Latest / Beyond The Horizon / Virginia Roberts And Her 2nd Supplemental Response To Maxwell's Discovery Request (Part 3) (10/25/26)

Transcript

Virginia Roberts And Her 2nd Supplemental Response To Maxwell's Discovery Request (Part 3) (10/25/26) · Beyond The Horizon

• 0:00
  Speaker 1: What's up, everyone, and welcome back to the Epstein Chronicles.
• 0:03
  Speaker 1: In this episode, we're going to pick up where we
• 0:06
  Speaker 1: left off with Virginia Roberts and her second response to
• 0:11
  Speaker 1: the supplemental request for discovery. Response to interrogatory number eight. Ms.
• 0:17
  Speaker 1: Roberts objects to this interrogatory in that it violates local
• 0:21
  Speaker 1: rule 33.3. Ms. Roberts objects that it seeks information protected
• 0:26
  Speaker 1: by the attorney-client privilege, the attorney-work-product privilege, joint defense, common
• 0:31
  Speaker 1: interest privilege, the public interest privilege, and any other applicable privilege. Additionally, Ms.
• 0:37
  Speaker 1: Roberts objects to this interrogatory because naming some such individuals
• 0:42
  Speaker 1: would jeopardize her physical safety based on credible threats to
• 0:45
  Speaker 1: the same. Ms. Roberts refers to the list of witnesses
• 0:49
  Speaker 1: identified in her revised Rule 26 disclosures. Number nine, identify
• 0:55
  Speaker 1: any employment you have had from 1996 until present. including,
• 0:59
  Speaker 1: without limitation, the name of your employer or the name
• 1:03
  Speaker 1: of any person who engaged you for such employment, the
• 1:06
  Speaker 1: address and telephone number for any such employment, the beginning
• 1:10
  Speaker 1: and ending dates of any such employment, your job title
• 1:14
  Speaker 1: in such employment, and your income from such employment. Response
• 1:18
  Speaker 1: to Interrogatory No. 9 Ms. Roberts objects to this request
• 1:22
  Speaker 1: in that it is overly broad and unduly burdensome and
• 1:26
  Speaker 1: seeks information that is not relevant to this case. Ms.
• 1:29
  Speaker 1: Roberts responds as follows. Ms. Roberts worked at Mar-a-Lago as
• 1:34
  Speaker 1: a locker room attendant for the spa area. Records produced
• 1:37
  Speaker 1: in this case identify the date of employment as 2000,
• 1:41
  Speaker 1: and she recalls being there in the summer. Ms. Roberts
• 1:44
  Speaker 1: previously attempted to gather employment records from Mar-a-Lago, see Roberts 002726.
• 1:50
  Speaker 1: She earned approximately $ 9 per hour. The address is 1100
• 1:56
  Speaker 1: South Ocean Boulevard, Palm Beach, Florida, 33480, and the telephone
• 2:01
  Speaker 1: number is 561-832-2600. Ms. Roberts worked at Roadhouse Grill as
• 2:07
  Speaker 1: a waitress in approximately 2002, but Ms. Roberts is unsure
• 2:11
  Speaker 1: of the exact dates of her employment. Her wages primarily
• 2:15
  Speaker 1: consisted of tips. Ms. Roberts does not recall the location
• 2:19
  Speaker 1: of the Roadhouse Grill, a Google search for the same
• 2:22
  Speaker 1: yields and address at 8865 Southern Boulevard, in Palm Beach, Florida. Ms.
• 2:27
  Speaker 1: Roberts worked at Employment Training and Recruitment Australia from approximately
• 2:32
  Speaker 1: 2005 through January of 2006, but Ms. Roberts is unsure
• 2:38
  Speaker 1: of the exact dates of employment. Ms. Roberts was a
• 2:40
  Speaker 1: receptionist earning approximately $ 15 per hour, to the best of
• 2:44
  Speaker 1: her recollection. Upon information and belief, this corporation is currently
• 2:49
  Speaker 1: located in a different location from the location at which Ms.
• 2:52
  Speaker 1: Roberts was employed. Upon information and belief, Based on an
• 2:57
  Speaker 1: internet search, the new location of this entity is listed. Ms.
• 3:01
  Speaker 1: Roberts worked at Gemma Catering Wedding Receptions in approximately 2004.
• 3:06
  Speaker 1: She received approximately $ 10 an hour and she does not
• 3:09
  Speaker 1: recall the name of the proprietor nor its location. Ms.
• 3:13
  Speaker 1: Roberts worked at Manway Logistics in approximately 2003. Ms. Roberts
• 3:19
  Speaker 1: recalls it located in or around Sydney, Australia. An internet
• 3:23
  Speaker 1: search yielded an address of 246 Miller Road, Villawood, North Southwest, 2163. Ms.
• 3:31
  Speaker 1: Roberts worked as a receptionist and earned approximately $ 20 an hour. 10.
• 3:36
  Speaker 1: Identify any income from any source other than your employment
• 3:40
  Speaker 1: that you have received from January 1, 1996 until the present,
• 3:45
  Speaker 1: including the person or entity providing such income, the amount
• 3:49
  Speaker 1: of the income, the dates on which any such income
• 3:52
  Speaker 1: was received, and the nature of the income, whether a loan,
• 3:55
  Speaker 1: investment proceeds, legal settlement, asset sale, gift, or other source.
• 4:01
  Speaker 1: Response to Interrogatory No. 10 Ms. Roberts objects to this
• 4:06
  Speaker 1: interrogatory in that it violates Local Rule 33.3. Ms. Roberts
• 4:11
  Speaker 1: objects to this request in that it is overly broad
• 4:14
  Speaker 1: and seeks confidential information. Ms. Roberts objects to this interrogatory
• 4:18
  Speaker 1: in that it seeks information covered by confidentiality provisions. Ms.
• 4:23
  Speaker 1: Roberts objects to this information in that any payment information
• 4:26
  Speaker 1: for the sexual trafficking she endured at the hands of
• 4:29
  Speaker 1: Jeffrey Epstein and Ghislaine Maxwell is in the possession, custody,
• 4:33
  Speaker 1: and control of the defendant and Jeffrey Epstein. Ms. Roberts
• 4:37
  Speaker 1: is in possession of a responsive document that contains a
• 4:40
  Speaker 1: confidentiality provision. If defendant obtains and produces to Ms. Roberts
• 4:45
  Speaker 1: a written waiver from her co-conspirator Mr. Epstein of her
• 4:48
  Speaker 1: confidentiality provision, freeing Ms. Roberts from any liability whatsoever, Under
• 4:53
  Speaker 1: the confidentiality provision, she will produce the document. Number 11.
• 4:58
  Speaker 1: Identify any facts upon which you base your contention that
• 5:02
  Speaker 1: you have suffered as a result of the alleged defamation
• 5:05
  Speaker 1: by Ghislaine Maxwell, past and future loss wages, and past
• 5:08
  Speaker 1: and future loss of earning capacity and actual earnings, precise
• 5:12
  Speaker 1: amounts yet to be computed, but not less than $ 5 million.
• 5:17
  Speaker 1: Response to Interrogatory Number 11. Ms. Roberts objects to this
• 5:21
  Speaker 1: interrogatory and In that it violates Local Rule 33.3, Ms.
• 5:25
  Speaker 1: Roberts objects to this interrogatory in that it prematurely seeks
• 5:28
  Speaker 1: expert witness disclosures. Ms. Roberts incorporates by reference herein her
• 5:34
  Speaker 1: revised Rule 26 disclosures, which includes her computation of damages. 12.
• 5:40
  Speaker 1: Identify any health care provider from whom you received any
• 5:44
  Speaker 1: treatment for any physical, mental, or emotional condition that you
• 5:48
  Speaker 1: suffered from subsequent to any alleged defamation by Ghislaine Maxwell,
• 5:53
  Speaker 1: including A, the healthcare provider's name, address, and telephone number, B,
• 5:58
  Speaker 1: the type of consultation, examination, or treatment provided, C, the
• 6:03
  Speaker 1: dates he received consultation, examination, or treatment, D, whether such
• 6:08
  Speaker 1: treatment was on an inpatient or outpatient basis, E, the
• 6:12
  Speaker 1: medical expenses to date, F, Whether health insurance or some
• 6:16
  Speaker 1: other person or organization or entity has paid for the
• 6:19
  Speaker 1: medical expenses, N.G., for each such health care provider, please
• 6:24
  Speaker 1: execute the medical and mental health records release attached hereto
• 6:29
  Speaker 1: as Exhibit A. Response to Interrogatory No. 12. Pursuant to
• 6:34
  Speaker 1: this court's order, Ms. Roberts will provide information for health
• 6:37
  Speaker 1: care providers from 1999 through the present. Ms. Roberts continues
• 6:42
  Speaker 1: to search for medical providers in Dr. Stephen Olson, St.
• 6:47
  Speaker 1: Thomas More Hospital, Cannon City, Colorado. Dr. Mona Devanchon, Royal
• 6:54
  Speaker 1: Palm Beach, Florida. Dr. Chris Donahue, Dr. John Harris, Dr. Awawa, Dr. Seltahari.
• 7:03
  Speaker 1: Royal Oaks Medical Center, Carol Hayek, New York Presbyterian Hospital,
• 7:08
  Speaker 1: treated Ms. Roberts as described in the medical records produced
• 7:11
  Speaker 1: as Roberts 003258-3298. Campbelltown Hospital, Sydney West Hospital, treated Ms.
• 7:21
  Speaker 1: Roberts as described in the medical records produced at Roberts 003291-3298.
• 7:29
  Speaker 1: Westmead Hospital treated Ms. Roberts on as described in the
• 7:32
  Speaker 1: medical records produced as Roberts 003291-003298. As defendant requested, medical
• 7:41
  Speaker 1: releases have been provided for Dr. Karen Kutikoff, Wellington Imaging Associates,
• 7:46
  Speaker 1: and Growing Together. 13. Identify any health care provider from
• 7:51
  Speaker 1: whom you received any treatment for any physical, mental, or
• 7:54
  Speaker 1: emotional condition, including addiction to alcohol, prescription or illegal drugs.
• 7:59
  Speaker 1: that you suffered from prior to the alleged defamation by
• 8:02
  Speaker 1: Ghislaine Maxwell, including A, the healthcare provider's name, address, and
• 8:07
  Speaker 1: telephone number, B, type of consultation, examination, or treatment provided, C,
• 8:12
  Speaker 1: the dates you received consultation, examination, or treatment, D, whether
• 8:16
  Speaker 1: such treatment was on an inpatient or outpatient basis, E,
• 8:21
  Speaker 1: the medical expenses to date, F, whether health insurance, some
• 8:25
  Speaker 1: other person, or organization or entity is paid for the
• 8:28
  Speaker 1: medical expenses, and G, for each such health care provider,
• 8:32
  Speaker 1: please execute the medical and mental health records release attached
• 8:36
  Speaker 1: hereto as Exhibit A. Response to Interrogatory No. 13. Ms.
• 8:42
  Speaker 1: Roberts objects to this interrogatory in that it violates Local
• 8:45
  Speaker 1: Rule 33.3. Ms. Roberts objects to this request in that
• 8:49
  Speaker 1: it's overbroad and seeks confidential medical information of a sex
• 8:54
  Speaker 1: abuse victim and is not limited in scope to the
• 8:56
  Speaker 1: issues in this case. Ms. Roberts objects that it seeks
• 9:00
  Speaker 1: information protected by the attorney-client privilege, the attorney-work-product privilege, joint
• 9:05
  Speaker 1: defense common interest privilege, and any other applicable privilege. Ms.
• 9:09
  Speaker 1: Roberts objects to this request in that it is not
• 9:12
  Speaker 1: limited in scope to the medical information relating to the
• 9:15
  Speaker 1: abuse she suffered from defendant and Jeffrey Epstein. Fourteen. identify
• 9:21
  Speaker 1: any person you believe subjected you to or with whom
• 9:24
  Speaker 1: you engaged in any illegal or inappropriate sexual conduct, conduct
• 9:30
  Speaker 1: or assault prior to June 1999, including the names of
• 9:33
  Speaker 1: the individuals involved, the dates of any such illegal or
• 9:37
  Speaker 1: inappropriate sexual contact, conduct or assault, whether income was received
• 9:41
  Speaker 1: by you or anyone else concerning such an event, whether
• 9:45
  Speaker 1: police reports were filed concerning such an event, and the
• 9:48
  Speaker 1: outcome of any such case, as well as the address
• 9:51
  Speaker 1: and location of any such event. Response to Interrogatory No. 14. Ms.
• 9:57
  Speaker 1: Roberts objects to this interrogatory in that it violates Local
• 10:01
  Speaker 1: Rule 33.3. Ms. Roberts objects to this request in that
• 10:05
  Speaker 1: it's overbroad and seeks confidential medical information of a sex
• 10:09
  Speaker 1: abuse victim. Ms. Roberts objects to this request in that
• 10:12
  Speaker 1: it seeks sexual assault information from a period prior to
• 10:15
  Speaker 1: the sexual abuse at issue in this matter, for a
• 10:18
  Speaker 1: period when she was a minor child from the time Ms.
• 10:21
  Speaker 1: Roberts was born until she was 15. Ms. Roberts objects
• 10:25
  Speaker 1: to this request in that it sought solely to harass
• 10:28
  Speaker 1: and intimidate Ms. Roberts, who was a victim of sexual
• 10:31
  Speaker 1: abuse by the defendant. Requests for Production 1. All communications
• 10:37
  Speaker 1: and documents identified in Interrogatories 1-14 above. Response to Request 1. Ms.
• 10:44
  Speaker 1: Roberts objects to this request in that defendants' interrogatories violate
• 10:48
  Speaker 1: Local Rule 33.3. Ms. Roberts objects in that it seeks
• 10:52
  Speaker 1: information protected by the attorney-client privilege, the attorney-work-product privilege, joint-defense
• 10:58
  Speaker 1: common-interest privilege, the public-interest privilege, and any other applicable privilege. Ms.
• 11:03
  Speaker 1: Roberts objects to this request on the grounds that it
• 11:06
  Speaker 1: is overly broad and unduly burdensome, incorporating the interrogatories that
• 11:11
  Speaker 1: total 59 subparts and calls for the production of documents
• 11:15
  Speaker 1: that are irrelevant in this action and not reasonably calculated
• 11:19
  Speaker 1: to lead to the discovery of admissible evidence. Ms. Roberts
• 11:23
  Speaker 1: objects to this request in that it seeks to invade
• 11:25
  Speaker 1: the privacy and the rights of a sex abuse victim,
• 11:28
  Speaker 1: and is meant for the improper purpose of harassing and
• 11:32
  Speaker 1: intimidating this victim. Subject to, and without waiving the above objections, Ms.
• 11:37
  Speaker 1: Roberts is withholding production of documents that are privileged pursuant
• 11:41
  Speaker 1: to the attorney-client privilege, the work-product privilege, and the public
• 11:45
  Speaker 1: interest privilege, Ms. Roberts is also withholding electronic renditions of
• 11:49
  Speaker 1: photographs that depict the faces of her minor children, including
• 11:53
  Speaker 1: school portraits and other photographs taken that reveal the faces
• 11:58
  Speaker 1: of her minor children. Subjection to and without waiving the
• 12:02
  Speaker 1: above objections, Ms. Roberts has already produced documents, Bates-labeled Roberts
• 12:07
  Speaker 1: 000001 to Roberts 005353, and will produce non-privileged documents responsive
• 12:16
  Speaker 1: to this request, limited to documents that do not depict
• 12:20
  Speaker 1: images of her minor children as described Supra, and will
• 12:24
  Speaker 1: continue to supplement her production. Alright folks, we're going to
• 12:28
  Speaker 1: end this episode right here, and in the next episode
• 12:30
  Speaker 1: we'll pick up where we left off. All of the
• 12:33
  Speaker 1: information that goes with this episode can be found in
• 12:36
  Speaker 1: the description box.