Ghislaine Maxwell's Undisputed Statement Of Facts Pursuant To Virginia's Allegations (Part 4)

Ghislaine Maxwell’s Rule 56.1 request in the defamation lawsuit brought by Virginia Roberts Giuffre was a procedural move designed to narrow the case before trial by asking the court to treat Maxwell’s version of certain facts as undisputed. Under Local Rule 56.1, parties seeking summary judgment have to lay out the material facts they claim are not genuinely in dispute, with citations to admissible evidence. Maxwell argued that Giuffre’s response failed that test because, in Maxwell’s view, Giuffre did not properly support many of her denials with admissible evidence. Maxwell also objected to Giuffre adding her own supposedly “undisputed facts,” arguing that Giuffre had not filed her own cross-motion for summary judgment and therefore could not use the Rule 56.1 process to smuggle in a competing fact narrative.

The request mattered because it was not just a dry filing dispute; it went directly to how Maxwell wanted the court to view the foundation of Giuffre’s claims. Maxwell sought to have several facts deemed admitted, including points about Giuffre’s earlier media interviews, the 2011 and 2015 statements issued on Maxwell’s behalf, the way Giuffre’s allegations appeared in prior court filings, and whether media republication of Maxwell’s denials could legally be pinned on Maxwell. In plain English, Maxwell was trying to box Giuffre in procedurally: if the court accepted Maxwell’s Rule 56.1 position, it would weaken Giuffre’s ability to argue that there were disputed facts requiring a jury trial. But the broader context is that this was part of Maxwell’s aggressive defense strategy in the 2015 defamation case, where Giuffre sued after Maxwell publicly branded her allegations false; the case eventually settled, while the sealed filings later became a major source of Epstein-related disclosures.


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