Virginia Roberts Responds To Maxwell's Summary Judgement Request (Part 2)

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.

In this episode we're going to pick up where we

left off with Virginia Roberts and her response to Ghislaine

Maxwell seeking a summary judgment. 2. It is an undisputed

fact that Tony Figueroa testified that defendant would call him

to bring over underage girls and that the defendant and

Epstein would have threesomes with Ms. Roberts. Tony Figueroa testified

that That plaintiff told him about the threesomes Ms. Roberts

had with defendant Ann Epstein, which included the use of strap-ons. Question,

and tell me everything that you remember about what Ms.

Roberts said about being intimate with Ms. Maxwell and Mr.

Epstein at the same time. Figueroa responds, I remember her

talking about, like, strap-ons and stuff like that, but I mean,

like I said... All the details are not really that clear,

but I remember her talking about, like, how they would

always be using that stuff like that. Question, she and Ms.

Maxwell and Mr. Epstein would use strap-ons? Figueroa responds, uh-huh. Question,

other than sex with the prince, is there anyone else

that Jeffrey wanted Ms. Roberts to have sex with that

she relayed to you? Answer, mainly, like I said, just Ms.

Maxwell and all the other girls. Question, Ms. Maxwell wanted,

Jeffrey wanted, Virginia to have sex with Ms. Maxwell? Answer,

and him, yeah. Question, and did she tell you whether

she had ever done that? Answer, yeah, she said she did. Question,

and what did she describe having happened? Answer, I believe

I already told you that, with the strap-ons and dildos

and everything. Redacted, redacted. Figueroa also testified that defendant... Called

him to ask if he had found any other girls

for Epstein, thereby acting as a procurer of girls for Epstein. Question,

when Ghislaine Maxwell would call you during the time that

you were living with Virginia, she would ask you what specifically? Answer,

just if I found other girls to bring to Jeffrey. Question, okay. Answer,

pretty much every time there was a conversation between With

any of them, it was either asking Virginia where she

was at or asking her to go get girls or

asking me to go get girls. Question. Okay, well, tell me.

When did Ms. Maxwell ask you to bring a girl? Answer.

Never in person. It was like literally like on the phone,

maybe like once or twice. Question. All right. Did Ms.

Maxwell call you frequently? Answer. No. Question. All right. How

many times did you think Ms. Maxwell called you at all? Answer.

I'd just say that probably just a few, a couple

of times, maybe once or twice. Question. One or two. Answer.

The majority of the time, it was pretty much his assistant. Question.

How do you know Ms. Maxwell's voice? Answer. Because she

sounds British. Question. So someone with a British accent called

you once or twice and asked for? Answer. Well, she

told me who she was. Question. Okay. And what did

she say when she called you and asked you to

bring girls? Answer. She just said, hi, this is Ghislaine.

Jeffrey was wondering if you had anybody that could come over. Three.

It is an undisputed fact that Rinaldo Rizzi testified that

defendant took the passport of a 15-year-old Swedish girl and

threatened her when she refused to have sex with Epstein.

Rinaldo Rizzi was the house manager for one of defendant's

close friends, Eva Dubin. Mr. Rizzo testified through tears how

while working at Dubin's house, he observed defendant bring a

15-year-old Swedish girl to Dubin's house. In distress, the 15-year-old

girl tearfully explained to him that defendant tried to force

her to have sex with Epstein through threats and stealing

her passport. Question. How old was this girl? Answer. 15

years old. Question. Describe to me what the girl looked like,

including her demeanor and anything else you remember about her

when she walks into the kitchen. Answer, very attractive, beautiful

young girl, makeup, very put together, casual dress, but seemed

to be upset, maybe distraught, and she was shaking. And

as she sat down, she sat down and sat in

the stool exactly the way the girls that I mentioned

to you sat at Jeffrey's house, with no expression and

with her head down. But we could tell that she

was very nervous. Question, what do you mean by distraught

and shaking? What do you mean by that? Answer, shaking.

I mean literally quivering. Question, what did she say? Answer,

she proceeds to tell my wife and I that, and

this is not, this is blurting out, not a conversation

like I'm having casual conversation. That quickly, I was on

an island. I was on the island and there was Ghislaine.

There was Sarah. She said they asked for sex. I

said no. And she is just rambling. And I'm like, what?

And she said, I asked her, I said, what? And

she says, yes, I was on the island. I don't

know how I got from the island to here. Last

afternoon or in the afternoon, I was on the island

and now I'm here. And I said, do you have a,

this is not making any sense to me. And I said,

this is nuts. Do you have a passport? Do you

have a phone? And she says, no. And she says,

Ghislaine took my passport. And I said, what? And she

says Sarah took her passport and her phone and gave

it to Ghislaine Maxwell. And at that point she said

she was threatened. And I said threatened? She said yes.

I was threatened by Ghislaine Maxwell not to discuss this.

And I'm just shocked. So the conversation, and she is

just rambling on and on again. Like I said, how

she got here, she doesn't know how she got here.

Again I asked her, did you contact your parents? And

she says no. At that point she says, I'm not

supposed to talk about this. I said, but I said,

how did you get here? I don't understand. We were

totally lost for words. And she said that before she

got there, she was threatened again by Jeffrey and Ghislaine

not to talk about what I had just mentioned earlier.

And she said that she was used for sex. Question.

And during this time that you're saying she is rambling,

is her demeanor continues to be what you described it? Answer. Yes. Question.

Was she in fear? Yes. Question. Could you tell? Answer, yes. Answer,

she was shaking uncontrollably. Now, just to interject here, how

do you let that even occur? How does Mr. Rizzo

let that occur and not directly grab this girl and

take her to the nearest police station? Or if you

really want to go down as a hero, don't you

just break Jeffrey Epstein's face right then and there? I

know I would have. It would have been well worth it.

Number four, it is an undisputed fact that Lynn Miller

testified that she believed defendant became Robert's new mama. Lynn

Miller is Robert's mother. She testified that when Robert started

living with Defendant, Defendant became Robert's new mama. Incredulously, Defendant

testified that she barely remembered Miss Roberts. 5. It is

an undisputed fact that Detective Joseph Ricari testified that he

sought to investigate Defendant in relation to his investigation of

Jeffrey Epstein. Detective Ricari led the Palm Beach Police investigation

of Epstein. He testified that defendant procured girls for Epstein

and that he sought to question her in relation to

his investigation, but could not contact her due to the

interference of Epstein's lawyer. Question. Cross-reference of Jeffrey Epstein's residence

revealed which affiliated names? Answer. It revealed Nadia Marcinkova, Ghislaine Maxwell,

Mark Epstein. Also the cross-reference. Any previous reports from the

residence as well? Question. During your investigation, did you learn

of any involvement that Nadia Marcinkova had with any of

the activities that you were investigating? Question. The other name

that is on here, as a cross-reference, is Ghislaine Maxwell.

Did you speak with Ghislaine Maxwell? Answer. I did not. Question.

Did you ever attempt to speak with Ghislaine Maxwell? Answer.

I wanted to speak with everyone related to this home,

including Ms. Maxwell. My contact was through Gus, attorney Gus Fronston.

at the time, who initially had told me that he

would make everyone available for an interview. And subsequent conversations later,

no one was available for an interview, and everybody had

an attorney, and I was not going to be able

to speak with them. Question, okay, during your investigation, what

did you learn in terms of Ghislaine Maxwell's involvement, if any?

The witness, Ms. Maxwell, during her research, was found to

be Epstein's longtime friend. During the interviews, Ms. Maxwell was

involved in seeking girls to perform massages, and work at

Epstein's home. Number six, it is an undisputed fact that

pilot David Rogers testified that he flew defendant and Ms.

Roberts at least 23 times on Epstein's jet, the Lolita Express,

and that GM on the flight log stands for Ghislaine Maxwell. Notably,

at defendant's deposition, defendant refused to admit that she flew

with Ms. Roberts and denied that she appeared on Epstein's

pilot's flight logs. However, David Rogers, Epstein's pilot, testified that

the passenger listed on his flight logs bearing the initials

GM was in fact Ghislaine Maxwell, and that he was

the pilot on at least 23 flights in which defendant

flew with plaintiff. The dates of those flights show that Ms.

Roberts was an underage child on many of them when

she flew with defendant. Number seven. It is an undisputed

fact that Sarah Kellan, Nadia Marcinkova, and Jeffrey Epstein invoked

the Fifth Amendment when asked about defendants trafficking girls for

Jeffrey Epstein. Both Sarah Kellan and Nadia Marcinkova lived with

Jeffrey Epstein for many years. They both invoked the Fifth

Amendment when asked about defendants' participation in recruiting underage girls

for sex with Epstein. Marcinkova testified as follows. Question. Marcinkova,

same answer. Invoking the Fifth. Question, have you observed Ghislaine

Maxwell and Jeffrey Epstein convert what started as a massage

with these young girls into something sexual? Again, she takes

the fifth. Kellan testified as follows. Did Ghislaine Maxwell work

as a recruiter for young girls for Jeffrey Epstein when

you met her? Answer, on advice of my counsel, I

must invoke the Fifth Amendment and the Sixth Amendment privilege. Question,

isn't it true that Ghislaine Maxwell would recruit underage girls

for sex? and sex acts with Jeffrey Epstein? Answer, on

advice of my counsel, I must invoke my Fifth and

Sixth Amendment privilege. Similarly, Jeffrey Epstein invoked the Fifth Amendment

when asked about defendants' involvement in procuring underage girls for

sex with him. Question, Maxwell was one of the main

women whom you used to procure underage girls for sexual activities, true?

The witness, Fifth. Question. Maxwell was a primary co-conspirator in

your sexual abuse scheme. True. Epstein. Fifth. Question. Maxwell was

a primary co-conspirator in your sex trafficking scheme. True. Epstein. Fifth. Question.

Maxwell herself regularly participated in your sexual exploitation of minors. True. Witness. Fifth. Eight.

It is an undisputed fact that Juan Alessi testified that

defendant was one of the people who procured over 100

girls he witnessed visit Epstein and that he had to

clean defendant's sex toys. Juan Alessi was Epstein's house manager.

He testified as follows. Question. And over the course of

that 10-year period, while Ms. Maxwell was at the house,

do you have any approximation as to the number of

different females, females that you were told were a massage

therapist that came to the house? Alessi, I cannot give

you a number, but I would say probably over 100

in my stay there. Question. I don't think I asked

that right. The question that I was looking to ask,

so let me go back. Did you go out looking

for the girls? Answer, no. Question, to bring? Answer, never. Question,

as a massage therapist? Alessi, never. Question, who did? Answer, Ms. Maxwell, Mr. Epstein,

and their friends, because their friends relay to other friends.

They knew a massage therapist. and they would send to

the house, so it was referrals. Question, did you have

occasion to clean up after the massages? Answer, yes. Question, okay,

and that is after both a massage for Jeffrey Epstein

as well as clean up after a massage that Ghislaine

Maxwell may have received? Answer, yes. Question, and on occasion after,

in cleaning up after a massage of Jeffrey Epstein or

Ghislaine Maxwell, did you have occasion to find vibrators or

sex toys that would be left out? Answer, yes, I did.

All right, we're going to wrap up with episode two

right there. And in the next episode on topic, we'll

pick up where we left off. All of the information

that goes with this episode can be found in the

description box.