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:
bobbycapucci@protonmail.com
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.