Latest / Beyond The Horizon / Virginia Roberts And Her 2nd Supplemental Response To Maxwell's Discovery Request (Part 4) (10/28/26)

Transcript

Virginia Roberts And Her 2nd Supplemental Response To Maxwell's Discovery Request (Part 4) (10/28/26) · Beyond The Horizon

• 0:00
  Speaker 1: What's up, everyone, and welcome back to the Epstein Chronicles.
• 0:04
  Speaker 1: In this episode, we're going to dive right back in
• 0:06
  Speaker 1: to the court documents, and we're going to continue looking
• 0:09
  Speaker 1: at Virginia Roberts' response to the second supplemental request by
• 0:14
  Speaker 1: Ghislaine Maxwell. Number three, all documents from any law enforcement agency,
• 0:19
  Speaker 1: whether local, state, federal, whether in the United States or elsewhere,
• 0:23
  Speaker 1: which concerns or relates to you in any way, these
• 0:26
  Speaker 1: documents should include without limitation any witness statements, including statements
• 0:31
  Speaker 1: made by you. Response to request number three. Ms. Roberts
• 0:36
  Speaker 1: objects to the request and that it seeks information that
• 0:39
  Speaker 1: is protected by the attorney-client work product, public interest privilege,
• 0:43
  Speaker 1: and other applicable privileges. Ms. Roberts objects to this request
• 0:47
  Speaker 1: and that it is not limited in time period. Subject
• 0:50
  Speaker 1: to and without waiving the above objections, Ms. Roberts has
• 0:53
  Speaker 1: already produced documents Bates labeled Robert00001 to Robert005353 and will
• 1:02
  Speaker 1: produce non-privileged documents responsive to this request and will continue
• 1:06
  Speaker 1: to supplement her production. Ms. Roberts is withholding documents that
• 1:11
  Speaker 1: concern or relate to any current ongoing investigation by any
• 1:15
  Speaker 1: law enforcement agency under the public interest privilege and other
• 1:19
  Speaker 1: applicable privileges. Four, all documents reflecting any letter of engagement,
• 1:24
  Speaker 1: any fee agreement, or any other type of writing reflecting
• 1:27
  Speaker 1: an engagement of any attorney identified in response to interrogatory
• 1:32
  Speaker 1: number three. Response to request number four, Ms. Roberts objects
• 1:36
  Speaker 1: to this request in that it seeks information that is
• 1:39
  Speaker 1: protected by the attorney-client, work product, joint defense, and other
• 1:43
  Speaker 1: applicable privileges. Ms. Roberts is withholding documents based on this objection. Specifically, Ms.
• 1:49
  Speaker 1: Roberts is withholding documents reflecting the engagements between herself and
• 1:54
  Speaker 1: her attorneys she has engaged in relation to the above-captioned
• 1:58
  Speaker 1: action and other actions as those documents involve privileged communications. 5.
• 2:04
  Speaker 1: Documents relating to any communications occurring from 1998 to the present,
• 2:09
  Speaker 1: with any of the following individuals or with their attorneys, agents,
• 2:13
  Speaker 1: or representatives. A. Jeffrey Epstein. B. Glenn Maxwell. C. Any
• 2:18
  Speaker 1: witness disclosed in Plaintiff Rule 26A disclosures. D. Any witnesses
• 2:24
  Speaker 1: identified by you in response to Interrogatory No. 8 and 14. E.
• 2:29
  Speaker 1: Skye Roberts. F. Lynn Roberts. G. Kimberly Roberts. H. Daniel LNU,
• 2:34
  Speaker 1: half-brother of plaintiff. I. Carol Roberts Kess. J. Philip Guderian. K.
• 2:41
  Speaker 1: Anthony Valadares. L. Anthony Figueroa. M. Ron Eppinger. Response to
• 2:47
  Speaker 1: request number five. Ms. Roberts' objection to this request on
• 2:51
  Speaker 1: the grounds that it is overly broad and unduly burdensome
• 2:55
  Speaker 1: particularly as it seeks documents relating to over 60 individuals
• 2:58
  Speaker 1: and calls for the production of documents that are irrelevant
• 3:01
  Speaker 1: to this action and not reasonably calculated to lead to
• 3:05
  Speaker 1: the discovery of admissible evidence. Ms. Roberts objects because compliance
• 3:09
  Speaker 1: with this request is unduly burdensome. Ms. Roberts objects to
• 3:13
  Speaker 1: this request in that documents responsive to this request are
• 3:16
  Speaker 1: within the possession, custody, and control of the defendant and
• 3:20
  Speaker 1: Jeffrey Epstein, with whom she claims the joint defense privilege
• 3:23
  Speaker 1: and defendant has refused to produce responsive documents to Ms.
• 3:27
  Speaker 1: Roberts' request seeking communications between the defendant and Ms. Roberts
• 3:32
  Speaker 1: and between Jeffrey Epstein and Ms. Roberts. Ms. Roberts objects
• 3:36
  Speaker 1: to the request to the extent it seeks documents protected
• 3:40
  Speaker 1: by attorney-client, work product, joint defense, public interest, or any
• 3:44
  Speaker 1: other applicable privilege, Ms. Roberts objects to this request in
• 3:47
  Speaker 1: that it sought solely to harass and intimidate Ms. Roberts
• 3:51
  Speaker 1: and invade her privacy by seeking her private communications with
• 3:55
  Speaker 1: her various family members, including aunts, uncles, and parents, and siblings.
• 4:00
  Speaker 1: Subject to and without waiving the above objections, Ms. Roberts
• 4:04
  Speaker 1: is withholding production of documents that are privileged pursuant to
• 4:07
  Speaker 1: the attorney-client privilege the work-product privilege, and the public interest privilege. Ms.
• 4:13
  Speaker 1: Roberts is also withholding electronic renditions of photographs that depict
• 4:17
  Speaker 1: the faces of her minor children, including school portraits and
• 4:21
  Speaker 1: other photographs taken that reveal the faces of her minor children.
• 4:26
  Speaker 1: Subjection 2, and without waiving the above objections, Ms. Roberts,
• 4:30
  Speaker 1: has already produced documents Bates labeled Roberts 000001 to Roberts 005353,
• 4:38
  Speaker 1: and will produce non-privileged documents responsive to this request limited
• 4:42
  Speaker 1: to documents that do not depict images of her minor children,
• 4:46
  Speaker 1: as described Supra, and will continue to supplement this production. 6.
• 4:51
  Speaker 1: All photographs or video containing any image of you and
• 4:54
  Speaker 1: the following individuals. To the extent you have such photographs
• 4:58
  Speaker 1: and video in their original native format, please produce them
• 5:02
  Speaker 1: in that format, not a paper copy. a. Ghislaine Maxwell b.
• 5:06
  Speaker 1: Alan Dershowitz c. Jeffrey Epstein d. Andrew Albert Christian Edward,
• 5:11
  Speaker 1: the Duke of York, a.k.a. the Joe Exotic of the
• 5:14
  Speaker 1: Windsor family e. Ron Eppinger f. Bill Clinton G. Stephen Hawking, H.
• 5:20
  Speaker 1: Al Gore, I. Any of the individuals identified by you
• 5:24
  Speaker 1: in response to Interrogatory No. 8 and No. 14. Response
• 5:28
  Speaker 1: to Request No. 6. Ms. Roberts objects to this request
• 5:32
  Speaker 1: in that the documents responsive to this request are within
• 5:35
  Speaker 1: the possession, custody, and control of the defendant and Jeffrey Epstein,
• 5:40
  Speaker 1: with whom she claims the joint defense privilege, and defense
• 5:43
  Speaker 1: has refused to produce responsive documents in to Ms. Roberts
• 5:46
  Speaker 1: requesting seeking communications between the defendant and Ms. Roberts and
• 5:50
  Speaker 1: between Jeffrey Epstein and Ms. Roberts. Subject to and without
• 5:54
  Speaker 1: waiving the above objections, Ms. Roberts has already produced documents,
• 5:58
  Speaker 1: Bates labeled Roberts 0001 to Roberts 005353, and will produce
• 6:05
  Speaker 1: non-privileged documents responsive to this request and will continue to
• 6:09
  Speaker 1: supplement her production. Ms. Roberts does not have original native
• 6:13
  Speaker 1: format as requested. so she is producing the paper copies
• 6:17
  Speaker 1: she has in her possession, custody, and control. 7. Photographs
• 6:22
  Speaker 1: and video of you in any of Jeffrey Epstein's properties,
• 6:25
  Speaker 1: including but not limited to his home in Palm Beach,
• 6:28
  Speaker 1: his home in New York, his ranch in Santa Fe,
• 6:31
  Speaker 1: and Little St. James Island in the U.S. Virgin Islands.
• 6:34
  Speaker 1: To the extent you have such photographs and videos in
• 6:37
  Speaker 1: their original, native format, please produce them in that format,
• 6:41
  Speaker 1: not a paper copy. Response to request number seven. Ms.
• 6:45
  Speaker 1: Roberts objects to this request and that documents responsive to
• 6:49
  Speaker 1: this request are within the possession, custody, and control of
• 6:52
  Speaker 1: the defendant and Jeffrey Epstein, with whom she claims a
• 6:55
  Speaker 1: joint defense privilege and defendant has refused to produce responsive
• 6:59
  Speaker 1: documents to Ms. Roberts. Request seeking communications between the defendant
• 7:04
  Speaker 1: and Ms. Roberts and between Jeffrey Epstein and Ms. Roberts.
• 7:08
  Speaker 1: Subject to and without waiving the above objections, Ms. Roberts
• 7:12
  Speaker 1: has already produced documents Bates labeled Robert00001 to Robert005353 and
• 7:20
  Speaker 1: will produce documents responsive to this request and will continue
• 7:23
  Speaker 1: to supplement her production. Ms. Roberts does not have original
• 7:27
  Speaker 1: native format as requested, so she is producing the paper
• 7:31
  Speaker 1: copies she has in her possession, custody, and control. The
• 7:35
  Speaker 1: defendant has documents responsive to this request that she should produce.
• 7:40
  Speaker 1: Number eight. All photographs or video of you in any
• 7:44
  Speaker 1: of Ms. Maxwell's properties, including her home in London, England,
• 7:47
  Speaker 1: and her home in New York City, to the extent
• 7:49
  Speaker 1: you have such photographs or video in their original native format,
• 7:53
  Speaker 1: please produce them in that format, not a paper copy.
• 7:57
  Speaker 1: Response to request number eight. Ms. Roberts objects to this
• 8:01
  Speaker 1: request in that documents responsive to this request are within
• 8:05
  Speaker 1: the possession, custody, and control of the defendant and Jeffrey Epstein,
• 8:09
  Speaker 1: with whom she claims a joint defense privilege, and defendant
• 8:12
  Speaker 1: has refused to produce responsive documents to Ms. Roberts' request
• 8:16
  Speaker 1: seeking communications between the defendant and Ms. Roberts and between
• 8:20
  Speaker 1: Jeffrey Epstein and Ms. Roberts. Subject to and without waiving
• 8:24
  Speaker 1: the above objections, Ms. Roberts has already produced documents Documents
• 8:28
  Speaker 1: Bates labeled Robert 00001 to Robert 005353 and will produce
• 8:35
  Speaker 1: non-privileged documents responsive to this request and will continue to
• 8:40
  Speaker 1: supplement her production. Ms. Roberts does not have original native
• 8:44
  Speaker 1: format as requested, so she is producing the paper copies
• 8:47
  Speaker 1: she has in her possession, custody, and control. The defendant
• 8:51
  Speaker 1: has documents responsive to this request that she should produce.
• 8:55
  Speaker 1: Number nine. Any documents reflecting rental agreements or purchase agreements
• 9:00
  Speaker 1: for the residential addresses identified by you in response to
• 9:04
  Speaker 1: interrogatory number one. Response to request number nine. Ms. Roberts
• 9:09
  Speaker 1: objects to this request on the grounds that it is
• 9:12
  Speaker 1: overly broad and unduly burdensome and calls for the production
• 9:16
  Speaker 1: of documents that are irrelevant to this action and not
• 9:19
  Speaker 1: reasonably calculated to lead to the discovery of admissible evidence. Ms.
• 9:23
  Speaker 1: Roberts objects to this request In that it seeks confidential
• 9:27
  Speaker 1: financial information that is irrelevant to this action, Ms. Roberts
• 9:31
  Speaker 1: objects to this request to the extent it seeks documents
• 9:34
  Speaker 1: protected by attorney-client work product, joint defense, public interest, or
• 9:39
  Speaker 1: any other applicable privilege. Ms. Roberts objects to this request
• 9:43
  Speaker 1: in that the information regarding rental agreements for the apartments
• 9:47
  Speaker 1: that defendant and Jeffrey Epstein rented for her are in
• 9:50
  Speaker 1: the defendant's possession, control, and custody. Subject to and without
• 9:55
  Speaker 1: waiving the above objections, Ms. Roberts has already produced documents
• 9:59
  Speaker 1: Bates labeled, Robert00001 to Robert005353 and will continue to produce
• 10:07
  Speaker 1: non-privileged documents responsive to this request and will continue to
• 10:12
  Speaker 1: supplement this production. Number 10. all documents relating to your
• 10:16
  Speaker 1: employment and or association with the Mar-a-Lago Club located in
• 10:20
  Speaker 1: Palm Beach, Florida, including any application for employment. Response to
• 10:25
  Speaker 1: request number 10. Ms. Roberts objects to this request to
• 10:28
  Speaker 1: the extent it seeks documents protected by the attorney client,
• 10:32
  Speaker 1: work product, joint defense, public interest, or any other applicable
• 10:36
  Speaker 1: privilege Subject to and without waiving the above objections, Ms.
• 10:40
  Speaker 1: Roberts has already produced documents Bates labeled Robert 000001 to
• 10:46
  Speaker 1: Robert 005353 and will produce non-privileged documents responsive to this
• 10:52
  Speaker 1: request and will continue to supplement its production. Number 11.
• 10:57
  Speaker 1: Any documents reflecting any confidentiality agreement by and between or
• 11:01
  Speaker 1: concerning you and the Mar-a-Lago Club. Response to request number 10. Ms.
• 11:07
  Speaker 1: Roberts objects to this request to the extent it seeks
• 11:10
  Speaker 1: documents protected by the attorney-client, work product, joint defense, public interest,
• 11:15
  Speaker 1: and any other applicable privilege. Ms. Roberts has been unable
• 11:19
  Speaker 1: to locate any such document. 12. All documents concerning any
• 11:24
  Speaker 1: employment by you from 1998 to present or identified by
• 11:28
  Speaker 1: you in response to Interrogatory No. 9, including any records
• 11:32
  Speaker 1: of your employment at the Roadhouse Grill in Palm Beach, Florida.
• 11:36
  Speaker 1: Response to request number 12. Ms. Roberts objects to this
• 11:40
  Speaker 1: request on the grounds that it is overly broad and
• 11:43
  Speaker 1: unduly burdensome and calls for the production of documents that
• 11:46
  Speaker 1: are irrelevant to this action and not reasonably calculated to
• 11:50
  Speaker 1: lead to the discovery of admissible evidence. Ms. Roberts objects
• 11:54
  Speaker 1: to this request to the extent it seeks documents protected
• 11:57
  Speaker 1: by the attorney-client, work product, joint defense, public interest, or
• 12:01
  Speaker 1: any other applicable privilege, Subject to and without waiving the
• 12:05
  Speaker 1: above objections, Ms. Roberts has already produced documents Bates labeled
• 12:10
  Speaker 1: Robert00001 to Robert005353 and will produce non-privileged documents responsive to
• 12:19
  Speaker 1: this request and will continue to supplement this production. Number 13.
• 12:24
  Speaker 1: All documents concerning any allegations of theft by you from
• 12:27
  Speaker 1: the Roadhouse Grill in Palm Beach, Florida from 1999 to 2002.
• 12:33
  Speaker 1: Response to request number 13. Ms. Roberts objects to this
• 12:37
  Speaker 1: request in that it seeks information solely to harass, embarrass,
• 12:41
  Speaker 1: and intimidate Ms. Roberts. Ms. Roberts objects to this request
• 12:44
  Speaker 1: to the extent it seeks documents protected by the attorney
• 12:48
  Speaker 1: client privilege, the attorney work product privilege, joint defense common
• 12:52
  Speaker 1: interest privilege, public interest privilege, and any other applicable privilege. Ms.
• 12:57
  Speaker 1: Roberts objects to this request in that it wrongfully characterizes
• 13:01
  Speaker 1: a theft by you. Ms. Roberts objects to this request
• 13:04
  Speaker 1: as it seeks documents of sealed juvenile records and the
• 13:08
  Speaker 1: only means of obtaining such records are either through court, order,
• 13:11
  Speaker 1: or illegal means. All right, folks, that's going to do
• 13:14
  Speaker 1: it for this one. And in the next episode, we'll
• 13:16
  Speaker 1: pick up where we left off. All of the information
• 13:20
  Speaker 1: that goes with this episode can be found in the
• 13:23
  Speaker 1: description box.