Latest / Beyond The Horizon / Virginia Roberts And Her 2nd Supplemental Response To Maxwell's Discovery Request (Part 1) (10/25/26)

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Virginia Roberts And Her 2nd Supplemental Response To Maxwell's Discovery Request (Part 1) (10/25/26) · Beyond The Horizon

• 0:00
  Speaker 1: What's up everyone and welcome back to the Epstein Chronicles.
• 0:04
  Speaker 1: The journey into the underbelly of the Jeffrey Epstein criminal
• 0:07
  Speaker 1: enterprise continues in this episode as we begin our dive
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  Speaker 1: into the plaintiff's second amended supplemental response and objections to
• 0:16
  Speaker 1: defendant's first set of discovery requests to plaintiff. Case number 15-CV-07433-RWS,
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  Speaker 1: Virginia Roberts plaintiff. Ghislaine Maxwell, the defendant. The plaintiff hereby
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  Speaker 1: serves her second amended supplemental responses and objections to the
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  Speaker 1: defendant's first set of discovery requests. General Objections Defendant's first
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  Speaker 1: set of discovery requests violates Local Civil Rule 33.3. Defendant
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  Speaker 1: has served interrogatories that are in direct violation of that
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  Speaker 1: rule because the integratories are not restricted to those seeking
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  Speaker 1: names of witnesses with knowledge or information relevant to the
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  Speaker 1: subject matter of the action, the computation of each category
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  Speaker 1: of damage alleged, and the existence, custodian, location, and general
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  Speaker 1: description of relevant documents, including pertinent insurance agreements and other
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  Speaker 1: physical evidence or information of a similar nature. Local Civil
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  Speaker 1: Rule 33.3a. Instead, they seek information under subsections B and C,
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  Speaker 1: of Local Civil Rule 33.3, and therefore they should not
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  Speaker 1: be served because they are not a more practical method
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  Speaker 1: of obtaining the information sought than a request for production
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  Speaker 1: or a deposition, and because they were served in advance
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  Speaker 1: of the period 30 days prior to the discovery cutoff date.
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  Speaker 1: Local Civil Rule 33.3b and c. The interrogatories you served
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  Speaker 1: violate Local Rule 33.3, and we ask that you immediately
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  Speaker 1: withdraw those interrogatories. See Rule 33.3, Local Rules for the
• 2:04
  Speaker 1: Southern District of New York. See also Shannon v. New
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  Speaker 1: York City Transit Authority, No. 00-CIV-5079-Suite J, 2001, WL-286727, at 3, SDNY,
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  Speaker 1: March 22, 2001. According to Gary Fredrich, Enterprises LLC v.
• 2:27
  Speaker 1: Marvel Enterprises Inc., No. 08-SIV-1533-BSJ-JCF-2011-WL-164-2381 at 4 SDNY, April 26, 2011.
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  Speaker 1: Specifically ruled 33.3 provides a. Unless otherwise ordered by the
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  Speaker 1: court at the commencement of discovery. Interrogatories will be restricted
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  Speaker 1: to those seeking names of witnesses with knowledge of information
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  Speaker 1: relevant to the subject matter of the action, the computation
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  Speaker 1: of each category of damage alleged, and the existence, custodian, location,
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  Speaker 1: and general description of relevant documents, including pertinent insurance agreements
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  Speaker 1: and other physical evidence or information of a similar nature. b.
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  Speaker 1: During discovery, interrogatories, other than those seeking information, described in
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  Speaker 1: paragraph a above may only be served one if they
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  Speaker 1: are more practical methods of obtaining the information sought than
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  Speaker 1: a request for production or a deposition or two if
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  Speaker 1: ordered by the court see at the conclusion of the
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  Speaker 1: discovery and at least 30 days prior to the discovery
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  Speaker 1: cutoff date interrogatory seeking the claims and contentions of the
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  Speaker 1: opposing party may be served unless the court has ordered
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  Speaker 1: otherwise Similarly, requests for production numbers 1, 2, 4, 6, I, 9, 12, 30, 35,
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  Speaker 1: and 37 also violate Local Rule 33.3 in that they
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  Speaker 1: rely on the offending interrogatory requests. The rule provides that
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  Speaker 1: a party must first try to obtain discovery through document
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  Speaker 1: production and testimony. Discovery does not close in this case
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  Speaker 1: until July 1st 2016 and defendant has not yet noticed
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  Speaker 1: a deposition. As such, these interrogatories violate Local Rule 33.3
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  Speaker 1: and are premature. Defendant's first set of discovery requests also
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  Speaker 1: violates Rule 33. Fed.r.civ.p, which provides a party, may serve
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  Speaker 1: on any other party no more than 25 interrogatories, including
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  Speaker 1: all discrete subparts. in that defendant has served a total
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  Speaker 1: of 59 interrogatories, including subparts in violation of Rule 33.
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  Speaker 1: We ask that you immediately withdraw those interrogatories that exceed
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  Speaker 1: the 25 interrogatory limit set by Rule 33. Ms. Roberts
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  Speaker 1: objects to defendant's first set of discovery requests to the
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  Speaker 1: extent They seek information that is protected by any applicable privilege,
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  Speaker 1: including but not limited to attorney-client privilege, work product privilege,
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  Speaker 1: joint defense common interest privilege, public interest privilege, and any
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  Speaker 1: other applicable privilege. Ms. Roberts objects to the request to
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  Speaker 1: the extent defendants' first set of discovery requests call for
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  Speaker 1: the production of documents or information that is already in
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  Speaker 1: the possession, custody, or control of the defendant. Ms. Roberts
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  Speaker 1: further objects to the request to the extent that defendant's
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  Speaker 1: first set of discovery requests is a duplicate of documents
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  Speaker 1: and information that can equally or more readily be obtained
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  Speaker 1: by the defendant. Ms. Roberts objects to the request to
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  Speaker 1: the extent that they seek documents that are not relevant, material,
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  Speaker 1: or necessary to this action and thus are not reasonably
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  Speaker 1: calculated to lead to the discovery of admissible evidence. Many
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  Speaker 1: of the requests in the defendant's first set of Discovery
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  Speaker 1: seek documents that are in no way limited to their
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  Speaker 1: relation to this case. Indeed, they seek documents that are
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  Speaker 1: not important to resolving the issues, documents that are not
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  Speaker 1: relevant to any party's claim or defense, and documents that
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  Speaker 1: are not proportional to the needs of the case. Such
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  Speaker 1: requests create a heavy burden on Ms. Roberts, and that
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  Speaker 1: outweighs any such benefit. Such discovery is prohibited and by
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  Speaker 1: the federal rules of civil procedure, particularly under the 2015
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  Speaker 1: amendments to Rule 26B1, Fed, R.civ.p, and is wholly inappropriate. Ms.
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  Speaker 1: Roberts objects to the request to the extent that they
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  Speaker 1: are overly broad, unduly burdensome, and individually logging all privileges,
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  Speaker 1: responsive documents would be overly burdensome. Plaintiff contends that requests
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  Speaker 1: targeting such privileged information are are overly broad under Rule 26B1, Fed.R.Civ.P. Specifically, Ms.
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  Speaker 1: Roberts objects to the request as overly burdensome to the
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  Speaker 1: extent that they would require logging volumes and ever-increasing privilege
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  Speaker 1: communications between Ms. Roberts and her counsel after the date
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  Speaker 1: litigation commenced on September 21, 2015. Ms. Roberts objects to
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  Speaker 1: the request as overly burdensome to the extent that they
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  Speaker 1: would require logging volumes of privilege documents between Ms. Roberts
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  Speaker 1: and her counsel related to Jane Doe No. 1 and
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  Speaker 1: Jane Doe No. 2 v. United States, Case No. 08-80736-CIV-MARA,
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  Speaker 1: pending in the Southern District of Florida, Bradley Edwards and
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  Speaker 1: Paul Cassell v. Alan Dershowitz, Case No. CACE-15-000072, pending in
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  Speaker 1: the 17th Judicial Circuit, Broward County, Florida, and Jane Doe No.
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  Speaker 1: 102 v. Jeffrey Epstein, Case No. 0980656-CIV-Mara, Johnson, Southern District
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  Speaker 1: of Florida. Accordingly, due to the undue burden of individually
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  Speaker 1: logging responsive, privileged documents related to defendants' overly broad requests,
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  Speaker 1: Plaintiff has employed categorical logging of such privileged response documents
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  Speaker 1: pursuant to local civil rule 26.2c. Ms. Roberts objects to
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  Speaker 1: defendants' definition of your attorneys because it includes names of
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  Speaker 1: attorneys that do not represent her, including Spencer, Coven, and
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  Speaker 1: Jack Scarola. Ms. Roberts' response to defendants' first set of
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  Speaker 1: discovery requests are being made after reasonable inquiry into the
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  Speaker 1: relevant facts and are based only upon the information and
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  Speaker 1: documentation that is presently known to her. Ms. Roberts reserves
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  Speaker 1: the right to modify and or supplement her responses. Ms.
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  Speaker 1: Roberts is producing documents and information herewith, and she will
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  Speaker 1: continue to review and produce relevant documents until completion. Ms.
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  Speaker 1: Roberts incorporates her above-listed general objections in the responses herein. Interrogatories. 1. State. A.
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  Speaker 1: Your present residential address. B. Each residential address you have
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  Speaker 1: had since 1988, including any residential treatment facilities. C. Dates
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  Speaker 1: you lived at each address. D. The other persons who
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  Speaker 1: live with you at each address and for what period
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  Speaker 1: of time that they lived at such address. Response to
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  Speaker 1: Interrogatory 1. Ms. Roberts objects to this interrogatory in part
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  Speaker 1: because it violates Rule 33.3. Ms. Roberts objects to this
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  Speaker 1: interrogatory in that it seeks information that is sought by
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  Speaker 1: defendant only to harass and intimidate Ms. Roberts, who is
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  Speaker 1: a victim of sexual trafficking. Per the plaintiff's first responses
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  Speaker 1: and objections, and per our representations during the March 21, 2016,
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  Speaker 1: meet and confer call, we are working diligently to find
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  Speaker 1: information to supplement the blow information with regard to address
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  Speaker 1: and dates, and once that information is obtained, plaintiff, will
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  Speaker 1: serve supplemental responses. Additionally, per the March 21, 2016 meet
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  Speaker 1: and confer call, we are working diligently to find information
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  Speaker 1: to supplement the below information with regard to addresses and dates,
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  Speaker 1: and once that information is obtained, plaintiff will serve supplemental responses. Additionally,
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  Speaker 1: per the March 21, 2016 meet and confer phone call,
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  Speaker 1: we are addressing with the plaintiff whether she will reveal
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  Speaker 1: her address to Defendant's Council confidentially, and we will update
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  Speaker 1: you with her response. A. Due to safety concerns with
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  Speaker 1: respect to Ms. Roberts and her minor children, she is
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  Speaker 1: not at liberty to reveal her present residential location. To
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  Speaker 1: ensure that defendant is not prejudiced by the failure to
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  Speaker 1: provide information about Ms. Roberts' specific residential location, Ms. Roberts
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  Speaker 1: agrees to have her attorneys to accept service on her
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  Speaker 1: behalf of any necessary communication or filings in this matter
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  Speaker 1: to be addressed to Sigrid McCauley, ESQ, Boyes, Schiller, and Flexner, LLP.
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  Speaker 1: Then it gives the address. and B. Ms. Roberts can
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  Speaker 1: recall living at the following addresses following the period of
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  Speaker 1: 1998 to the present. Ms. Roberts may have lived at
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  Speaker 1: other locations for which she does not presently have the address. Ms.
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  Speaker 1: Roberts is providing the information she has presently to the
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  Speaker 1: best of her recollection and review of documents and will
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  Speaker 1: supplement to the extent she obtains additional information responsive to
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  Speaker 1: this interrogatory. See, Ms. Roberts believes she has lived at
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  Speaker 1: the following residences. In January 1998, Ms. Roberts was 14
• 12:00
  Speaker 1: years old. Ms. Roberts recalls one facility named Growing Together
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  Speaker 1: that was located in or around Palm Beach, but she
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  Speaker 1: does not recall the dates when she resided at the facility.
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  Speaker 1: From 2000 to 2002, Ms. Roberts lived and traveled with
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  Speaker 1: Jeffrey Epstein and stayed at his various mansions in New York,
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  Speaker 1: Palm Beach, New Mexico, and the USVI. Jeffrey Epstein also
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  Speaker 1: rented a residence for Ms. Roberts in Royal Palm Beach.
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  Speaker 1: The exact address and dates of rental are in the possession, custody,
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  Speaker 1: and control of Jeffrey Epstein, Tony Figueroa, James Michael Ostrich,
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  Speaker 1: and a few other individuals for whom Ms. Roberts cannot
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  Speaker 1: recall the names of stayed with her from time to
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  Speaker 1: time at that residence that Jeffrey Epstein rented. Ms. Roberts'
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  Speaker 1: parents' address was 129-59 Rackley Road, Loxahatchee, Florida, and she
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  Speaker 1: lived there from time to time with her mother, her father,
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  Speaker 1: and her brothers. 2C. Quentin, St. Bass Hill, NSW, in
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  Speaker 1: approximately 2003, but she is not certain of the date.
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  Speaker 1: At this location, Ms. Roberts lived with her future husband, Robert. North.
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  Speaker 1: Paramentata NSW from approximately 2003 to 2005 but she is
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  Speaker 1: not certain of those dates at this location Ms. Roberts
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  Speaker 1: lived with her husband Blue Bay NSW from approximately 2005
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  Speaker 1: to 2008 but is not certain of those dates at
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  Speaker 1: this location same people 3 Elk Street NSW from approximately
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  Speaker 1: 2008 to 2009 but is not certain of those dates
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  Speaker 1: at this location same folks 50 Robertson Road, Bass Hill
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  Speaker 1: NSW from 2009 through January 2010. At this location, Ms.
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  Speaker 1: Roberts lived with her husband. 50 Bondina Road, Glenning Valley
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  Speaker 1: NSW from approximately 2010 through October 13, 2013. At this location,
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  Speaker 1: same people. 5035 Winchester Drive, Titusville, Florida from approximately November 6,
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  Speaker 1: 2013 to October of 2014. At this location, Ms. Roberts
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  Speaker 1: lived with the same people. 1270 J Street, Penrose, Colorado.
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  Speaker 1: 81240 from approximately October of 2014 through October of 2015.
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  Speaker 1: At this location, Ms. Roberts and the same people. All right,
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  Speaker 1: we're going to wrap up episode one here. And in
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  Speaker 1: the next episode, we're going to pick up with episode two.
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  Speaker 1: All of the information that goes with this episode can
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  Speaker 1: be found in the description box.