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

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Virginia Roberts And Her 2nd Supplemental Response To Maxwell's Discovery Request (Part 2) (10/26/26) · 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 diving right back in to Virginia
• 0:07
  Speaker 1: Roberts' second supplemental response to discovery request from Ghislaine Maxwell.
• 0:15
  Speaker 1: Response to Interrogatory Number 2. Ms. Roberts objects to this
• 0:19
  Speaker 1: request in that it violates Rule 33.3. Ms. Roberts objects
• 0:24
  Speaker 1: to this request that is overly broad. and seeks information
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  Speaker 1: solely to harass and intimidate Miss Roberts. For the period
• 0:32
  Speaker 1: of 1998 to the present, Miss Roberts provides the following information.
• 0:38
  Speaker 1: During the time period that she was sexually trafficked by
• 0:41
  Speaker 1: Jeffrey Epstein and the defendant, the defendant provided Miss Roberts
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  Speaker 1: with a cell phone so that she could be reached
• 0:48
  Speaker 1: by the defendant and Jeffrey Epstein at any time. Defendant
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  Speaker 1: in possession of the information relating to this cell phone
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  Speaker 1: that she provided to Ms. Roberts. Ms. Roberts is responding
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  Speaker 1: with the information she can presently recall, but to the
• 1:03
  Speaker 1: extent she obtains additional information, she will supplement this response.
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  Speaker 1: She can recall the following cell numbers. She gives some
• 1:10
  Speaker 1: cell numbers. Ms. Roberts had a Facebook account for a
• 1:12
  Speaker 1: short time, but it's no longer active. Per our representations
• 1:17
  Speaker 1: during the March 21, 2015 Meet and Confer phone call,
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  Speaker 1: we are working diligently to find information to supplement the
• 1:25
  Speaker 1: above information, and once that information is obtained, plaintiff will
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  Speaker 1: serve supplemental responses. 3. Identify each attorney who has represented
• 1:34
  Speaker 1: you from 1998 to the present, the dates of any
• 1:38
  Speaker 1: such representation, and the nature of the representation. Response to
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  Speaker 1: Interrogatory No. 3 Ms. Roberts objects to this interrogatory as
• 1:47
  Speaker 1: it seeks privilege information relating to her representation by attorneys. Ms.
• 1:52
  Speaker 1: Roberts responds as follows. Bob Joseph Berg, Catherine W. Ezell,
• 1:57
  Speaker 1: Amy Eldrie, among other possible Podhurst-Orsek PA attorneys, represented Ms.
• 2:03
  Speaker 1: Roberts as a party in the litigation, styled as Jane
• 2:06
  Speaker 1: Doe No. 102 vs. Jeffrey Epstein, Case No. 09-80-656-SIV, Mara Johnson,
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  Speaker 1: starting on January 27, 2009. Stan Pottinger, David Boies, and
• 2:21
  Speaker 1: Sigrid McCauley, along with other Boies-Shiller and Flexner LLP Boies-Shiller attorneys,
• 2:27
  Speaker 1: represented Ms. Roberts as a non-party in the litigation styled
• 2:31
  Speaker 1: as Bradley Edwards and Paul Cassell versus Alan Dershowitz, case
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  Speaker 1: number 15-000072, 17th Judicial District, Broward County, Florida, starting in
• 2:43
  Speaker 1: February of 2015. Brad Edwards, along with other Farmer, Jaffe, Weising, Edwards, Fistos,
• 2:50
  Speaker 1: and Lehrman, P.L., Farmer-Jaffe attorneys, Paul Cassell, Stan Pottinger, David Boies,
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  Speaker 1: and Sigrid McCauley, along with other Boies-Shiller attorneys, represent Ms.
• 3:00
  Speaker 1: Roberts as the party's in the litigation styled Roberts v.
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  Speaker 1: Maxwell 15-CV-07433-RWS in the Southern District of New York and
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  Speaker 1: the complaint of which was filed in September of 2015.
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  Speaker 1: Paul Cassell represents Ms. Roberts as a non-party in the
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  Speaker 1: litigation styled as Jane Doe No. 1 and Jane Doe No.
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  Speaker 1: 2 v. United States Case No. 08-80736-RWS dash Civ, dash Mara,
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  Speaker 1: Southern District of Florida, starting in May of 2014. Brad Edwards,
• 3:35
  Speaker 1: along with other Farmer Jaffe attorneys, represents Ms. Roberts as
• 3:39
  Speaker 1: a non-party in the litigation styled as Jane Doe No.
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  Speaker 1: 1 and Jane Doe No. 2 versus the United States,
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  Speaker 1: case number 08-80736-CIV-Mara, Southern District of Florida, starting in 2011.
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  Speaker 1: Brad Edwards provided Ms. Roberts with legal advice concerning media
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  Speaker 1: inquiries Ms. Roberts had received starting in 2011. Paul Cassell,
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  Speaker 1: Brad Edwards, along with other Farmer, Jaffe attorneys, Stan Pottinger,
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  Speaker 1: David Boies, along with other Boies-Shiller attorneys, represented Ms. Roberts
• 4:14
  Speaker 1: regarding investigations into potential legal action starting in the second
• 4:18
  Speaker 1: half of 2014. Paul Cassell, Brad Edwards, along with other Farmer,
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  Speaker 1: Jaffe attorneys, Stan Pottinger, David Boies, and Sigrid McCauley, along
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  Speaker 1: with other Boy Schiller attorneys, represent Ms. Roberts as a
• 4:32
  Speaker 1: cooperating witness with regard to law enforcement investigation starting in
• 4:36
  Speaker 1: May of 2015. Paul Cassell provided Ms. Roberts with legal
• 4:40
  Speaker 1: advice concerning potential legal action starting in early 2011. Paul
• 4:46
  Speaker 1: Cassell and Brad Edwards, along with other Farmer Jaffe attorneys,
• 4:49
  Speaker 1: represented Ms. Roberts and Victims Refuse Silence, giving advice regarding
• 4:55
  Speaker 1: Victims Refuse Silence, starting October 2014. Meg Garvin, a law
• 5:00
  Speaker 1: professor at Lewis and Clark Law School and the executive
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  Speaker 1: director of the National Crime Victim Law Institute, represented Ms.
• 5:08
  Speaker 1: Roberts and Victims Refuse Silence, giving advice regarding Victims Refuse Silence,
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  Speaker 1: starting in October 2014. Sigrid McCauley, along with other boys
• 5:19
  Speaker 1: and Schiller attorneys, represented Ms. Roberts and Victims Refuse Silence,
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  Speaker 1: giving advice regarding victims refused silence starting in February of 2015. 4.
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  Speaker 1: Identify each communication, including the transmission of any document that
• 5:35
  Speaker 1: you or your attorney have had with any local, state,
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  Speaker 1: or federal law enforcement agent or agency involved. whether in
• 5:42
  Speaker 1: the United States or any other country, whether in your
• 5:45
  Speaker 1: capacity as a purported victim, witness, or perpetrator of any
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  Speaker 1: criminal activity, and whether as a juvenile or as an adult, including,
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  Speaker 1: without limitation, a. the date of any such communication, b.
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  Speaker 1: the form of any such communication, whether oral or written,
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  Speaker 1: if written in the format of any such communication, c.
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  Speaker 1: the identities of all persons involved in the communication, including
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  Speaker 1: the identity of the law enforcement agency with whom the
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  Speaker 1: agent is or was affiliated. d. The case number associated
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  Speaker 1: with any such communication. e. The subject matter of any
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  Speaker 1: such communication. f. The disposition of any case associated with
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  Speaker 1: any such communication, irrespective of whether the matter was sealed, expunged,
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  Speaker 1: or later dismissed. Response to Interrogatory Number 4 Ms. Roberts
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  Speaker 1: objects to this interrogatory in that it violates Local Rule 33.3. Ms.
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  Speaker 1: Roberts objects to this interrogatory in that it seeks protected
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  Speaker 1: information regarding confidential investigations. Ms. Roberts objects in that it
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  Speaker 1: seeks information protected by attorney-client privilege, the attorney-work-product privilege, joint-defense-common-interest privilege,
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  Speaker 1: the public-interest privilege, and any other applicable privilege. Ms. Roberts
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  Speaker 1: objects to the extent this seeks information regarding sexual assaults
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  Speaker 1: that occurred prior to her involvement with the defendant and
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  Speaker 1: Jeffrey Epstein. Ms. Roberts responds as follows. Ms. Roberts, in
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  Speaker 1: accordance with the court's direction at the hearing on April 21, 2016,
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  Speaker 1: has submitted documents to the court for in-camera review. Ms.
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  Speaker 1: Roberts met with the FBI and on or about March 17, 2011. Ms.
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  Speaker 1: Roberts also corresponded with Maria Villafano, the U.S. Attorney's Office,
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  Speaker 1: and the correspondence has been produced. 5. Identify each communication
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  Speaker 1: that you and your attorneys have had with any author, reporter, correspondent, columnist, writer, commentator,
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  Speaker 1: investigative journalist, photojournalist, newspaper person, freelance reporter, stringer, or any
• 7:57
  Speaker 1: other employee of any media organization. or independent consultant to
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  Speaker 1: the same, including, A, the date of any such communication, B,
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  Speaker 1: the form of any such communication, whether oral or written,
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  Speaker 1: and if written, the format of any such communication, C,
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  Speaker 1: the identities of all persons involved in such communication, including
• 8:18
  Speaker 1: the identity of the media organization with whom the agent
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  Speaker 1: is or was affiliated, D, the article title, date of publication,
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  Speaker 1: and means of publication of any article, report, or reprinting
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  Speaker 1: of any such communication made by you or your attorneys. E.
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  Speaker 1: The amount of income that you and your attorneys received
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  Speaker 1: in exchange for any such communication. F. The dates on
• 8:44
  Speaker 1: which you and your attorneys received any such income for
• 8:48
  Speaker 1: any such communication. Response to interrogatory number five. Ms. Roberts
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  Speaker 1: objects to this interrogatory in that it violates Local Rule 33.3. Ms.
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  Speaker 1: Roberts objects in that it seeks information protected by attorney-client privilege,
• 9:03
  Speaker 1: the attorney-work-product privilege, joint defense-common-interest privilege, and the public interest privilege,
• 9:09
  Speaker 1: and any other applicable privilege. Ms. Roberts objects in that
• 9:13
  Speaker 1: this request is overly broad and unduly burdensome. 6. identify
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  Speaker 1: any false statements attributed to Ghislaine Maxwell which have been
• 9:23
  Speaker 1: published globally, including within the Southern District of New York,
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  Speaker 1: as you contend in paragraph 9 of count 1 of
• 9:30
  Speaker 1: your complaint, including a. the exact false statement, b. the
• 9:34
  Speaker 1: date of its publication, c. the publishing entity and title
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  Speaker 1: of any publication containing the purportedly false statement, d. the
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  Speaker 1: URL or Internet address for any Internet version of such publication, N.E.
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  Speaker 1: The nature of the publication, whether in print, Internet, broadcast,
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  Speaker 1: or some other form of media. Response to Interrogatory No. 6. Ms.
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  Speaker 1: Roberts objects. to this interrogatory in that it violates Local
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  Speaker 1: Rule 33.3. Ms. Roberts objects in that it seeks information
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  Speaker 1: protected by the attorney-client privilege, the attorney-work-product privilege, joint defense-common-interest privilege,
• 10:14
  Speaker 1: and the public interest privilege, and any other applicable privilege. Ms.
• 10:18
  Speaker 1: Roberts further objects because the information requested above is in
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  Speaker 1: the possession of the defendant who has failed to comply
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  Speaker 1: with her production obligations in this matter. 7. State whether
• 10:29
  Speaker 1: you believe that you have ever been defamed by anyone
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  Speaker 1: other than Ghislaine Maxwell. If so, as to each alleged
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  Speaker 1: act of defamation, state a. the exact false statement b.
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  Speaker 1: the date of its publication c. the publishing entity Response
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  Speaker 1: to interrogatory number seven. Ms. Roberts objects to this request
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  Speaker 1: and that it violates Local Rule 33.3. Ms. Roberts objects
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  Speaker 1: to the request and that it seeks information protected by
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  Speaker 1: the attorney-client work product privilege. Ms. Roberts objects to this
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  Speaker 1: interrogatory and that it is not limited in time or
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  Speaker 1: to the subject matter of this litigation. 8. Identify the
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  Speaker 1: individual as referenced in your pleadings. filed in the U.S.
• 11:29
  Speaker 1: District Court for the Southern District of Florida, Jane Doe
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  Speaker 1: 1 and Jane Doe 2, versus United States of America, 08-CV-80736-CAM,
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  Speaker 1: as the high-profile, non-party individuals to whom Mr. Jeffrey Epstein
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  Speaker 1: sexually trafficked you, including numerous prominent American politicians, powerful business executives,
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  Speaker 1: foreign presidents, a well-known prime minister, and other world leaders,
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  Speaker 1: including as to each episode of alleged sexual trafficking. A.
• 12:01
  Speaker 1: The date of any such sexual trafficking. B. The location
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  Speaker 1: of any such sexual trafficking. C. Any witnesses to any
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  Speaker 1: such sexual trafficking. D. Any income you received in exchange
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  Speaker 1: for such sexual trafficking. And E. Any documents you have
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  Speaker 1: to support or corroborate your claim. of such sexual trafficking.
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  Speaker 1: All right, folks, we're going to wrap up right here.
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  Speaker 1: And in the next episode, we're going to pick up
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  Speaker 1: where we left off.