeen. He

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believes the spa, like the kitchen dining room, was opened

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to local guests in the summer Seemacaulley declaration at Exhibit seventeen,

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and that his daughter was not attending school when she

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worked at mar A Lago Seamacaulley declaration at Exhibit seventeen.

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In addition, Juana Lessi testified that it was summer when

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defendant approached Miss Roberts at mar A Lago because he

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specifically remembered that day I was sweating like hell in

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in the car for Miss Maxwell to come out of

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the massage seem Acauley declaration at Exhibit one. A Lessie deposition.

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Defendants purported facts forty one. Miss Roberts represented herself as

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a massuse for Jeffrey Epstein while working at the mar

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A Lagos, Spa and reading a library book about massage.

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Miss Roberts met Miss Maxwell. Miss Roberts thereafter told her

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father that she got a job working for Jeffrey Epstein

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as a massuse. Miss Roberts's father took her to Epstein's

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house on one occasion or around that time, and Epstein came

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outside and introduced himself to mister Roberts. Miss Roberts commenced

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employment as a traveling massuse for mister Epstein. Miss Roberts

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was excited about her job as a massuse, about traveling

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with him, and about meeting famous people. Miss Roberts represented

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that she was employed as a massuse beginning in January

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two thousand and one. Miss Roberts never mentioned Miss Maxwell

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to her then fiancee Ostrich. Miss roberts father never met

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Miss Maxwell. Miss Robert's statement controverting defendant's facts. Miss Roberts

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denies defendant's false and factually unsupported narrative. In Florida, a

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person cannot work as a massuse unless she is at

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least eighteen years of age or has received a high

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school diploma or high school equivalency diploma. Florida Statute Section

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four eighty dash zero four to one. Miss Roberts was

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a minor child under the age of eighteen when she

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was working at mar A Lago as a spa attendant

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Robert's deposition at sixty one and sixty one twenty four.

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She was approached by defendant, who told her she could

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make money as a massuse, a profession in which Miss

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Roberts had no experience. See McCauley declaration at exhibit five.

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Sky Roberts Virginia Roberts father verified Miss roberts account that

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defendant recruited his daughter to learn massage therapy see mccauleay

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00:18:56,839 --> 00:19:01,079
declaration at exhibit seventeen. Miss Roberts his father drove her

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to Jeffrey Epstein's house, the address of which was given

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to her by the defendant see McCauley declaration at exhibit five.

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Miss Roberts was led into the house and was instructed

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by defendant on how to give a massage, during which

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Epstein and defendant turned the massage into a sexual encounter

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and offered Miss Roberts money and a better life to

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be compliant in the sexual demands of defendant and Epstein.

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See McAuley declaration at exhibit five. The miner. Miss Roberts

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then began traveling with defendant and Epstein on private planes

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and servicing people sexually for money, working not as a

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legitimate massuse but in a position of sexual servitude Seemacaulley

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declaration at Exhibits one and five. Epstein's house manager Juana

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Lessi described defendant's methodical routine of how she prepared a

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list of places ahead of time, then drove to each

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place for the purpose of recruiting girls to massage Epstein

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Seemacauley declaration at Exhibit eighteen. Alessi also stated that on

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multiple occasions he drove defendant to pre planned places while

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she recruited girls for a massage. He further testified that

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he witnessed Miss Roberts at Epstein's house on the very

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same day that he witnessed defendant recruit Miss Roberts from

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mar A Lago Sea McCauley declaration at Exhibit eighteen. Johanna Schoberg,

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through her sworn testimony, demonstrated that defendant recruited her in

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a similar fashion by driving to the college campus where

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she attended school and approached her to work at Epstein's

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home answering phones seamccauley declaration at Exhibit sixteen. Schoberg testified

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that she answered phones for one day before defendant propositioned

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her to rub feet for one hundred bucks an hour

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Seemacauley declaration at Exhibit sixteen. The following day, Schoberg was

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paired with defendant's assistant, Emmy Taylor, who provided her with

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massage training on Epstein Schoburg at thirteen and fifteen. Miss

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Robert's then boyfriend Ostrich testified that he could not recall

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the name of the person who recruited Miss Roberts. However,

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he did say she was recruited by someone to work

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for Epstein as a massage therapist, but that Miss Roberts

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did not have any experience seem Acauley declaration at Exhibit two.

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Neither Miss Roberts nor Miss Schoberg were licensed or trained

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in massage, but were invited soon after being recruited to

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travel with Epstein on his private plane to massage Seemacauley

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declaration at Exhibit sixteen. The defendants purported facts forty two.

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Miss Roberts resumed a relationship with convicted felon Anthony Figueroa

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in spring two thousand and one, while living with Ostrich,

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Miss Roberts lied to and cheated on him with her

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high school boyfriend, Anthony Figueroa. Miss Roberts and Ostrich thereafter

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broke up, and Figueroa moved into the Bento compartment with

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Miss Roberts. When Ostrich returned to the Bento compartment to

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check on his pets and retrieve his belongings in Miss

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Robert's presence, punched Ostrich in the face. Figuaroa and Miss

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Roberts fled the scene before police arrived. Figuaroa was then

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convicted felon and a drug abuser on probation for possession

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of a controlled substance. Miss Robert's statement controverting defendant's facts.

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This entire statement is wholly irrelevant to the case being

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tried and is improperly being inserted to tarnish the record.

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Miss Robert's dating history as a young teen bears no

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relation to the allegations made within Miss Robert's complaint against

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the defendant. As previously stated, defendant is attempting to muddy

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the record with nonsensical teen drama in an effort to

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detract from her salacious sexual abuse of a minor child.

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Such statements bear no relation to the issues presented through

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her motion for some rejudgment and should be given way

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reflecting the same specifically set forth in Miss Robert's objections

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to designated testimony. The alleged information would be excluded by

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multiple rules of evidence and contested by Miss Roberts see

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McAuley declaration at Exhibit five. Moreover, it was the defendant

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who solicited Anthony Figueroa to recruit high school age girls

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for Epstein. Seemacaulley declaration at Exhibit four. Defendants purported facts.

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Miss Roberts freely and voluntarily contacted the police to come

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to her aid in two thousand and one and two

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thousand and two, but never reported to them that she

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was Epstein's sex slave. In August two thousand and one,

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at age seventeen, while living in the same apartment, Miss

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Roberts and Figaroa hosted a party with a number of guests.

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During the party, according to Miss Roberts, someone entered Miss

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roberts room and stole five hundred dollars from her shirt pocket.

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Miss Roberts contacted the police. She met and spoke with

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police officers regarding the incident and filed a report. She

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did not disclose to the officer that she was a

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sex slave. A second time, in June two thousand and two,

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Miss Roberts contacted the police to report that her former

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landlord had left her belongings by the roadside and had

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litter mattress on fire. Again, Miss Roberts met and spoke

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with the law enforcement officers, but did not complain that

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she was the victim of any sexual trafficking or abuse

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or that she was then being held as a sex slave.

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

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misleading in several respects and irrelevant. The fact that Miss

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Roberts did not contact police on two occasions for two

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specific purposes, and did not take that opportunity to also

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inform the police of everything else that was going on

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in her life at the time is immaterial. Defendant implies

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that anytime someone calls the police for one thing, they

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should tell the police about every other crime, regardless of

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the relevance to the crime for which the police responded,

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and regardless to the threat to herself should she report

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on these powerful people. Moreover, as Professor Conan explained, popular

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understanding of the term seine slave might still connote images

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of violent pimps, white slavery, or a victims chained to

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a bed and a brothel in the minds of some people.

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To call Miss Roberts a victim of sex trafficking would, however,

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very accurately convey the reality that she, along with a

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great many other victims of contemporary forms of slavery, are

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often exploited by the invisible chains of fraud and psychological coercion. C.

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00:25:25,839 --> 00:25:31,119
Mccauleay declaration at Exhibit twenty three coonan expert report at

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00:25:31,160 --> 00:25:35,400
twenty Miss Roberts specifically testified that she was fearful of

401
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the defendant and Epstein, and accordingly she would not have

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00:25:39,079 --> 00:25:43,240
reported her abusers. She also knew that Epstein had control

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00:25:43,279 --> 00:25:47,039
over the Palm Beach Police see McCauley's declaration at exhibit five.

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

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here and in the next episode dealing with the topic,

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we're going to pick up where we left off. All

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of the information that goes with this episode can be

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found in the description box