Latest / Beyond The Horizon / Virginia Roberts And Her 2nd Supplemental Response To Maxwell's Discovery Request (Part 5) (10/28/26)

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Virginia Roberts And Her 2nd Supplemental Response To Maxwell's Discovery Request (Part 5) (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 pick up where we left
• 0:09
  Speaker 1: off with Virginia Roberts and her second response to the
• 0:13
  Speaker 1: supplemental discovery request made by Ghislaine Maxwell. Number 14, a
• 0:19
  Speaker 1: copy of your federal, state, or local tax returns for
• 0:22
  Speaker 1: the years 1998 to the present, whether from the United
• 0:26
  Speaker 1: States or any other country. Response to request number 14. Ms.
• 0:31
  Speaker 1: Roberts objections to this request on the grounds that it
• 0:34
  Speaker 1: is overly broad and unduly burdensome and calls for the
• 0:38
  Speaker 1: production of documents that are irrelevant to this action and
• 0:42
  Speaker 1: not reasonably calculated to lead to the discovery of admissible evidence. Ms.
• 0:47
  Speaker 1: Roberts objects to this request and that it seeks confidential
• 0:51
  Speaker 1: financial information that is irrelevant to this action. Ms. Roberts
• 0:55
  Speaker 1: objects to this request in that it seeks financial information
• 0:58
  Speaker 1: from her when she was a minor child starting at
• 1:01
  Speaker 1: age 14. Ms. Roberts objects in that it seeks information
• 1:05
  Speaker 1: protected by the attorney-client privilege, the attorney-work-product privilege, joint-defense-common-interest privilege,
• 1:12
  Speaker 1: the accountant-client privilege, and any other applicable privilege. Subject to
• 1:18
  Speaker 1: and without waiving the above objections, Ms. Roberts has already
• 1:21
  Speaker 1: produced documents labeled Roberts 00001 to Roberts 005353 and will
• 1:29
  Speaker 1: produce non-privileged documents responsive to this request and will continue
• 1:34
  Speaker 1: to supplement this production. Number 15. All documents concerning your
• 1:39
  Speaker 1: attendance at or enrollment at any school or educational program
• 1:44
  Speaker 1: of whatever type from 1998 to the present. Response to
• 1:48
  Speaker 1: request number 15. Ms. Roberts objections to this request on
• 1:52
  Speaker 1: the grounds that it is overly broad and unduly burdensome
• 1:56
  Speaker 1: and calls for the production of documents that are irrelevant
• 1:59
  Speaker 1: to this action and not reasonably calculated to lead to
• 2:02
  Speaker 1: the discovery of admissible evidence. Ms. Roberts objects to this
• 2:06
  Speaker 1: request to the extent it seeks documents protected by the
• 2:10
  Speaker 1: attorney-client privilege, the attorney-work-product privilege, joint defense common interest privilege,
• 2:16
  Speaker 1: the public interest privilege, and any other applicable privilege. Ms.
• 2:21
  Speaker 1: Roberts objects to this request in that her school records
• 2:24
  Speaker 1: from when she was a minor child are an invasion
• 2:27
  Speaker 1: of privacy and sought only to harass and embarrass her.
• 2:31
  Speaker 1: Subject to and without waiving the above objections, Ms. Roberts
• 2:35
  Speaker 1: has already produced documents, bates labeled Roberts 00001 to Roberts 005353,
• 2:44
  Speaker 1: and will produce non-privileged documents responsive to this request and
• 2:48
  Speaker 1: will continue to supplement its production. Number 16. Any diary, journal,
• 2:55
  Speaker 1: or calendar concerning your activities between 1996 and 2002? Response
• 3:01
  Speaker 1: to request number 16. Ms. Roberts' objections to this request
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  Speaker 1: on the grounds that the time period is overly broad
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  Speaker 1: and calls for the production of documents that are irrelevant
• 3:12
  Speaker 1: to this action and not reasonably calculated to lead to
• 3:15
  Speaker 1: the discovery of admissible evidence. Ms. Roberts objects to this
• 3:19
  Speaker 1: request to the extent it seeks proprietary and copyrighted protected materials. Ms.
• 3:25
  Speaker 1: Roberts objects in that it seeks information protected by the
• 3:28
  Speaker 1: attorney-client privilege. the attorney work product privilege, joint defense, common
• 3:33
  Speaker 1: interest privilege, and any other applicable privilege, Ms. Roberts objects
• 3:37
  Speaker 1: to this request in that it seeks highly personal and
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  Speaker 1: sensitive material from a time when she was being sexually trafficked. Ms.
• 3:45
  Speaker 1: Roberts has been unable to locate any such documents. Number 17.
• 3:50
  Speaker 1: All documents relating to your travel from the period of
• 3:53
  Speaker 1: 1998 to the present, including but not limited to a
• 3:57
  Speaker 1: copy of your passport, that was valid for any part
• 4:00
  Speaker 1: of that time period, any visa issued to you for travel,
• 4:04
  Speaker 1: any visa application that you prepared or which was prepared
• 4:08
  Speaker 1: on your behalf, any travel itinerary, receipt log, or document,
• 4:12
  Speaker 1: including any photograph, substantiating your travel during that time period.
• 4:17
  Speaker 1: Response to request number 17. Ms. Roberts objections to this
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  Speaker 1: request on the grounds that it is overly broad and
• 4:25
  Speaker 1: unduly burdensome, calls for the production of documents that are
• 4:29
  Speaker 1: irrelevant to this action and not reasonably calculated to lead
• 4:33
  Speaker 1: to the discovery of admissible evidence. Ms. Roberts objects in
• 4:37
  Speaker 1: that it seeks information protected by the attorney-client privilege, the
• 4:41
  Speaker 1: attorney-work-product privilege, joint defense common interest privilege, and any other
• 4:46
  Speaker 1: applicable privilege. Ms. Roberts objects to this request in that
• 4:50
  Speaker 1: it is overly broad and not limited to travel records
• 4:53
  Speaker 1: relevant to the abuse that she suffered. Ms. Roberts objects
• 4:56
  Speaker 1: to this request and that it seeks information that is
• 4:59
  Speaker 1: wholly irrelevant to this lawsuit. Subject to and without waiving
• 5:04
  Speaker 1: the above objections, Ms. Roberts has already produced documents Bates
• 5:08
  Speaker 1: labeled Robert 0001 to Robert 005353 and will produce non-privileged
• 5:15
  Speaker 1: documents responsive to this request and will continue to supplement
• 5:19
  Speaker 1: this production. Per the agreements made in the March 21,
• 5:22
  Speaker 1: 2016 meet and confer, we will attempt to locate and
• 5:27
  Speaker 1: make copies of plaintiff's current passport book. Number 18. All
• 5:32
  Speaker 1: documents showing any payment or remuneration of any kind made
• 5:36
  Speaker 1: by Jeffrey Epstein or any of his agents or associates
• 5:39
  Speaker 1: to you from 1999 until the present. Response to request
• 5:43
  Speaker 1: number 18. Ms. Roberts objects to this request in that
• 5:47
  Speaker 1: documents responsive to this request are within the possession, custody,
• 5:51
  Speaker 1: and control of the defendant and Jeffrey Epstein, with whom
• 5:55
  Speaker 1: she claims the joint defense privilege, and defendant has refused
• 5:58
  Speaker 1: to produce responsive documents. Ms. Roberts objects in that it
• 6:02
  Speaker 1: seeks information protected by the attorney-client privilege, the attorney-work product privilege,
• 6:08
  Speaker 1: joint defense common interest privilege, the public interest privilege, and
• 6:12
  Speaker 1: any other applicable privilege. At this point in time, Ms.
• 6:15
  Speaker 1: Roberts has been unable to locate any such documents. but
• 6:19
  Speaker 1: continues to search for responsive documents. Number 19. Any documents
• 6:24
  Speaker 1: reflecting a confidentiality agreement, settlement agreement, or any contractual agreement
• 6:29
  Speaker 1: of any kind between you and Jeffrey Epstein or any
• 6:33
  Speaker 1: attorneys for you and or Mr. Epstein. Response to request
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  Speaker 1: number 19. Ms. Roberts objects to this request in that
• 6:41
  Speaker 1: the documents responsive to this request are within the possession, custody,
• 6:45
  Speaker 1: and control of the defendant and Jeffrey Epstein, with whom
• 6:48
  Speaker 1: she claims the joint defense privilege, and defendant has refused
• 6:51
  Speaker 1: to produce responsive documents. Ms. Roberts objects in that it
• 6:55
  Speaker 1: seeks information protected by the attorney-client privilege, the attorney work,
• 6:59
  Speaker 1: product privilege, joint defense common interest privilege, the public interest privilege,
• 7:04
  Speaker 1: and any other applicable privilege. Ms. Roberts is in possession
• 7:08
  Speaker 1: of a responsive document that contains a confidentiality provision, as
• 7:12
  Speaker 1: discussed during the March 21, 2016 meet and confer. If
• 7:17
  Speaker 1: defendant obtains and produces to Ms. Roberts a written waiver
• 7:21
  Speaker 1: from her co-conspirator, Mr. Epstein, of the confidentiality provision releasing Ms.
• 7:26
  Speaker 1: Roberts from any liability whatsoever under the confidentiality provision, she
• 7:31
  Speaker 1: will produce the document. 20. Any document reflecting your intent, plan,
• 7:36
  Speaker 1: or consideration of asserting or threatening a claim or filing
• 7:40
  Speaker 1: a lawsuit against another person, any document reflecting such a
• 7:44
  Speaker 1: claim or lawsuit, including any complaint or draft complaint or
• 7:48
  Speaker 1: any demand for consideration with respect to any such claim
• 7:52
  Speaker 1: or lawsuit against any person. Response to request number 20. Ms.
• 7:57
  Speaker 1: Roberts' objections to this request on the grounds that it
• 8:00
  Speaker 1: is overly broad and unduly burdensome and calls for the
• 8:04
  Speaker 1: production of documents that are irrelevant to this action and
• 8:07
  Speaker 1: not reasonably calculated to lead to the discovery of admissible evidence. Ms.
• 8:12
  Speaker 1: Roberts objects to this request to the extent it seeks
• 8:15
  Speaker 1: documents protected by the attorney-client work product, joint defense, or
• 8:19
  Speaker 1: any other applicable privilege. Ms. Roberts objects because this request
• 8:24
  Speaker 1: is overly broad and unduly burdensome in that it seeks
• 8:27
  Speaker 1: wholly privileged communications from other cases. the logging of which
• 8:32
  Speaker 1: on a privileged log would be unduly burdensome. As such, Ms.
• 8:35
  Speaker 1: Roberts is providing categorical privilege entries relating to those matters.
• 8:41
  Speaker 1: At this point in time, Ms. Roberts has not found
• 8:44
  Speaker 1: any non-privileged documents responsive to this request, but continues to
• 8:48
  Speaker 1: search for responsive documents. Number 21. All documents relating to
• 8:53
  Speaker 1: your driver's license from 1998 to 2002. Response to request
• 8:55
  Speaker 1: number 21. Ms. Roberts objections to this request on the
• 9:01
  Speaker 1: grounds that it is overly broad and unduly burdensome and
• 9:05
  Speaker 1: calls for the production of documents that are irrelevant to
• 9:08
  Speaker 1: this action and not reasonably calculated to lead to the
• 9:11
  Speaker 1: discovery of admissible evidence. Ms. Roberts objects to this request
• 9:16
  Speaker 1: and the documents responsive to this request are within the possession, custody,
• 9:20
  Speaker 1: and control of the defendant and Jeffrey Epstein for whom
• 9:23
  Speaker 1: she claims a joint defense privilege and defendant has refused
• 9:27
  Speaker 1: to produce responsive documents. At this point in time, Ms.
• 9:31
  Speaker 1: Roberts has not found any documents responsive to this request,
• 9:35
  Speaker 1: but continues to search for responsive documents. Number 22. Ms.
• 9:40
  Speaker 1: Roberts objections to this request on the grounds that it
• 9:43
  Speaker 1: is irrelevant to this action and not reasonably calculated to
• 9:47
  Speaker 1: lead to the discovery of admissible evidence. Ms. Roberts objects
• 9:51
  Speaker 1: in that it seeks information protected by the attorney-client privilege,
• 9:55
  Speaker 1: the attorney work product privilege, and any other applicable privilege.
• 9:59
  Speaker 1: Subject to and without waiving the above objections, Ms. Roberts
• 10:03
  Speaker 1: has already produced documents Bates labeled Robert 00001 to Robert
• 10:09
  Speaker 1: 005353 and will produce non-privileged documents responsive to this request
• 10:14
  Speaker 1: and will continue to supplement this production. Number twenty-three. all
• 10:18
  Speaker 1: documents concerning your naturalization application to Australia from 1999 to
• 10:24
  Speaker 1: the present. Response to request number 23. Ms. Roberts objections
• 10:28
  Speaker 1: to this request on the grounds that it is irrelevant
• 10:31
  Speaker 1: to the action and not reasonably calculated to lead to
• 10:35
  Speaker 1: the discovery of admissible evidence. Ms. Roberts objects in that
• 10:39
  Speaker 1: it seeks information protected by the attorney-client privilege, the attorney-work-product privilege,
• 10:44
  Speaker 1: and any other applicable privilege. Ms. Roberts has been unable
• 10:48
  Speaker 1: to locate any such documents. 24. All documents concerning your
• 10:52
  Speaker 1: employment in Australia, including but not limited to, employment application,
• 10:57
  Speaker 1: pay stubs, documents reflecting your income, including any tax documents.
• 11:02
  Speaker 1: Response to request number 24. Ms. Roberts objections to this
• 11:06
  Speaker 1: request on the grounds that it is overly broad and
• 11:09
  Speaker 1: unduly burdensome, and calls for the production of documents that
• 11:13
  Speaker 1: are irrelevant to this action and not reasonably calculated to
• 11:17
  Speaker 1: lead to the discovery of any admissible evidence. Ms. Roberts
• 11:21
  Speaker 1: objects to this request in that it seeks confidential financial information. Ms.
• 11:25
  Speaker 1: Roberts objects to this request to the extent it seeks
• 11:29
  Speaker 1: documents protected by the attorney-client, work product, joint defense, or
• 11:33
  Speaker 1: any other applicable privilege. Ms. Roberts objects to this request
• 11:37
  Speaker 1: in that it seeks overly broad financial information. not tailored
• 11:41
  Speaker 1: to the sexual abuse and defamation issues in this case.
• 11:45
  Speaker 1: Subject to and without waiving the above objections, Ms. Roberts
• 11:49
  Speaker 1: has already produced documents Bates labeled Robert 000001 to Robert
• 11:56
  Speaker 1: 005353 and will produce non-privileged documents responsive to this request
• 12:01
  Speaker 1: and will continue to supplement this production. Twenty-five. all documents
• 12:06
  Speaker 1: concerning any massage therapist license obtained by you, including any
• 12:11
  Speaker 1: massage therapy license issued in the United States, Thailand, and
• 12:15
  Speaker 1: or Australia. Response to request number 25. Ms. Roberts objects
• 12:21
  Speaker 1: to this request and that documents responsive to this request
• 12:24
  Speaker 1: are within the possession, custody, and control of the defendant
• 12:28
  Speaker 1: and Jeffrey Epstein, for whom she claims a joint defense
• 12:31
  Speaker 1: privilege and defendant has refused to produce responsive documents, Ms.
• 12:35
  Speaker 1: Roberts objects in that it seeks information protected by the
• 12:39
  Speaker 1: attorney-client privilege, the attorney-work-product privilege, and any other applicable privilege.
• 12:44
  Speaker 1: At this point in time, Ms. Roberts has not found
• 12:47
  Speaker 1: any non-privileged documents responsive to this request, but continues to
• 12:51
  Speaker 1: search for responsive documents. Number 26. All documents concerning any
• 12:57
  Speaker 1: prescription drugs taken by you, including the prescribing doctor, the
• 13:01
  Speaker 1: dates of said prescription, and the dates of fulfillment, of
• 13:04
  Speaker 1: any such prescription. Response to request number 26. Ms. Roberts
• 13:10
  Speaker 1: objections to this request on the grounds that it is
• 13:13
  Speaker 1: overly broad and unduly burdensome and calls for the production
• 13:16
  Speaker 1: of documents that are irrelevant to this action and not
• 13:19
  Speaker 1: reasonably calculated to lead to the discovery of admissible evidence. Ms.
• 13:24
  Speaker 1: Roberts objects to this request in that it is not
• 13:27
  Speaker 1: limited in date range in any way. Therefore, she was
• 13:30
  Speaker 1: on a prescription drug when she was two years old
• 13:33
  Speaker 1: she would have to produce that document. Ms. Roberts also
• 13:37
  Speaker 1: objects to this request in that it is not limited
• 13:39
  Speaker 1: to prescription drugs she has taken as a result of
• 13:42
  Speaker 1: the abuse she endured. Ms. Roberts objects to this request
• 13:46
  Speaker 1: to the extent it seeks confidential medical records that are
• 13:50
  Speaker 1: not relevant to this action. Ms. Roberts objects to this
• 13:53
  Speaker 1: request to the extent it seeks documents protected by the attorney-client,
• 13:57
  Speaker 1: work product, or any other applicable privilege. Subject to and
• 14:01
  Speaker 1: without waiving the above objections, Ms. Roberts has already produced
• 14:05
  Speaker 1: baits labeled Roberts 000001 to Roberts 005353 and is producing
• 14:13
  Speaker 1: non-privileged documents responsive to the request limited to documents relating
• 14:17
  Speaker 1: to prescription drugs relating to her treatment for sexual abuse
• 14:21
  Speaker 1: she suffered at the hands of the defendant and Jeffrey
• 14:24
  Speaker 1: Epstein and relating to conditions or symptoms arising after defendant's
• 14:29
  Speaker 1: defamatory statement and will continue to supplement this production. 27.
• 14:34
  Speaker 1: All documents written or recorded which reference by name or
• 14:38
  Speaker 1: other description Ghislaine Maxwell. Response to request number 27. Ms.
• 14:43
  Speaker 1: Roberts objects in that it seeks information protected by the
• 14:46
  Speaker 1: attorney-client privilege, the attorney-work product privilege, joint defense common interest privilege,
• 14:52
  Speaker 1: the public interest privilege, and any other applicable privilege. Ms.
• 14:55
  Speaker 1: Roberts objects to this request to the extent it seeks
• 14:59
  Speaker 1: proprietary or copyright-protected materials. Subject to and without waiving the
• 15:04
  Speaker 1: above objections, Ms. Roberts has already produced documents Bates labeled
• 15:09
  Speaker 1: Robert 000001 to Robert 0005353 and will produce privileged documents
• 15:18
  Speaker 1: responsive to this request and will continue to supplement her production. 28.
• 15:23
  Speaker 1: All documents reflecting notes of or notes prepared for any
• 15:27
  Speaker 1: statements or interviews in which you reference by name or
• 15:31
  Speaker 1: other description Ghislaine Maxwell. Response to request number 28. Ms.
• 15:35
  Speaker 1: Roberts objects in that it seeks information protected by the
• 15:38
  Speaker 1: attorney-client privilege, the attorney-work product privilege, joint defense common interest privilege,
• 15:44
  Speaker 1: the public interest privilege, and any other applicable privilege. Ms.
• 15:47
  Speaker 1: Roberts objects to this request to the extent it seeks
• 15:50
  Speaker 1: proprietary or copyright-protected material. At this point in time, Ms.
• 15:55
  Speaker 1: Roberts has not found any non-privileged documents responsive to this request,
• 16:00
  Speaker 1: but continues to search for responsive documents. 29. All documents
• 16:05
  Speaker 1: concerning any communications by you, on your behalf, with any
• 16:09
  Speaker 1: media outlet, including but not limited to, the Daily Mail,
• 16:13
  Speaker 1: Daily Express, The Mirror, National Enquirer, New York Daily News,
• 16:17
  Speaker 1: Radar Online, and the New York Post, whether or not
• 16:20
  Speaker 1: such communications were on the record or off the record.
• 16:24
  Speaker 1: Response to request number 29. Ms. Roberts objects in that
• 16:27
  Speaker 1: it seeks information protected by the attorney-client privilege, the attorney
• 16:31
  Speaker 1: work product privilege, and any other applicable privilege. Ms. Roberts
• 16:35
  Speaker 1: objects to this request to the extent it seeks proprietary
• 16:39
  Speaker 1: or copyright-protected materials. Subject to and without waiving the above objections, Ms.
• 16:44
  Speaker 1: Roberts has already produced documents Bates labeled 000001 to Robert
• 16:48
  Speaker 1: 005353 and will produce non-privileged documents responsive to this request
• 16:57
  Speaker 1: and will continue to supplement her production. 30. All documents
• 17:01
  Speaker 1: concerning any income received by you from any media outlet
• 17:05
  Speaker 1: in exchange for your statement, whether on the record or
• 17:08
  Speaker 1: off the record, regarding Jeffrey Epstein, Alan M. Dershowitz, Prince Andrew,
• 17:12
  Speaker 1: Bill Clinton, or Ghislaine Maxwell, or any of the individuals
• 17:16
  Speaker 1: identified by you in response to Interrogatory Numbers 8 and 14.
• 17:21
  Speaker 1: Response to Request Number 30. Ms. Roberts objects in that
• 17:25
  Speaker 1: it seeks information protected by the attorney-client privilege, the attorney-work
• 17:29
  Speaker 1: product privilege, and any other applicable privilege. Ms. Roberts objects
• 17:33
  Speaker 1: to this request to the extent it seeks proprietary or
• 17:36
  Speaker 1: copyright-protected materials. Ms. Roberts objects to this request in that
• 17:40
  Speaker 1: it seeks confidential financial information. Subject to, and without waiving
• 17:45
  Speaker 1: the above objections, Ms. Roberts has already produced documents Bates
• 17:50
  Speaker 1: labeled Robert 000001 to Robert 005353, and will produce non-privileged
• 17:58
  Speaker 1: documents responsive to this request and will continue to supplement
• 18:01
  Speaker 1: her production. Number 31. All documents concerning any actual or
• 18:07
  Speaker 1: potential book, television, or movie deals concerning your allegations about
• 18:11
  Speaker 1: being a sex slave, including but not limited to potential
• 18:15
  Speaker 1: book by former New York Police Department detective John Connolly,
• 18:18
  Speaker 1: and writer James Patterson. Response to request number 31. Ms.
• 18:23
  Speaker 1: Roberts objects in that it seeks information protected by the
• 18:26
  Speaker 1: attorney-client privilege, the attorney-work-product privilege, and any other applicable privilege. Ms.
• 18:32
  Speaker 1: Roberts objects to this request to the extent it seeks
• 18:35
  Speaker 1: proprietary or copyright-protected materials. Ms. Roberts objects to this request
• 18:40
  Speaker 1: in that it seeks confidential financial information. Subject to, and
• 18:44
  Speaker 1: without waiving the above objections, Ms. Roberts has already produced documents,
• 18:49
  Speaker 1: Bates labeled, Roberts 000001 to Roberts 005353, and will produce
• 18:57
  Speaker 1: non-privileged documents responsive to this request and will continue to
• 19:01
  Speaker 1: supplement her production. Number 32. All manuscripts and other writings,
• 19:07
  Speaker 1: whether published or unpublished, created in whole or in part
• 19:10
  Speaker 1: by or in consultation with you, concerning, relating, or referencing
• 19:15
  Speaker 1: Jeffrey Epstein, Ghislaine Maxwell, or any of their agents or associates.
• 19:20
  Speaker 1: Response to request number 32. Ms. Roberts objects in that
• 19:24
  Speaker 1: it seeks information protected by the attorney-client privilege, the attorney-work
• 19:28
  Speaker 1: product privilege, and any other applicable privilege. Ms. Roberts objects
• 19:32
  Speaker 1: to this request to the extent it seeks proprietary or
• 19:36
  Speaker 1: copyright-protected materials. Ms. Roberts objects to this request in that
• 19:40
  Speaker 1: it seeks confidential financial information. Subject to, and without waiving
• 19:44
  Speaker 1: the above objections, Ms. Roberts has already produced documents Bates
• 19:48
  Speaker 1: labeled Roberts' 000001 to Robert 005353, and will produce non-privileged
• 19:56
  Speaker 1: documents responsive to this request and will continue to supplement
• 20:00
  Speaker 1: her production. Number 33, all documents concerning or relating to
• 20:05
  Speaker 1: victims refused silence, the organization referred to in the complaint,
• 20:10
  Speaker 1: including articles of incorporation, any financial records for the organization,
• 20:14
  Speaker 1: any income you receive from the organization, and any documents
• 20:18
  Speaker 1: reflecting your role within the organization or any acts taken
• 20:22
  Speaker 1: on behalf of the organization. Response to request number 33. Ms.
• 20:27
  Speaker 1: Roberts objects in that it seeks information protected by the
• 20:30
  Speaker 1: attorney-client privilege, the attorney-work product privilege, and any other applicable privilege. Ms.
• 20:36
  Speaker 1: Roberts objects to this request to the extent It seeks
• 20:39
  Speaker 1: proprietary or copyrighted protected materials. Ms. Roberts objects to this
• 20:44
  Speaker 1: request in that it seeks confidential financial information. Subject to
• 20:49
  Speaker 1: and without waiving the above objections, Ms. Roberts has already
• 20:52
  Speaker 1: produced documents Bates labeled Robert 000001 to Robert 005353 and
• 21:00
  Speaker 1: will produce non-privileged documents responsive to this request and will
• 21:04
  Speaker 1: continue to supplement her production. 34. to the extent not
• 21:08
  Speaker 1: produced in response to the above listed requested documents, all notes, writings, photographs,
• 21:14
  Speaker 1: and or audio or video recordings made or recorded by
• 21:17
  Speaker 1: you or of you at any time that refer or
• 21:21
  Speaker 1: relate to any way to Ghislaine Maxwell. Response to request
• 21:25
  Speaker 1: number 34. Ms. Roberts objects to this request and that
• 21:28
  Speaker 1: documents responsive to this request are within the possession, custody,
• 21:32
  Speaker 1: and control of the defendant and Jeffrey Epstein, for whom
• 21:36
  Speaker 1: she claims a joint defense privilege and defendant has refused
• 21:39
  Speaker 1: to produce responsive documents. Ms. Roberts objects in that it
• 21:43
  Speaker 1: seeks information protected by the attorney-client privilege, the attorney-work product privilege,
• 21:48
  Speaker 1: and any other applicable privilege. Ms. Roberts objects to this
• 21:51
  Speaker 1: request to the extent it seeks proprietary and copyrighted protected material.
• 21:57
  Speaker 1: Subject to and without waiving the above objections, Ms. Roberts
• 22:00
  Speaker 1: has already produced documents Bates labeled Robert 000001 to Robert
• 22:07
  Speaker 1: 005353 and will produce non-privileged documents responsive to this request
• 22:13
  Speaker 1: and will continue to supplement her production. Number 35. All
• 22:18
  Speaker 1: phone records including text messages, email, social media communications, letters,
• 22:22
  Speaker 1: or any other form of communication from or to you
• 22:26
  Speaker 1: or associated with you in any way from 1998 to
• 22:29
  Speaker 1: the present which concern, relate to, Identify, mention, or reflect
• 22:33
  Speaker 1: Ghislaine Maxwell, Jeffrey Epstein, Alan Dershowitz, Prince Andrew, Bill Clinton,
• 22:38
  Speaker 1: or any of the individuals identified in your response to
• 22:42
  Speaker 1: Interrogatory No. 8 and 14. Response to Request No. 35 Ms.
• 22:48
  Speaker 1: Roberts' objections to this request on the grounds that it
• 22:50
  Speaker 1: is overly broad and unduly burdensome and calls for the
• 22:54
  Speaker 1: production of documents that are irrelevant to this action and
• 22:57
  Speaker 1: not reasonably calculated to lead to the discovery of admissible evidence. Ms.
• 23:01
  Speaker 1: Roberts objects to this request to the extent it seeks
• 23:04
  Speaker 1: documents from anyone associated with you, as that is vague
• 23:09
  Speaker 1: and ambiguous. Ms. Roberts objects to this request in that
• 23:13
  Speaker 1: documents responsive to this request are within the possession, custody,
• 23:17
  Speaker 1: and control of the defendant and Jeffrey Epstein, for whom
• 23:21
  Speaker 1: she claims the joint defense privilege and defendant has refused
• 23:24
  Speaker 1: to produce responsive documents. Ms. Roberts objects in that it
• 23:29
  Speaker 1: seeks information protected by the attorney-client privilege, the attorney-work-product privilege,
• 23:34
  Speaker 1: the public-interest privilege, and any other applicable privilege. Ms. Roberts
• 23:39
  Speaker 1: objects to this request to the extent it seeks proprietary
• 23:42
  Speaker 1: and copyrighted material. Subject to and without waiving the above objections, Ms.
• 23:47
  Speaker 1: Roberts has already produced documents Bates labeled Robert00001 to Robert005353
• 23:55
  Speaker 1: and will produce non-privileged documents responsive to this request and
• 23:59
  Speaker 1: will continue to supplement her production. While Ms. Roberts has
• 24:03
  Speaker 1: produced her documents, Ms. Roberts' response does not include documents
• 24:06
  Speaker 1: from anyone associated with you based on the above-referenced objection. 36.
• 24:13
  Speaker 1: All documents relating to massages, including but not limited to
• 24:17
  Speaker 1: any documents reflecting the recruiting or hiring of masseuses, advertising
• 24:21
  Speaker 1: for masseuses, flyers created for distribution at high schools or colleges,
• 24:26
  Speaker 1: and records reflecting emails or calls to persons, relating to massages.
• 24:31
  Speaker 1: Response to request number 36. Ms. Roberts objections to this
• 24:36
  Speaker 1: request on the grounds that it is overly broad and
• 24:39
  Speaker 1: unduly burdensome and calls for the production of documents that
• 24:42
  Speaker 1: are irrelevant to this action and not reasonably calculated to
• 24:45
  Speaker 1: lead to the discovery of admissible evidence. Ms. Roberts objects
• 24:50
  Speaker 1: to this request in that it is not limited in
• 24:53
  Speaker 1: time in any way. Ms. Roberts objects to this request
• 24:56
  Speaker 1: and that documents responsive to this request are within the possession, custody,
• 25:01
  Speaker 1: and control of defendant and Jeffrey Epstein, for whom she
• 25:04
  Speaker 1: claims a joint defense privilege and defendant has refused to
• 25:09
  Speaker 1: produce responsive documents. Ms. Roberts objects in that it seeks
• 25:12
  Speaker 1: information protected by the attorney-client privilege, the attorney-work-product privilege, public
• 25:18
  Speaker 1: interest privilege, and any other applicable privilege. Number 37. Statements
• 25:23
  Speaker 1: or records from any bank into which you deposited money
• 25:26
  Speaker 1: received from Jeffrey Epstein, any person identified in Interrogatory No.
• 25:31
  Speaker 1: 18 or 14, any witness disclosed to you in your
• 25:34
  Speaker 1: Rule 26 disclosures, any media organization, or any employee or
• 25:38
  Speaker 1: affiliate of any media organization. Response to Request No. 37. Ms.
• 25:45
  Speaker 1: Roberts objects in that it seeks information protected by her
• 25:48
  Speaker 1: attorney-client privilege. the attorney work product privilege, joint defense common
• 25:53
  Speaker 1: interest privilege, the public interest privilege, and any other applicable privilege. Ms.
• 25:57
  Speaker 1: Roberts objects to this request that it seeks personal financial information. Ms.
• 26:02
  Speaker 1: Roberts objects to this request and that it is overly
• 26:05
  Speaker 1: broad as it has no time limitation. Subject to and
• 26:09
  Speaker 1: without waiving the above objections, Ms. Roberts has already produced
• 26:13
  Speaker 1: documents labeled Robert 00001 to Robert 005353. and will produce
• 26:20
  Speaker 1: non-privileged documents responsive to this request, and will continue to
• 26:25
  Speaker 1: supplement her production. This was dated April 26th of 2016,
• 26:30
  Speaker 1: and it was signed by Sigrid McCauley. Alright folks, that's
• 26:35
  Speaker 1: a wrap for this one, and for this document as
• 26:37
  Speaker 1: a whole. And like usual, we're going to keep it
• 26:40
  Speaker 1: moving until we have them all updated and added to
• 26:43
  Speaker 1: the catalog. But until then, all of the information that
• 26:46
  Speaker 1: goes with this episode can be found in the description box.