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Virginia Roberts Responds To Maxwell's Summary Judgement Request (Part 1)

Virginia Giuffre’s response to Ghislaine Maxwell’s motion for summary judgment was a direct challenge to Maxwell’s attempt to dismiss the case without a trial. In her filing, Giuffre argued that Maxwell’s statements denying any wrongdoing were not only defamatory, but made with actual malice—because Maxwell knew they were false when she made them. Giuffre’s legal team submitted sworn testimony, supporting documentation, and detailed timelines to establish that Maxwell had played a central role in Epstein’s trafficking operation and that her denials were part of a broader effort to discredit and silence victims.

Virginia Giuffre’s response to Ghislaine Maxwell’s motion for summary judgment was a direct challenge to Maxwell’s attempt to dismiss the case without a trial. In her filing, Giuffre argued that Maxwell’s statements denying any wrongdoing were not only defamatory, but made with actual malice—because Maxwell knew they were false when she made them. Giuffre’s legal team submitted sworn testimony, supporting documentation, and detailed timelines to establish that Maxwell had played a central role in Epstein’s trafficking operation and that her denials were part of a broader effort to discredit and silence victims.


to contact me:


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source:


Giuffre-unseal.pdf (courthousenews.com)

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

On today's episode, we're going to begin taking a look

at Virginia Roberts' response to Ghislaine Maxwell's motion for a

summary judgment. And this goes right along with the Virginia

Roberts deposition that we just went through over the past

week or so. This document is pretty big, but not

quite as big as the deposition. So it won't take

us as long to get through this one. But with

that said, it is still relatively lengthy. So why don't

we just dive right in and get started? Case number

15-CV-07433-RWS Virginia Roberts vs. Ghislaine Maxwell Preliminary Statement There can

be no question that disputed issues of material facts preclude

granting summary judgment when, in one count defamation case, defendant

presents the court with a 68-page memorandum of law, a

16-page statement of purported facts, and approximately 700 pages of exhibits.

The sheer scope of defendant's response, if anything, conclusively demonstrates

that volumes of disputed facts surround the core question of

whether defendant abused Ms. Roberts. Indeed, defendant acknowledges a dispute

between the parties as to whether she abused Ms. Roberts.

See motion for summary judgment at 1. Motion to dismiss

at 1. This court already said that this disputed factual

question is central to this case. Either plaintiff is telling

the truth about her story and the defendant's involvement, or

defendant is telling the truth and she was not involved

in the trafficking and ultimate abuse of plaintiff. The answer

depends on facts. Defendant's statements are therefore actionable as defamation.

Whether they ultimately prove to meet the standards of defamation,

including but not limited to falsity is a matter for

the fact finder. Order denying defendant's motion to dismiss at 10.

While this fact remains in dispute, summary judgment is foreclosed.

But even turning to defendant's claims, the avalanche of aspersions

she casts upon Ms. Roberts and her counsel should not

distract the court from the fact that the instant motion

cannot come within sight of meeting the standard for an

award of summary judgment. The most glaring and An emblematic

example of the defendant's far-fetched claims appears in her attempt

to move away from her defamatory statement by arguing that

it was her attorney, and not her, who issued the

defamatory statement for the press to publish, though she is

forced to admit the statement was made on her behalf.

This is an untenable position to take at trial, and

an impossible argument to advance at summary judgment stage as

both the testamentary and documentary evidence positively refute that argument.

Defendant incorrectly asked this court to make a factual finding

that her defamatory press release was actually a legal opinion

issued not by her but by her lawyer to the

media despite documentary evidence showing otherwise. Defendant also argues that

she has proven the truth of her statement calling Ms.

Roberts a liar with respect to the statements Ms. Roberts

made about defendant. To the contrary, evidence both documentary and

testimonial from numerous witnesses corroborate Ms. Roberts' account of defendant's

involvement in the sexual abuse and trafficking of Ms. Roberts.

Just to briefly highlight a few, Johanna Schuberg testified that

defendant recruited her under the guise of legitimate assistant position,

but asked her to perform sexual massages for Epstein and

and punished her when she didn't cause Epstein to orgasm.

Tony Figueroa testified that defendant contacted him to recruit high

school-age girls for Epstein and also testified that Maxwell and

Epstein participated in multiple threesomes with Virginia Roberts. Even more shockingly,

the butler for defendant close friend witnessed firsthand a 15-year-old

Swedish girl crying and shaking because defendant was attempting to

force her to have sex with Epstein and she refused.

This is a fraction of the testimony that will be

elicited at trial about defendant's involvement in the sexual abuse

of trafficking Ms. Roberts. Defendant's primary argument in support of

her contention that she did not abuse and traffic Ms.

Roberts as a minor child is that employment records show

that Ms. Roberts was either 16 or 17 when defendant

recruited her from her job at Mar-a-Lago for sex with Epstein,

not 15 years old, as plaintiff originally thought. Call this, yes,

I'm a sex trafficker, but only of 16-year-old girl's defense.

Defendant does not explain why sexual abuse of a 15-year-old

differs in any material way from the sexual abuse of

a 16- or 17-year-old. All instances involve a minor child

who cannot consent and who is protected by federal and

state laws. The fact remains that the defendant recruited Ms.

Roberts while she was a minor child for sexual purposes

and then proceeded to take her all over the world

on convicted pedophile Jeffrey Epstein's private jet, the Lolita Express,

as well as to his various residences and even to

her own London house. Flight logs even reveal 23 flights

that defendant shared with Ms. Roberts, although defendant claims she

was unable to remember even a single one of those flights.

Inconsequential details that Ms. Roberts may have originally remembered incorrectly

do not render her her substantive claims of abuse by

defendant false, much less deliberate lies. At most, these minor

inaccuracies in the context of a child suffering from a

troubled childhood and sexual abuse create nothing more than a

fact question on whether defendant's statements that Ms. Roberts lied

when she accused defendant of abuse is substantially true, thereby

precluding summary judgment. See Mitra Sports International LTD vs. Home

Box Office Incorporated 22F. SUPP. 3D240- 255SDNY2014. Because determining whether COI is substantially

true would require this court to decide disputed facts, summary

judgment is not appropriate. Defendant has tried to spin these

inconsequential mistakes of memory into talismanic significance and evidence of

some form of bad faith litigation, but this claim fails

under the weight of the evidence. As the court knows,

the clear weight of the evidence establishes defendant's heavy and

extensive involvement in both Jeffrey Epstein's sex trafficking ring and

in recruiting Ms. Roberts. living with her and Jeffrey Epstein

in the same homes while Ms. Roberts was a minor,

and traveling with Ms. Roberts and Jeffrey Epstein, including 23

documented flights. Even the House staff testified that defendant and Ms.

Roberts were regularly together. See the declaration of Sigrid McCauley

at Exhibit 1. Alessi's deposition at 103-4-9. Question. After that day,

do you recall that she started coming to the house?

more frequently? Answer, yes, she did. Question, in fact, did

she start coming to the house approximately three times a week? Answer, yes, probably.

It is also undisputed that a witness deposed in this

case have testified about defendant's role as a procurer of

underage girls and young women for Jeffrey Epstein. At the

very least, a trier of fact should determine whether Whether

the evidence establishes whether or not Ms. Roberts' claims of

defendant being involved in her trafficking and abuse are true.

Defendant's summary judgment motion should be denied in its entirety.

Part 2. Undisputed Facts The record evidence in this case

shows that defendant shared a household with convicted pedophile Jeffrey

Epstein for many years. While there, she actively took part

in recruiting underage girls and young women for sex with Epstein,

as well as scheduling the girls to come over and

maintaining a list of girls and their phone numbers. Ms.

Roberts was indisputably a minor when defendant recruited her to

have sex with convicted pedophile Jeffrey Epstein. Thereafter, Ms. Roberts

flew on Epstein's private jets, the Lolita Express, with defendant

at least 23 times. A. It is an undisputed fact

that multiple witnesses deposed in this case have testified that

defendant operated as convicted pedophile Jeffrey Epstein's procurer of underage girls. 1.

It is an undisputed fact that Johanna Schuberg, testified defendant,

lured her from her school to have sex with Epstein

under the guise of hiring her for a job answering phones. Ms.

Schuberg's account of her experiences with defendant are chillingly similar.

As with Ms. Roberts, defendant, a perfect stranger, approached Ms.

Schuberg while trolling Ms. Schuberg's school grounds. She lured Ms.

Schuberg into her and Epstein's home under the guise of

a legitimate job of answering phones, a pretext that lasted

only a day. A young college student nearly 2,000 miles

away from home, defendant soon instructed Ms. Schuberg to massage

Epstein and made it clear that Schuberg's purpose was to

bring Epstein to orgasm during these massages. So, that defendant

did not have to. Question, and when did you first

meet Ms. Maxwell? Answer, 2001, March probably, end of February,

beginning of March. Question, and how did you meet her? Answer,

she approached me while I was on campus at Palm

Beach Atlantic College. Question, and how long did you work

in that position? answering phones and doing? Answer, just one day. Question,

and what happened that second time you came to the house? Answer,

at that point, I met Emmy Taylor, and she took

me up to Epstein's bathroom, and he was present, and

her and I both massaged Epstein. She was showing me

how to massage, and then... She, he, took, he got

off the table, she got on the table, she took

off her clothes, got on the table, and then he

was showing me moves that he liked. And then I

took my clothes off, they asked me to get on

the table so I could feel it. Then they both

massaged me. Question, who did Emmy work for? Answer, Ghislaine. Question,

did Maxwell ever refer to Emmy by any particular term? Answer,

she called her her slaves. Question, did Jeffrey ever tell

you why he received so many massages from so many

young girls? Answer, he explained to me that, in his opinion,

he needed to have three orgasms a day. It was biological,

like eating. Question, was there anything you were supposed to

do in order to get the camera? The witness, and

remember this witness, is Johanna Schuberg. I did not know

that there were expectations of me to get the camera

until after. She, the defendant, had purchased the camera for

me and I was over there giving Jeffrey a massage.

I didn't know that she was in possession of the

camera until later. She told me, called me after I

had left and said, I have the camera for you

but you cannot receive it yet because you came here

and didn't finish your job and I had to finish

it for you. Question, and did you? What did you

understand her to mean? Answer, she was implying that I

did not get Jeffrey off and so she had to

do it. Question, and when you say, get Jeffrey off,

do you mean bring him to orgasm? Answer, yes. Question,

based on what you knew, did Maxwell know the type

of massages Jeffrey was getting typically involved sexual acts? The witness, yes. Question,

what was Maxwell's main job with respect to Epstein? The witness, well,

beyond companionship, her job, as it related to me, was

to find other girls that would perform massages for him

and herself. Ms. Schuberg, also testified about sexual acts that

occurred with her, Prince Andrew, and Ms. Roberts when she

and defendant were staying at Epstein's Manhattan mansion. Question, tell

me how it came to be that there was a

private picture taken? Schuberg answers, I just remember someone suggesting

a photo, and they told us to get on the couch,

and so Andrew and Virginia sat on the couch, and

they put the puppet, the puppet on her lap. And

so then I sat on Andrew's lap, and I believe

on my own volition, and they took the puppet's hands

and put it on Virginia's breast, and so Andrew put

his on mine. Ms. Schuberg's testimony corroborates Ms. Roberts' account

of the how defendant recruited her and others under a

ruse of a legitimate job in order to bring them

into the household to have sex with Epstein. Ms. Schuberg's

testimony corroborates Also corroborates Ms. Roberts' account of being lent

out to Prince Andrew by the defendant, as even the

interaction Ms. Schuberg witnessed included a sexual act. Prince Andrew

using a puppet to touch Ms. Roberts' breast while using

a hand to touch Ms. Schuberg's breast. Alright folks, we're

going to wrap up with Part 1 there. In the

next episode on this topic, we'll pick up with Part 2.

All of the information that goes with this episode can

be found in the description box.

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