← Back to Podcast/Virginia Roberts Responds To Maxwell's Summary Judgement Request (Part 9)
Episode Transcript

Virginia Roberts Responds To Maxwell's Summary Judgement Request (Part 9)

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 picking up where we left off

with the Virginia Roberts response to Ghislaine Maxwell's attempt to

get a summary judgment. A. When Ms. Roberts initially described

her encounters with the defendant and Epstein, she mistakenly believed

the first encounter occurred during the year 1999. Discovery has

resulted in the production of records including Ms. Roberts' employment

records from Mar-a-Lago, which she did not possess at the

time she was recounting her interactions with the defendant. Those

records establish that the initial encounter wherein defendant recruited Ms.

Roberts occurred during the year 2000 and not 1999. Ms.

Roberts was 16 years old before August 9, 2000, and

turned 17 on that date. It is unclear from the

limited records available whether the defendant approached and recruited Ms.

Roberts before or just after Roberts' 17th birthday. However, what

has now been established through numerous witnesses is that defendant

approached and recruited a minor child for the purposes of

enticing that minor over to the house of Jeffrey Epstein,

a currently registered sex offender. The exact lure of Ms.

Roberts by defendant, enticement of being paid money to give

a billionaire a massage at his mansion, was used by

Epstein and his many associates and employees to recruit dozens

and dozens of other underage girls. There is no doubt

that the crux of Ms. Roberts' statements on this point

is that the defendant recruited her when she was only

a minor child, unable to consent to sex, not precisely

how far under the age of consent she was. Defendant's

public claim that Ms. Roberts' account of this approach and

recruitment element was untrue and obvious lies is not substantially true,

but is itself an obvious lie, as Ms. Roberts will

approve to the jury at trial. B. Defendant's January 2015

statement claiming as untrue and an obvious lie the allegation

that she regularly participated in Epstein's sexual exploitation of minors

and that the government knows such facts is not substantially true,

but instead completely false. Defendant next argues that she accurately

denied that she regularly participated in Epstein's sexual exploitation on

minors and that the government knows such as a fact.

MSJ at 58. It's not clear whether defendant is nitpicking

this statement by contesting whether she regularly participated in Epstein's

sexual exploitation or whether she did participate, but the government

was unaware of the extent of her involvement. Call this

the yes, I'm a sex trafficker, but only on Tuesdays

and Thursdays defense, here again, to simply recount the claim

is to see its absurdity. Contrary to defendants misleading cherry-picked

fragments of information that she has chosen to use to

support her point, there is an abundance of evidence clearly

linking defendant to Epstein's sexual exploitation of minors. As the

court is aware, numerous message pads were recovered from Epstein's home,

indicating defendants' involvement in and knowledge of Epstein's illegal exploitation. Additionally,

numerous employees and others have testified about defendants' high-ranking position

in the hierarchical structure of the sexual exploitation scheme. In fact,

multiple individuals, in addition to Ms. Roberts, have testified about

Maxwell's involvement in the exploitation of minors, including Ms. Roberts.

Defendant also argues that one government investigator, Palm Beach, Florida,

Detective Ricari, may not have been aware of her involvement

in the sex trafficking. Defendant fails to cite another passage

in Detective Ricari's deposition where he noted that he was

aware of defendant's involvement with Epstein and the sexual exploitation

of children. But even assuming Ricari was unaware, which Ms.

Roberts strongly disputes... defendant would have, at most, a yes,

I'm a sex trafficker, but I successfully hid it from

one of the cops' defense, again, not a likely claim.

More broadly, Ms. Roberts' statement about what the government knew

about sex trafficking was made in pleadings filed in a

federal court case attacking the decision of the U.S. Attorney's

Office for the Southern District of Florida to offer Jeffrey

Epstein immunity from prosecution for federal sex trafficking crimes. Accordingly,

to present an even arguable claim for summary judgment, defendant

would have to show that the U.S. Attorney's Office and

its investigators from the FBI did not know about defendant

sex trafficking. This proof would need to include, for example,

evidence that the FBI did not learn about defendant sex

trafficking when, among other things, Ms. Roberts told FBI agents

about it when she met them in Australia in 2011.

Here again, the defendant has no evidence to even begin

making such a showing. C. Defendant's January 2015 statement claiming

as untrue or an obvious lie that Maxwell and Epstein

converted Ms. Roberts into a sexual slave is not substantially true.

Defendant next argues that she accurately disputed Ms. Roberts' statement

that the defendant held her as a sex slave, relying

on dictionary definitions of slave that define the term to

refer to a confined person who is the legal property

of another, MSJ at 59, citing Merriam-Webster, etc. Defendant claims Ms.

Roberts was not confined to the property of the defendant,

call this the yes, I'm a sex trafficker, but I

didn't use chains defense. And once again, to even describe

the defense is to refute it. Defendant does not explain

why the jury would be required to use the held

in chains definition of slave, in evaluating her statement, Merriam-Webster,

11th edition, 2006. It also defines slave as one that

is completely subservient to a dominating influence, a definition that

fits Ms. Roberts' circumstances to a T. As Ms. Roberts

has explained in detail, she was recruited as a minor

child by the defendant, who then dominated her and used

her for sexual purposes. That testimony alone creates a genuine

issue of fact on this point. From the context of

all of Ms. Roberts' statements about the defendant, Ms. Roberts

has never said or implied that she was physically placed

in a cage. Instead, she has described the vast disparity

of power and the influence of defendant and Epstein, the

fear of disobedience, the typical locations of the abuse being

in a private plane, a huge mansion, man with Epstein's

employed servants, a private island, or some inescapable place abroad

in the presence of the defendant and in addition to

the continued and fraudulent promise of a better future, as

those things that kept her retained in a situation of

sexual servitude. While not physical chains, Ms. Roberts was groomed

as a minor and trained, and these factors became her

invisible chains. Indeed, as Ms. Roberts' expert on sex trafficking,

Professor Coonan, has explained, Popular understanding of the term sex

slave might still connote images of of violent pimps, white slavery,

or of victims chained to a bed in a brothel

in the minds of some people. To call Ms. Roberts

a victim of sex trafficking would, however, very accurately convey

the reality that she, along with a great many other

victims of contemporary forms of slavery, are often exploited by

the invisible chains of fraud and psychological coercion. See Macaulay

Declaration at Exhibit 23, Koonin Expert Report at 20. If

this court takes as true, which it must for the

purpose of this motion, that Ms. Roberts was trafficked and

used exclusively for sexual purposes by the defendant and Epstein,

then the court must also reach the conclusion at this

stage that Maxwell's assertion that Ms. Roberts' description of being

a sex slave is untrue or obvious lies is not

substantially true. There undoubtedly remains a genuine issue of material

fact on this point and, in fact, defendant's position taken

in this motion is tantamount to an admission of the

truth of plaintiff's statement about defendant on this point. D.

Any statement misdirection regarding Professor Alan Dershowitz is nothing more

than an irrelevant distraction to the facts of this case

and matters not on the defense of whether defendant's statement

was substantially true. Defendant next contends that she accurately recounted

that Alan Dershowitz had denied having sex with Ms. Roberts.

MSJ at 60. Call this the yes, I'm a sex trafficker,

but she was not trafficked to the professor defense. While

it is accurate that Ms. Roberts made allegations against Professor Dershowitz,

those allegations are not at issue in this case. Defendant,

in her defamatory statement, claimed that the allegations made by Ms.

Roberts against Ghislaine Maxwell are untrue. See McCauley Declaration at

Exhibit 26, GM 00068. In her deposition, Defendant, maintained the

position that she cannot speculate on what anybody else did

or didn't do. C. McCauley, Declaration at Exhibit 11, Maxwell, 4-22-2016.

In fact, regarding Ms. Roberts' claims about others, defendant unequivocally stated,

I can only testify to what she said about me,

which was 100% false. C. McCauley, Declaration at Exhibit 11, Maxwell,

makes additional misstatements about Dershowitz's production in a defamation action

filed against him in her desperate attempt to have Dershowitz

jump aboard and help bail out her sinking canoe. Ms.

Roberts can, and if necessary will, refute Dershowitz's claim he

was not a beneficiary of Epstein and defendant sex trafficking.

That is not relevant at this stage. Whatever may or

may not have happened with Dershowitz and Ms. Roberts' sworn

statement that he sexually abused her is alone enough to

create disputed facts on the issue of whether defendant's statements

about him are substantially true, has no bearing whatsoever on

the truth or falsity of the statements Ms. Roberts made

about the defendant. This case is not about whether Ms.

Roberts has ever made untruthful allegations against anyone, which she

contends she has not, but about whether her allegations about

defendant were true. or whether those specific allegations were untrue,

obvious lies, as defendant publicly proclaimed. These issues are disputed

and must go to the jury. E. Contrary to the

defendant's position, there is a genuine issue of material fact

as to whether she created or distributed child pornography or

whether the government was aware of the same. Defendant next

argues that she did not create child pornography and that

the government knew this. Call this the until you find

the photos on innocent defense. Of course, as noted earlier,

defendant's claim requires that she show the government in context.

The FBI and the U.S. Attorney's Office for the Southern

District of Florida knew that she had no child pornography.

Yet defendant has offered no such evidence, much less evidence

so powerful as to warrant summary judgment on this point.

This point is disputed. From the simple fact that Ms.

Roberts herself testified that defendant took many photographs of her naked.

See McCauley Declaration at Exhibit 5. Roberts' deposition at 232, 3-9. 233, 7-9.

This is consistent with the Palm Beach butler Alfredo Rodriguez

testimony that he personally saw photos of naked children on

the defendant's computer. See McCauley Declaration at Exhibit 21. Rodriguez'

deposition at at 1.50, 10-17, 3.06, 1-3.06, and 24. Another housekeeper,

Juan Alessi, also saw photos of young, nude females on

the defendant's computer, although he wasn't aware or sure whether

to consider it pornography. See McCauley Declaration at Exhibit 1. Finally,

Detective Ricari found a collage of nude photos of young

females in Epstein's closet and turned the photos over to

the FBI and the U.S. Attorney's Office. While the U.S.

Attorney's Office will not share the photos obtained from Ricari's investigation,

it is thus undisputed that the government possesses photos of nude,

young females confiscated from Epstein's Palm Beach mansion. Indeed, the

police video, disclosed through a Freedom of Information request, shows

naked images of women throughout the house, including a full

nude of the defendant. At a minimum, there is a clear,

genuine issue of material fact in this regard. F. Defendant

did act as a madam for Epstein to traffic Miss

Roberts to the rich and the famous. Defendant X argues

that she did not act as a madam for Epstein.

MSJ at 63. The gist of the argument seems to

be that the defendant believes trafficking one girl to Epstein

does not a madam make. Call this, yes, I was

Virginia's madam, but no one else's defense. This argument fails

linguistically on the very dictionary definitions that defendant cites elsewhere,

but not here. See Merriam-Webster, 11th edition, 2006, defining Madam

as the female head of prostitution. Once again, defendant conceals

the relevant facts on this issue. First, multiple witnesses have

testified to defendants recruiting, maintaining, harboring, and trafficking girls for Epstein.

In fact, defendant herself was unable to deny procuring Ms.

Roberts for Epstein. While defendant has attempted to fumble her

way through explaining some plausible reason, For bringing a 16

or 17-year-old to Epstein, her explanations are, to put it blandly, unpersuasive.

As with other issues, the jury will have to decide

who to believe. One of the individuals Ms. Roberts was

trafficked to was Prince Andrew. Trafficking that took place in

the defendant's own townhouse in London. There exist flight logs

evidencing Ms. Roberts flying to London alongside defendant and Epstein.

on Epstein's private plane, and a photo of Ms. Roberts, defendant,

and the prince without defendant ever offering a legal, reasonable

explanation for that photo being taken or for traveling with

a year-old girl overseas. Defendant begins to meander somewhat aimlessly

on this point, shifting plaintiff's burden to substantiate plaintiff's claim

that defendant was Epstein's madam, which at this point, at

issue into whether or not plaintiff has conclusively proven the

identities and accurate job titles of the other men to

whom plaintiff was lent for sex by Epstein. No matter

how hard defendant tries to reframe the case, drag other

people in, or split hairs, she is unable to contest

the facts, facts showing she was more than a madam,

but a full-fledged sex trafficker. Ms. Roberts told the truth,

when she said the defendant recruited her as a minor

under the pretense of giving her a massage and converted

her into a traveling sex slave consistent with defendant and

Epstein's pattern of practice. As the court astutely acknowledged early on,

at the center of this case is the veracity of

a contextual world of facts more broad than the allegedly

defamatory statements. Either transgressions occurred or it did not. Either

Maxwell was involved or she was not. If defendant was involved,

then her January 2015 statement was defamatory. Ms. Roberts will

prove to the jury, through overwhelming evidence, her prior allegations

about defendant's involvement. The court should give Ms. Roberts that

opportunity and deny the defendant's motion for summary judgment. Conclusion.

For the foregoing reasons, this court should deny defendant's motion

for summary judgment in all respects. This was signed by

Sigrid McCauley and it was dated January 31st, 2017. All right, folks,

that's going to conclude our look at Virginia Roberts' response

to Ghislaine Maxwell's attempt to get a summary judgment. And

if you're not disgusted yet, just wait. Plenty more is

on the way. All of the information that goes with

this episode can be found in the description box.

This transcript was automatically generated by the podcast creator and may contain errors. Aggregated via the PodcastIndex API.