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Virginia Robert's And The Unredacted Motion To Exceed Her Deposition Limit (10/12/26) · 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 into those unredacted documents.
• 0:08
  Speaker 1: And this time we're taking a look at the unredacted
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  Speaker 1: corrected reply in support of motion to exceed the presumptive
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  Speaker 1: 10 deposition limit. Case number 15-CV-07433-RWS, Virginia Roberts versus Ghislaine Maxwell.
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  Speaker 1: Plaintiffs amended, corrected, reply in support of motion to exceed
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  Speaker 1: the presumptive 10-deposition limit. Plaintiff Virginia Roberts, by and through
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  Speaker 1: her undersigned counsel, hereby files this reply in support of
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  Speaker 1: her motion to exceed presumptive 10-deposition limit. The motion should
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  Speaker 1: be granted because Ms. Roberts has shown good cause for
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  Speaker 1: needing to exceed the 10-deposition limit. In light of recent developments, Ms.
• 0:50
  Speaker 1: Roberts has streamlined her request and now seeks only a
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  Speaker 1: total of three additional depositions. The court should grant her
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  Speaker 1: motion and allow her to take the three additional depositions. 1.
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  Speaker 1: The proposed depositions are important to the fundamental claims and
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  Speaker 1: defenses in this case, and none are a duplicate. Defendant
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  Speaker 1: argues that the depositions Ms. Roberts seeks to take are
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  Speaker 1: somehow duplicates of each other. Even a quick reading of
• 1:18
  Speaker 1: the defendant's pleading makes clear this is untrue. Defendant repeatedly
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  Speaker 1: gives her own narrow view of what existing witnesses have said,
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  Speaker 1: for example, Defendant argues that Ms. Schoberg did not corroborate
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  Speaker 1: that Ms. Roberts is telling the truth. Defendant's response at 5.
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  Speaker 1: Defendant's characterization is untrue. But as the mere fact of
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  Speaker 1: the dispute confirms, this case is going to be hotly
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  Speaker 1: contested and the weight of the evidence on each side
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  Speaker 1: is going to be vitally important. The court is well
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  Speaker 1: aware of many other civil cases where the parties have
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  Speaker 1: taken far more than 10 depositions by mutual agreement. defendant's
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  Speaker 1: refusal to agree to a few more depositions here is
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  Speaker 1: simply an effort to keep all the relevant facts from
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  Speaker 1: being developed. Since Ms. Roberts filed her initial motion seeking
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  Speaker 1: seven additional depositions, she has worked diligently to try to
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  Speaker 1: streamline the necessary depositions and has discovered new information concerning
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  Speaker 1: witnesses and their knowledge of the claims in this case. Accordingly, Ms.
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  Speaker 1: Roberts currently brings before the court a significantly shorter list
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  Speaker 1: of witnesses she needs to depose to prove her claim,
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  Speaker 1: with some alterations. To be clear, Ms. Roberts has narrowed
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  Speaker 1: her request and is now only seeking an additional three
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  Speaker 1: depositions from the court as follows. For descriptions concerning the
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  Speaker 1: depositions already taken, defendant Ms. Schoberg, Mr. Alessi, Mr. Rogers,
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  Speaker 1: and Mr. Rizzo, and those yet to be taken, Mr. Epstein, Mr. Gow, Ms. Kellen, Ms. Marcinkova, Mr. Akari,
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  Speaker 1: and Mr. Brunel, Ms. Roberts references and incorporates her descriptions
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  Speaker 1: in her moving brief. The only remaining witness is William
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  Speaker 1: Jefferson Clinton. His deposition is necessary for the following reason.
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  Speaker 1: In a 2011 interview, Ms. Roberts mentioned a former president,
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  Speaker 1: Bill Clinton's close personal relationship with the defendant and Jeffrey Epstein.
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  Speaker 1: While Ms. Roberts made no allegations of illegal actions by
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  Speaker 1: Bill Clinton, Ms. Maxwell, in her deposition, raised Ms. Roberts'
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  Speaker 1: comments about Bill Clinton as one of the obvious lies
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  Speaker 1: to which she was referring in her public statement that
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  Speaker 1: formed the basis of this suit. Apart from the accounts
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  Speaker 1: concerning her being trafficked to Prince Andrew, ID at 21
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  Speaker 1: and 22, Ms. Roberts refers the court to Ms. Schoberg's
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  Speaker 1: deposition testimony in its entirety, DE 173 through 5. It
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  Speaker 1: is depositions like this verifying Ms. Roberts' account of being
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  Speaker 1: recruited by defendant for sex with Epstein that defendant is
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  Speaker 1: trying to avoid. However, multiple other witnesses have testimony and
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  Speaker 1: given testimony to prove her defamation claim against defendant. Ms.
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  Speaker 1: Roberts is no longer seeking the deposition, testimony of Emmy Taylor,
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  Speaker 1: JoJo Fontanella, and Michael Ryder. Defendant and Mr. Epstein and
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  Speaker 1: former President Clinton is a key person who can provide
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  Speaker 1: information about his close relationship with defendant and Mr. Epstein
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  Speaker 1: and disprove Ms. Maxwell's claims. Ms. Roberts is still working
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  Speaker 1: diligently with opposing counsel, these witnesses, and their attorneys on scheduling,
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  Speaker 1: as well as identifying other witnesses who may have factual
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  Speaker 1: information about the case. But, at this time, she seeks
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  Speaker 1: this court's approval for an additional three depositions, depositions that
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  Speaker 1: will not consume the full seven hours presumptively allotted. All
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  Speaker 1: three prongs of the three-factor test to evaluate a motion
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  Speaker 1: for additional depositions strongly support granting the motion. Atkinson v. Gord, No. 1, CIV. 0761, LAK, HBP, 2009, WL, 890682, At1, SDNY,
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  Speaker 1: April 2, 2009. First, as reviewed in detail on a
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  Speaker 1: witness-by-witness basis, above, the discovery sought is not a duplicate.
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  Speaker 1: The proposed opponents include the individual who assisted in making
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  Speaker 1: the defamatory statement, women defendant Maxwell hired to recruit girls
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  Speaker 1: for Jeffrey Epstein, an individual with intimate knowledge of defendant
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  Speaker 1: and Epstein's sexual trafficking ring, other victims of Jeffrey Epstein,
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  Speaker 1: including a then underage victim, Mr. Epstein himself, and other
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  Speaker 1: witnesses who can corroborate important pieces of Ms. Roberts' statements
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  Speaker 1: or refute Ms. Maxwell's statements and positions. These witnesses' testimony
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  Speaker 1: will corroborate Ms. Roberts' account of defendant being a recruiter
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  Speaker 1: of females for Epstein and corroborate the type of abuse
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  Speaker 1: she and others suffered. Sadly, Ms. Roberts is far from
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  Speaker 1: the only one of the defendant's victims and there are
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  Speaker 1: other witnesses whose testimony is necessary in order to demonstrate
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  Speaker 1: the truth of Ms. Roberts' claims and the falsity of
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  Speaker 1: the statements made by the defendant. Second, if Ms. Roberts
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  Speaker 1: is denied these depositions, she will not have had the
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  Speaker 1: opportunity to obtain the information by other discovery in this case.
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  Speaker 1: The court will recall from Ms. Roberts' opening motion that
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  Speaker 1: defendant's surprising lack of memory has, in no small part,
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  Speaker 1: caused the need for additional depositions. See motion at 5-8,
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  Speaker 1: listing 59 examples of memory lapses during Ms. Maxwell's deposition,
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  Speaker 1: including inability to remember events recorded on an aircraft, flight log,
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  Speaker 1: or a photograph. defendant offers no explanation for her convenient forgetfulness. Moreover,
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  Speaker 1: evidence of being recruited by defendant and being sexually assaulted
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  Speaker 1: is not something Ms. Roberts can obtain through requests for
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  Speaker 1: production or through interrogatories. The only way of obtaining such
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  Speaker 1: evidence is from witness testimony by those who were victimized,
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  Speaker 1: those who assisted defendant in recruiting and abuse, and those
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  Speaker 1: who observed the recruiting or the abuse. For example, Ronaldo
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  Speaker 1: Rizzo and a state manager for a friend of defendant
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  Speaker 1: and Epstein's, testified about an episode where defendant had threatened
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  Speaker 1: a terrified 15-year-old girl and confiscated her passport to try
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  Speaker 1: to make her have sex with Epstein on his private island,
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  Speaker 1: see Macaulay Declaration at Exhibit 2, Rizzo Deposition. Mr. Rizzo
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  Speaker 1: testified about another episode where defendant gave instructions to and
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  Speaker 1: presided over a group of 11 girls as young as
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  Speaker 1: 14 years old playing a kissing game with and for
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  Speaker 1: Jeffrey Epstein. Finally, see Macaulay Declaration at Exhibit 2, Rizzo,
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  Speaker 1: Final Deposition TR 52, 6 and 7, 55 at 23
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  Speaker 1: and 57, 23. Question, how old was this girl? Answer,
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  Speaker 1: 15 years old. What did she say? Answer, she proceeded
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  Speaker 1: to tell my wife and I that this is not
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  Speaker 1: This is blurting out, not a conversation like I'm having
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  Speaker 1: a casual conversation. That quickly, I was on an island.
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  Speaker 1: I was on the island and there was Ghislaine and
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  Speaker 1: there was Sarah, she said. They asked me for sex.
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  Speaker 1: I said no. And she says no. And she says
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  Speaker 1: Ghislaine took my passport. And I said what? And she
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  Speaker 1: says Sarah took her passport and phone and gave it
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  Speaker 1: to Ghislaine. And at that point, she said that she
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  Speaker 1: was threatened. And I said threatened? She says yes, I
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  Speaker 1: was threatened by Ghislaine. Not to discuss this. and she
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  Speaker 1: said that before she got there, she was threatened again
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  Speaker 1: by Jeffrey and Ghislaine, not to talk about what I
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  Speaker 1: had mentioned earlier about, again, the word she used was sex. Question,
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  Speaker 1: and during this time, that you're saying she is trembling,
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  Speaker 1: is her demeanor continues to be what you described it as? Answer, yes. Question,
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  Speaker 1: was she in fear? Answer, yes. See Macaulay Declaration at
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  Speaker 1: Exhibit 2, Rizzo, Final Deposition. Question, so in the house,
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  Speaker 1: tell me, if I am wrong, you have Jeffrey Epstein,
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  Speaker 1: Ghislaine Maxwell, and approximately 11 girls? Answer, yes, somewhere between
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  Speaker 1: 11 and 12. Question, can you describe the 11 to
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  Speaker 1: 12-year-old girls from your memory? Answer, in my recollection, various ages.
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  Speaker 1: They could have been from as young as 14, 15
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  Speaker 1: to 18, maybe 19, very girlish. Question, once inside the house,
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  Speaker 1: what happens next? Answer, 11. I showed Ghislaine and Jeffrey
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  Speaker 1: into the living room, and Ghislaine was the one that
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  Speaker 1: instructed the girls, pointing, that they needed to come to
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  Speaker 1: the living room. Document discovery and interrogatories are not helpful
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  Speaker 1: in obtaining this type of evidence. Depositions are needed. Third,
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  Speaker 1: the burden and expense of the proposed discovery is limited
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  Speaker 1: to three additional depositions. Defendant in this case is a
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  Speaker 1: multimillionaire with able counsel. Three depositions will not cause her
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  Speaker 1: undue burden, expense, or inconvenience these depositions are important to
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  Speaker 1: resolving the issues in this case given that very few
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  Speaker 1: witnesses reside within 100 miles of the courthouse and therefore
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  Speaker 1: cannot be compelled to trial this request for only three
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  Speaker 1: additional depositions is a reasonable request It's plain why defendant
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  Speaker 1: does not want these depositions to go forward. Ms. Schoberg, Mr. Alessi,
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  Speaker 1: and Mr. Rizzo's testimony was harmful to defendant's case, and
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  Speaker 1: the additional depositions will provide further evidence that defendant acted
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  Speaker 1: as Jeffrey Epstein's madam, proving the truth of Ms. Roberts'
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  Speaker 1: statements that defendant proclaimed publicly as obvious lies. 2. Ms.
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  Speaker 1: Roberts is seeking highly relevant trial testimony. All of the
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  Speaker 1: people Ms. Roberts seeks to depose have discoverable and important
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  Speaker 1: information regarding the elements of Ms. Roberts' claims. Ms. Roberts
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  Speaker 1: stated that defendant, very prerogative, nothing I would want my
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  Speaker 1: children to see, the girls were grinding on each other,
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  Speaker 1: lifting up their tops, it was very inappropriate. What did
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  Speaker 1: you see next? From what I knew, Jeffrey was with Ghislaine,
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  Speaker 1: and now I have all these girls acting very inappropriate.
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  Speaker 1: When the girls are kissing, either Jeff or other girls,
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  Speaker 1: where was Ghislaine Maxwell? Answer, sitting right next to Jeffrey. Question,
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  Speaker 1: is there something you remember vividly? Answer, I did pull
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  Speaker 1: the nanny aside, and I was really, my wife and
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  Speaker 1: I were dumbfounded, profound of the situation, and she mentioned
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  Speaker 1: this is an occurrence that had happened before, and they
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  Speaker 1: call it the kissing game. Ms. Roberts stated that the
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  Speaker 1: defendant recruited her and other females for sex with Jeffrey Epstein,
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  Speaker 1: the people she now seeks to depose, or all witnesses
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  Speaker 1: who can testify to defendant working, essentially, as a madam
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  Speaker 1: for Jeffrey Epstein, recruiting young females for Epstein, or corroborate
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  Speaker 1: other important aspects of her statements. The fact that the
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  Speaker 1: defendant recruited girls, some of which were underage for Epstein,
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  Speaker 1: makes Ms. Roberts claim that she was also recruited by
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  Speaker 1: the defendant to ultimately have sex with Epstein and others
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  Speaker 1: more credible, and that defendants' denials of any involvement in
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  Speaker 1: such recruiting is a ball-faced lie. Witnesses will testify that
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  Speaker 1: defendants' recruitment and management of the girls for Jeffrey Epstein
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  Speaker 1: was a major aspect of the defendants' job, and that Ms.
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  Speaker 1: Roberts' account of her sexual abuse and defendants' involvement accords
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  Speaker 1: perfectly with other witnesses' accounts of what defendants' job was
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  Speaker 1: for Epstein. That other young females were similarly recruited by
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  Speaker 1: the defendant is evidence that Ms. Roberts is telling the
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  Speaker 1: truth about her experiences, and thus direct evidence that defendant
• 12:43
  Speaker 1: defamed her when calling her a liar. Clearly, if Ms.
• 12:46
  Speaker 1: Roberts can establish that defendant's modus operandi was to recruit
• 12:50
  Speaker 1: young females for Epstein, that helps corroborate Ms. Roberts' own
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  Speaker 1: testimony that defendant recruited her for the same purposes and
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  Speaker 1: in the same manner. Although the court need not make
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  Speaker 1: a final ruling, On this evidentiary issue now, Rule 404B
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  Speaker 1: itself makes such testimony admissible. See Federal Rule Evidence 404B.
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  Speaker 1: Other Act evidence may be admissible for another purpose, such
• 13:16
  Speaker 1: as proving motive, opportunity, intent, preparation, plan, knowledge, identity, absence
• 13:22
  Speaker 1: of mistake or lack of accident. Indeed, even more specifically
• 13:26
  Speaker 1: than the general provisions, Rule 404b, Rule 415 makes these
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  Speaker 1: other acts admissible due to the fact that those involved
• 13:35
  Speaker 1: in sex abuse of minors have a strong propensity for
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  Speaker 1: repeating those crimes. See Federal Rule Evidence 415a. In civil
• 13:43
  Speaker 1: cases involving a claim for relief based on a party's
• 13:46
  Speaker 1: alleged sexual assault or child molestation, the court may admit
• 13:50
  Speaker 1: evidence that the party committed any other sexual assault or
• 13:54
  Speaker 1: child molestation. Entirely apart from corroborating Ms. Roberts' own individual abuse, however,
• 14:00
  Speaker 1: defendant fails to recognize that in calling Ms. Roberts a liar,
• 14:04
  Speaker 1: she was attacking all aspects of Ms. Roberts' account, including Ms.
• 14:08
  Speaker 1: Roberts' statements that defendant served generally as a recruiter for
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  Speaker 1: girls for Epstein and that Epstein sexually abused the underage
• 14:16
  Speaker 1: girls that were brought to him. Thus, in this defamation case,
• 14:20
  Speaker 1: the testimony of these witnesses are admissible, not only to
• 14:24
  Speaker 1: bolster Ms. Roberts' testimony about her individual abuse, but because
• 14:28
  Speaker 1: they are simply part of the body of statements whose
• 14:31
  Speaker 1: truth or falsity is at issue in this case. In addition,
• 14:36
  Speaker 1: one of the witnesses that Ms. Roberts seeks to depose
• 14:38
  Speaker 1: is a registered sex offender, Jeffrey Epstein, who stands at
• 14:42
  Speaker 1: the center of the case. Indeed, Some of the most
• 14:45
  Speaker 1: critical events took place in the presence of just three people, Ms. Roberts,
• 14:49
  Speaker 1: defendant Maxwell, and Epstein. If Epstein were to tell the truth,
• 14:53
  Speaker 1: his testimony would fully confirm Ms. Roberts' account of sexual abuse. Epstein, however,
• 14:59
  Speaker 1: may well attempt to support defendant by invoking the Fifth
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  Speaker 1: Amendment to avoid answering questions about his sexual abuse of Ms. Roberts.
• 15:07
  Speaker 1: Apparently privy to her former boyfriend Epstein's anticipated plans in
• 15:12
  Speaker 1: this regard, Defendant makes the claim that it would be
• 15:15
  Speaker 1: a convoluted argument to allow Ms. Roberts to use those
• 15:18
  Speaker 1: invocations against her. Defendant's response at 3. Tellingly, defendant's response
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  Speaker 1: brief cites no authority to refute that proposition that adverse
• 15:28
  Speaker 1: inference can be drawn against co-conspirators. Presumably this is because,
• 15:33
  Speaker 1: as recounted in Ms. Roberts' opening brief, page 20 and 22,
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  Speaker 1: The Second Circuit Seminal Decision, Labouti v. United States, 107 F. 3D
• 15:44
  Speaker 1: 110-121 Second Circuit, 1997, squarely upheld the drawing of adverse
• 15:50
  Speaker 1: inferences based on a non-party's invocation of the Fifth Amendment
• 15:54
  Speaker 1: right to remain silent. The Second Circuit instructed that the
• 15:58
  Speaker 1: circumstances of a given case, rather than status of particular
• 16:02
  Speaker 1: non-party witness, determines whether non-party witness invocation of privilege is
• 16:07
  Speaker 1: against self-incrimination is admissible in course of civil litigation. I.D.
• 16:13
  Speaker 1: at 122 and 123. The Second Circuit also held that,
• 16:17
  Speaker 1: in determining whether non-party witnesses' invocation of privilege against self-incrimination
• 16:23
  Speaker 1: in course of civil litigation and drawing of adverse inferences
• 16:27
  Speaker 1: is admissible, court may consider the following non-exclusive factors. 1.
• 16:32
  Speaker 1: Nature of witness relationship. with and loyalty to party. Two,
• 16:36
  Speaker 1: degree of control, which party is vested in witness in
• 16:39
  Speaker 1: regard to key facts and subject matter of litigation. Three,
• 16:44
  Speaker 1: whether witness is pragmatically non-captioned party in interest and whether
• 16:48
  Speaker 1: assertion of privilege advances interest of witness and party in
• 16:52
  Speaker 1: outcome of litigation. And four, whether witness was a key
• 16:56
  Speaker 1: figure in the litigation and played controlling role in respect
• 17:00
  Speaker 1: to underlying aspects. ID at 124 and 125. Ms. Roberts
• 17:06
  Speaker 1: will be able to establish that all these factors tip
• 17:09
  Speaker 1: decisively in favor of allowing an adverse inference. Accordingly, her
• 17:14
  Speaker 1: efforts to depose Epstein, Marcinkova, and Kellen seek important information
• 17:19
  Speaker 1: that will be admissible at trial. Part 3. Ms. Roberts'
• 17:24
  Speaker 1: request is timely. Defendant also argues that this motion is
• 17:28
  Speaker 1: somehow premature. Defendant's response at 2 and 3. Clearly, if Ms.
• 17:33
  Speaker 1: Roberts had waited to file her motion until later, defendant
• 17:36
  Speaker 1: would have argued until the matter came too late. The
• 17:39
  Speaker 1: motion is proper at this time because as of the
• 17:42
  Speaker 1: date of this filing, fact discovery closes in 17 days,
• 17:46
  Speaker 1: although Ms. Roberts has recently filed a motion for a
• 17:49
  Speaker 1: 30-day extension of the deadline. In order to give the
• 17:52
  Speaker 1: court the opportunity to rule as far in advance as possible,
• 17:56
  Speaker 1: thereby permitting counsel, for both sides to schedule the remaining depositions, Ms.
• 18:01
  Speaker 1: Roberts brings the motion now. She also requires a ruling
• 18:04
  Speaker 1: in advance so that she can make final plans about
• 18:07
  Speaker 1: how many depositions she has available and thus which depositions
• 18:12
  Speaker 1: she should prioritize. An additional reason this motion is appropriate
• 18:16
  Speaker 1: now is that despite Ms. Roberts' diligent pursuit of depositions,
• 18:20
  Speaker 1: many witnesses have have canceled their dates, failed to appear,
• 18:24
  Speaker 1: or wrongfully evaded service. These maneuvers have frustrated Ms. Roberts'
• 18:28
  Speaker 1: ability to take their depositions in a logical and sequential fashion,
• 18:33
  Speaker 1: complicating the planning of a deposition schedule. For example, on
• 18:37
  Speaker 1: April 11, 2016, Ms. Roberts served notice on Defendant's Council
• 18:42
  Speaker 1: for the deposition of Ronaldo Rizzo, setting it for May 13, 2016.
• 18:47
  Speaker 1: Nearly a month later, just a few days before the
• 18:50
  Speaker 1: properly noticed deposition, Defendants' Council requested that it be rescheduled,
• 18:55
  Speaker 1: and therefore that deposition did not take place until June 10, 2016. Additionally,
• 19:02
  Speaker 1: three other witnesses evaded Ms. Roberts' repeated efforts to serve them.
• 19:06
  Speaker 1: It took Ms. Roberts' motion for alternative service to convince
• 19:10
  Speaker 1: Jeffrey Epstein to allow his attorney to accept service of process.
• 19:14
  Speaker 1: The court has also before it Ms. Roberts' motion to
• 19:17
  Speaker 1: serve Sarah Kellan and Nadia Marcinkova by alternative service. These
• 19:21
  Speaker 1: witnesses' evasion of service delayed the taking of their depositions and,
• 19:26
  Speaker 1: as of the date of the filing, none have been
• 19:28
  Speaker 1: deposed yet. Conclusion For all of the reasons Ms. Roberts
• 19:32
  Speaker 1: should be allowed to take three more depositions than the
• 19:36
  Speaker 1: presumptive 10-deposition limit, a total of 13 depositions, dated June 14, 2016-2022,
• 19:43
  Speaker 1: and signed by Sigrid McCauley. All of the information that
• 19:46
  Speaker 1: goes with this episode can be found in the description box.