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.