Virginia Roberts Responds To Maxwell's Summary Judgement Request (Part 3)

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 continue talking about Virginia

Roberts and her response to Glenn Maxwell and Maxwell's request

for a summary judgment. 9. It is an undisputed fact

that defendant was unable to garner a single witness throughout

discovery who can testify that she did not act as

the procurer of underage girls and young women for Jeffrey Epstein.

Defendant has not been able to procure a single witness,

not one, to testify that defendant did not procure girls

for sex with Epstein or participate in the sex. Even

one of her own witnesses, Tony Figueroa, testified that she

both procured girls and participated in the sex. Another, one

of the defendant's witnesses, Ms. Roberts' mother, named defendant as Ms.

Roberts' new mama. Indeed, those who knew her well, who

spent considerable time with her in Epstein's shared household, like

Juana Lessie, Alfredo Rodriguez, and Joanna Schuberg, have testified that

she was Epstein's procuress. Others who live with her, Jeffrey Epstein,

Nadia Marcinkova, and Sarah Kellan, invoked the Fifth Amendment so

as to not answer questions on the same. No one

testified to the contrary. B. Documentary evidence also shows that

defendant trafficked Ms. Roberts and procured her for sex with

the convicted pedophile, Jeffrey Epstein, while she was underage. 1.

The flight logs. Defendant has never offered a legal explanation

for what she was doing with and why she was

traveling with a minor child on 21 flights while she

was a child, including six international flights aboard a convicted

pedophile's private jet all over the world. Her motion for

summary judgment, as well as previous briefing papers, are absolutely

silent on those damning documents. 2. The photographs. Throughout the

mountain of briefing and even in her own deposition testimony,

defendant never offered an explanation regarding Miss Roberts' photographs of her, defendant,

and Epstein. She never offered a legal explanation for why

Prince Andrew was photographed with his hand around Miss Roberts'

bare waist while she was a minor child while posing

with defendant inside defendant's house in London. This particular photograph

corroborates Miss Roberts' claims and there is no other reasonable

explanation why an American child should be in the company

of adults not her kin in the London house owned

by the girlfriend of a now convicted sex offender. Ms.

Roberts also produced pictures of herself taken when she was

in New York with defendant Ann Epstein and from a

trip to Europe with defendant Ann Epstein. And Ms. Roberts

has produced a number of pictures of herself taken at

Zorro Ranch Epstein's New Mexico ranch, two of which are below. Finally,

among other nude photos which included full nudes of defendant, Ms.

Roberts produced images of females that the Palm Beach police

confiscated during the execution of the warrant, including one photograph

revealing the bare bottom of a girl who appears to

be pre-pubescent Ms. Roberts. We will only submit in its

redacted form. The Victim Identification Letter In 2008, The United

States Attorney's Office for the Southern District of Florida identified Ms.

Roberts as a protected victim of Jeffrey Epstein's abuse. The U.S.

Attorney mailed Ms. Roberts a notice of her rights as

a crime victim under the CVRA. 4. New York Presbyterian

Hospital Records Ms. Roberts has provided extensive medical records in

this case, including medical records from the time when defendant

was sexually abusing and trafficking her. Ms. Roberts produced records

supporting her claim of being sexually abused in New York,

resulting in both the defendant and Epstein taking plaintiff to

New York Presbyterian Hospital in New York while she was

a minor. The dates on the hospital records show she

was 17 years old. 5. Judith Lightfoot Psychological Records As

the court is aware, defendant propounded wildly overbroad requests for

production concerning the past 18 years of Ms. Roberts' medical history.

The defendant repeatedly argued to the court that it was

essential to procure every page of those records in a

fanfare of unnecessary motion practice, c.e.g. defendant's motion to compel,

defendant's motion for sanctions at 10, Ms. Maxwell has been

severely prejudiced by plaintiff's failure to provide the required identifying

information and documents from her health care providers. Ms. Roberts

and her counsel took on the considerable burden and significant

expense of retrieving and producing over 250 pages of medical

records from over 20 providers spanning two continents and nearly

two decades. Now that those records have been collected, Defendant's

68-page motion makes no reference to a single medical record

produced by Ms. Roberts, nor a single provider, nor a

single treatment, nor a single medication prescribed. After defendant's repeated motion, practice,

stressing the essentiality of these records, this may surprise the court,

but not Ms. Roberts. Defendant's request unearthed documents that are

highly unfavorable to defendant that corroborate Ms. Roberts' claims against her.

Years before this cause of action arose, Ms. Roberts sought

counseling from a psychologist for the trauma she continued to

experience after being abused by defendant and Epstein. A 2011

psychological treatment record written by her treating psychologist unambiguously describes

defendant as Ms. Roberts' abuser. Ms. Roberts was approached by

Ghislaine Maxwell, who said she could help her get a

job as a massage therapist, seem respectable, was shown how

to massage, etc., Groff, Epstein, told to undress and perform

sexual acts on person, Ms. Maxwell promised her 200 bucks

after a job. Therefore, years after defendant defamed her, Ms.

Roberts confided in her treating psychologist that Maxwell recruited her

for sex with Epstein. Number six, message pads. Detective Ricari,

the lead investigator of the criminal investigation into Epstein and

his associate's crime sex, recovered carbon copies of of handwritten

messages taken by various staff, including defendant, at Epstein's Palm

Beach residence. These were collected both from trash pulls from

the residence and during the execution of the search warrant

where the pads were found laying out in the open

in the residence. The search warrant was executed in 2005.

and the message pads collected include messages recorded in 2004

and 2005. Numerous witnesses have described these copies of collected

messages accurately reflect those taken by various staff at the

Palm Beach Epstein Mansion between 2004 and 2005. The messages

raise the question, of fact as to Maxwell's involvement in

the sexual abuse of minors and are relevant to refute

Maxwell's denial of any involvement with Epstein during relevant time

periods and, accordingly, her denial of knowledge of certain events.

While there were hundreds of these messages recovered during the investigation,

this small sample demonstrates the undeniable reality that there exists

a genuine issue of material fact with respect to defendants'

involvement in and knowledge of the activities described by Roberts,

which Maxwell has said were untrue and obvious lies. This

sample reveals that Maxwell, GM, took messages at the residence,

including from underage girls who were calling to schedule a

time to come over to see Epstein. This demonstrates that

Maxwell was at Epstein's Palm Beach mansion in 2004 and 2005, Incidentally,

a time period she is denied being around the house

in her deposition. C. Roberts 001412 001435 001449 The messages

also reveal that multiple girls were leaving messages that were

being taken and memorialized and left out in the open

for anyone to see. Certain messages also make clear that

a number of these girls were in school. in addition

to taking messages herself and the staff working under her

direction taking these relevant messages. Staff employees were taking and

leaving messages for the defendant. This is evidence that Maxwell

was in the house at relevant times, including times that

she has now testified under oath that she was not there.

Other messages demonstrate Epstein and Maxwell's friends, including Jean-Luc Brunel,

leaving messages relating to underage females. The following are descriptions

of a sampling of message pads that create a genuine

dispute of material facts. One message pad reflects Redacted, who

is identified in the Palm Beach Police report as a minor,

contacting Jeffrey Epstein for work explaining that she does not

have any money. The term work was often used by

members of Jeffrey Epstein's sexual trafficking ring to refer to

sexual massages. C. Roberts, at 05660. She stated she was

called by Sarah for her return to work for Epstein.

Redacted stated work is the term used by Sarah to

provide the massage and underwear. Robert001462 July 5th, no year

to J.E. from Redacted. I need work. I mean, I

don't have money. Do you have some work for me?

Other message pads reflect Redacted, who is a minor, calling

and leaving a message at the Palm Beach Mansion. that

she has recruited another girl for Jeffrey Epstein, the second

massage demonstrates that Jeffrey Epstein required different girls to be

scheduled every day of the week. The third shows an

offer to have two minor girls come to the home

at the same time to provide sexual massages. These type

of massages indicate the lack of secrecy of the fact

that multiple young females were visiting every day and at

least raises a question of fact whether Maxwell was knowledgeable

and involved as Roberts has said or whether Roberts was

lying and Maxwell was not at all involved or aware

of this activity as defendant would attempt to have the

world believe. Roberts 001428 updated Jeffrey from redacted Has Girl

for Tonight Roberts 001432 7904. Mr. Epstein from Redacted Redacted

is available on Tuesday. No one for tomorrow. Mr. Epstein

from Redacted. Me and Redacted can come tomorrow anytime or

Redacted alone. Roberts 001452. Undated Jeffrey from Redacted has a

girl for tonight. Other message pads demonstrate. that there was

a pattern and practice of using young females to recruit

additional females to provide sexual massages on a daily basis.

Roberts 001413. J.E. from N. Redacted hasn't confirmed redacted for

11 yet, so she is keeping redacted on hold in

case redacted doesn't call back. Roberts 00144882005. J.E. from Redacted

Redacted confirmed At 4 p.m. Who is scheduled for the morning?

I believe redacted wants to work. This message pad reflects

that a friend of Jeffrey Epstein is sending him a

16-year-old Russian girl for purposes of sex. Roberts 001563 6105

For Jeffrey from Jean-Luc. He has a teacher for you

to teach you how to speak Russian. She is 2

times 8 years old and not blonde. Lessons are free.

and you can have your first today if you call.

This message pad directly refutes Maxwell's sworn testimony that she

was not present during the year 2005 at Jeffrey Epstein's

Palm Beach mansion because this show's redacted, leaving a message

for Jeffrey at the Palm Beach home that she was

going to work out with the defendant on September 10th, 2005.

The police were only able to retrieve a fraction of

these message pads During their trash pull, but even in

the few they recovered, it shows Maxwell was regularly at

the Palm Beach home during the time period she claimed

she was not. To the contrary, she was both sending

and receiving messages, like this one, reflect her presence at

the mansion, Roberts 00141291005, during the year Maxwell says she

was never around. JE from Redacted, I went to Sarah

and made her a water bottle and I went to

work out with GM. These message pads further corroborate that

defendant lied in her testimony and she was in fact

in regular contact with Jeffrey Epstein during the years 2004

and 2005. For example, the message from Larry demonstrates that

defendant is at the Palm Beach mansion so frequently that people,

including Epstein's main pilot, Larry Vesoski, are leaving messages for

Maxwell at the Palm Beach house. Roberts 00143572504 Mr. Epstein

from Ms. Maxwell. Tell him to call me. Roberts, 00-1449-8202-05. J.E.

from GM. Roberts, 00-1453-425-04. For Ms. Maxwell from Larry, returning

your call. This message pad shows that defendant was clearly

actively involved in Jeffrey Epstein's life and the activities at

his Palm Beach mansion. Roberts, 00-1454-Updated- Jeffrey from Galane would

be helpful to have redacted come to Palm Beach today

to stay here and help train the new staff with Galane.

This message pad clearly reflects an underage female noted by

the police redaction of the name, leaving a message asking

if she can come to the house at a later

time because she needs to stay in school. Roberts 001417

Jeffrey 22805 Redacted name She is wondering if 2.30 is okay.

She needs to stay in school. The message pad reflects

a message from redacted who was under the age of

18 at the time she was going over to Jeffrey

Epstein's home to provide sexual massages according to the Palm

Beach investigative report. Roberts 001423405 to Jeffrey Epstein from redacted.

It is okay for redacted to stop by and drop something.

The message pads reflect the pattern. of underage girls noted

by the police redaction of the name on the message pad.

Calling the Palm Beach mansion to leave a message about

sending a female over to provide a sexual massage, Roberts 001423,

11804 to Mr. J.E., redacted from, I have a female

for him, Roberts 001426, 10905, J.E. to J.E., from redacted,

I have a female for him, This message pad reflects

the pattern and practice of having young girls bring other

young girls to the house to perform sexual massages. Indeed,

the redacted reflected in this message pad corresponds in name

to the redacted that Tony Figueroa testified he initially brought

to Jeffrey Epstein's during the time period that the defendant

was requesting that Tony find him some young females to

bring to Jeffrey Epstein's home. See Figueroa at 184 and 185.

The Palm Beach Police report reflects that Redacted and Redacted

also brought 17-year-old Redacted to the home to perform sexual massages. C. Roberts, 05641, Redacted,

thereafter recruited a number of other young girls to perform

sexual massages, as reflected in the Palm Beach Police report. Roberts, 001427, 1203, J.E.

from Redacted, wants to know if she should bring her

friend with Redacted tonight. This message pad reflects sexual massages

being scheduled for the same day, which corroborates Virginia Roberts, redacted,

and Johanna Schuberg's testimony that Jeffrey Epstein required that he

have multiple orgasms in a day, which occurred during these

sexual massages. Roberts, 00144990305JE from redacted. I left a message

for redacted to confirm for 11 a.m. and redacted for 4.30 p.m.

This message pad shows a friend of Jeffrey Epstein's discussing

with him how he had sex with an 18-year-old who

had also been with Jeffrey Epstein. Robert001456 updated, J.E. from Jean-Luc.

He just did a good one. 18 years. She spoke

to me and said, I love Jeffrey. Law enforcement was

able to confirm identities of underage victims through the use

of the names and telephone numbers in these message pads. Question,

the next line down, is what I wanted to focus on.

April 5th, 2005. This trash pull. What evidence is yielded

from this particular trash pull? The witness, the trash pull

indicated that there were several messages with written items on it.

There was a message from HR indicating that there would

be an 11 o'clock appointment. There were other individuals that

had called during that day. And this is Detective Ricari

answering these questions. Answer, and when you would, when you

would see females' names and telephone numbers, would you take

those telephone numbers and match it to a person? Witness,

we would do our best to identify that person was. Question,

and is that one way in which you discover the

identities of some of the other what soon to became

known as the victims? The witness, correct. Question, do you

find names of other witnesses and people that you knew

to have been associated with the house in those message pads?

The witness, yes. Question. And so what was the evidentiary

value to you of the message pads collected from Jeffrey

Epstein's home in that search warrant? Rick Harry, it was

very important to corroborate what the victims had already told

me as to calling in and for work. All right, folks,

we're going to wrap up this episode here. In the

next episode, we're going to pick up where we left

off and start talking about the black book. All of

the information that goes with this episode can be found

in the description box.