In her Second Amended Response to Maxwell’s discovery demands, Virginia Giuffre pushed back aggressively, refusing to yield to Maxwell’s attempts to broaden discovery into intrusive and irrelevant personal and psychological domains. She objected to Maxwell’s sprawling requests as overly burdensome, unduly invasive, and aimed at discrediting her through unnecessary exposure rather than legitimate legal pursuit. Giuffre instead reinforced her focus on evidence directly tied to the defamation claims and trafficking allegations, contesting any effort by Maxwell to turn the process into a fishing expedition or reputation‑smearing exercise under the guise of legal procedure.
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Mark as Played
Transcript
Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Speaker 1 (00:00):
What's up, everyone, and welcome back to the Epstein Chronicles.
The journey into the underbelly of the Jeffrey Epstein criminal
enterprise continues in this episode as we begin our dive
into the plaintiff's second amended supplemental response and objections to
Defendant's first set of discovery requests to plaintiff Case number
(00:21):
fifteen DASH CV DASH zero seven four three three DASH
RWs Virginia Roberts Plaintiff Glenn Maxwell, the defendant. The plaintiff
hereby serves her second amended supplemental responses and objections to
the Defendant's first set of discovery requests. General objections. Defendant's
(00:43):
first set of discovery requests violates Local Civil Rule thirty
three point three. Defendant has served interrogatories that are in
direct violation of that rule because the integratories are not
restricted to those seeking names of witnesses with knowledge or
information relevant to the subject matter of the action, the
(01:05):
computation of each category of damage alleged, and the existence
custodian location and general description of relevant documents, including pertinent
insurance agreements and other physical evidence or information of a
similar nature. Local Civil Rule thirty three three a instead
(01:25):
they seek information under subsections B and C of Local
Civil Rule thirty three point three, and therefore they should
not be served because they are not a more practical
method of obtaining the information sought than a request for
production or a deposition, and because they were served in
advance of the period thirty days prior to the discovery
(01:48):
cutoff date Local Civil Rule thirty three point three B
and C. The interrogatories you serve to violate Local Rule
thirty three point three, and we ask that you immediately
withdraw the interrogatories s Rule thirty three dot three. Local
rules for the Southern District of New York. See also
Shannon versus New York City Transit Authority number zero zero
(02:11):
SIV five zero seven nine sweet j two thousand and one,
WL twenty eight sixty seven twenty seven AT three SDN
Y March twenty second, two thousand and one. According to
Gary Fridrich Enterprises, LLC versus Marvel Enterprises Incorporated, Number zero
eight SIV fifteen thirty three BSJ JCF twenty eleven, WL
(02:36):
one sixty four twenty three eighty one AT four SDNY,
April twenty six, twenty eleven. Specifically, ruled thirty three point
three provides a unless otherwise ordered by the court at
the commencement of discovery, interrogatories will be restricted to those
seeking names of witnesses with knowledge of information relevant to
(02:58):
the subject matter of the APA, the computation of each
category of damage alleged, and the existence custodian location and
general description of relevant documents, including pertinent insurance agreements and
other physical evidence or information of a similar nature. B
During discovery, interrogatories other than those seeking information described in
(03:22):
paragraph A above may only be served one if there
are more practical methods of obtaining the information sought than
a request for production or a debt position, or two
if ordered by the court c at the conclusion of
the discovery and at least thirty days prior to the
discovery cut off date. Interrogatory seeking the claims and contentions
(03:45):
of the opposing party may be served unless the court
has ordered otherwise. Similarly, requests for production numbers one, two, four, six, I, nine, twelve, thirty,
thirty five, and thirty seven also violate Local Rule thirty
three dot three in that they rely on the offending
(04:06):
interrogatory requests. The rule provides that a party must first
try to obtain discovery through document production and testimony. Discovery
does not close in this case until July first, twenty sixteen,
and defendant has not yet noticed a deposition. As such,
these interrogatories violate local rule thirty three dot three and
(04:27):
are premature. Defendants first set of discovery requests also violates
Rule thirty three fed dot R dot SIV, dot P,
which provides a party may serve on any other party
no more than twenty five interrogatories, including all discrete subparts.
In that defendant has served a total of fifty nine
(04:48):
interrogatories including subparts, in violation of rule thirty three. We
ask that you immediately withdraw those interrogatories that exceed the
twenty five interrogatory limits by rule thirty three. Miss Roberts
objects to Defendant's first set of discovery requests to the
extent they seek information that is protected by any applicable privilege,
(05:11):
including but not limited to, attorney client privilege, work product privilege,
joint defense, common interest privilege, public interest privilege, and any
other applicable privilege. Miss Roberts objects to the requests to
the extent Defendant's first set of discovery requests call for
the production of documents or information that is already in
(05:32):
the possession, custody, or control of the defendant. Miss Roberts
further objects to the request to the extent that defendant's
first set of discovery requests is a duplicate of documents
and information that can equally or more readily be obtained
by the defendant. Miss Roberts objects to the request to
the extent that they seek documents that are not relevant, material,
(05:55):
or necessary to this action, and thus are not reasonably
calculated to lead to the discovery of admissible evidence. Many
of the requests in the defendant's first set of discovery
seek documents that are in no way limited to their
relation to this case. Indeed, they seek documents that are
not important to resolving the issues, documents that are not
(06:16):
relevant to any party's claim or defense, and documents that
are not proportional to the needs of the case. Such
requests create a heavy burden on Miss Roberts and that
outweighs any such benefit. Such discovery is prohibited by the
Federal Rules of Civil Procedure, particularly under the twenty fifteen
(06:36):
amendments to Rule twenty six B one fed are DOT SIV,
DOT P and is wholly inappropriate. Miss Roberts objects to
the request to the extent that they are overly broad,
unduly burdensome, and individually logging all privileges responsive documents would
be overly burdensome. Plaintiff contends that request targeting such privileged
(06:59):
and information are overly broad under Rule twenty six B
one FED dot R dot SIEV dot P. Specifically, Miss
Roberts subjects to the requests as overly burdensome to the
extent that they would require logging volumes and ever increasing
privileged communications between Miss Roberts Ender Council after the date
(07:20):
litigation commenced on September twenty first, twenty fifteen. Miss Roberts
objects to the requests as overly burdensome to the extent
that they would require logging volumes of privileged documents between
Miss Roberts Ender Council related to Jane Doe number one
and Jane do number two versus United States Case number
(07:41):
zero eight DASH eight zero seven three six DASH Sieve
dash Mara pending in the Southern District of Florida. Bradley
Edwards and Paul Kassel verst Allandershowitz case number CAACEE fifteen
DASH zero zero zero zero seven two pending in the
seventeenth Judicial Circuit, Broward County, Florida and Jane Doe number
(08:02):
one oh two versus Jeffrey Epstein case number zero nine
eight zero six five six Dash Sieve Dash Mara Johnson,
Southern District of Florida. Accordingly, due to the undue burden
of individually logging responsive privileged documents related to Defendant's overly
broad requests, Plaintiff has employed categorical logging of such privileged
(08:26):
response documents pursuant to local Civil Rule twenty six dot
two C. Miss Roberts objects to Defendant's definition of your
attorneys because it includes names of attorneys that do not
represent her, including Spencer Covin and Jack Scarola. Miss Roberts's
response to Defendant's first set of discovery requests are being
(08:47):
made after reasonable inquiry into the relevant facts and are
based only upon the information and documentation that is presently
known tour. Miss Roberts reserves the right to modify and
or supplement her responses. Miss Roberts is producing documents and
information herewith and she will continue to review and produce
(09:08):
relevant documents. Until completion. Miss Roberts incorporates her above listed
general objections and the responses Herein interrogatories one state A
your present residential address. B each residential address you have
had since nineteen eighty eight, including any residential treatment facilities.
(09:30):
C dates you lived at each address. D the other
persons who live with you at each address, and for
what period of time that they lived at such address.
Response to Interrogatory one, Miss Roberts objects to this interrogatory
in part because it violates Rule thirty three dot three.
Miss Roberts objects to this interrogatory in that it seeks
(09:52):
information that is sought by defendant only to harass and
intimidate Miss Roberts, who is a victim of sexual trafficking.
Are the plaintiffs first responses and objections and per our
representations During the March twenty first, twenty sixteen Meet and
Confer call, we are working diligently. It'll find information to
supplement the blow information with regard to address end dates,
(10:15):
and once that information is obtained, plaintiff will serve supplemental responses. Additionally,
per the March twenty first, twenty sixteen Meet and Confer Call,
we are working diligently to find information to supplement the
below information with regard to addresses, end dates, and once
that information is obtained, Plaintiff will serve supplemental responses. Additionally,
(10:38):
per the March twenty first, twenty sixteen meet and confer
phone call, we are addressing with the plaintiff whether she
will reveal her address to Defendant's counsel confidentially and we
will update you with her response. A. Due to safety
concerns with respect to Miss Roberts and her minor children,
she is not at liberty to reveal her plays residential location.
(11:02):
To ensure that defendant is not prejudiced by the failure
to provide information about Miss roberts specific residential location, Miss
Roberts agrees to have her attorneys to accept service on
her behalf of any necessary communication or filings in this
matter to be addressed to Sigrid McAuley, ESQ, Boys, Schiller
(11:23):
and Flexner, LLP. Then it gives the address and b
Miss Roberts can recall living at the following addresses following
the period of nineteen ninety eight to the present. Miss
Roberts may have lived at other locations for which she
does not presently have the address. Miss Roberts is providing
the information she has presently to the best of her
(11:43):
recollection and review of documents, and will supplement to the
extent she obtains additional information responsive to this interrogatory. See.
Miss Roberts believes she has lived at the following residences.
In January nineteen ninety eight, Miss Roberts will fourteen years old.
Miss Roberts recalls one facility name Growing Together, that was
(12:05):
located in or around Palm Beach, but she does not
recall the dates when she resided at the facility. From
two thousand to two thousand and two, Miss Roberts lived
and traveled with Jeffrey Epstein and stayed at his various
mansions in New York, Palm Beach, New Mexico, and the USVII.
(12:26):
Jeffrey Epstein also rented a residence for Miss Roberts in
Royal Palm Beach. The exact address and dates of rental
are in the possession custody in control of Jeffrey Epstein,
Tony Figueroa, James Michael Austrich, and a few other individuals
for whom Miss Roberts cannot recall the names of stayed
with her from time to time at that residence that
(12:47):
Jeffrey Epstein rented. Miss Roberts' parents address was one twenty
nine fifty nine Rackley Road, Loxahatchie, Florida, and she lived
there from time to time with her mother, her father,
and her brother's two c Quentin Saint Bass Hill and
SW in approximately two thousand and three, but she is
not certain of the date. At this location, Miss Roberts
(13:09):
lived with her future husband, Robert North Paramentata, NSW from
approximately two thousand and three to two thousand and five,
but she is not certain of those dates. At this location,
Miss Roberts lived with her husband Blue Bay, NSW from
approximately two thousand and five to two thousand and eight,
but is not certain of those dates. At this location,
(13:31):
same people three Elk Street, NSW from approximately two thousand
and eight to two thousand and nine, but is not
certain of those dates. At this location, Same folks fifty
Robertson Road, bass Hill and SW from two thousand and
nine through January twenty ten. At this location, Miss Roberts
lived with her husband fifty Bundina Road, Glenning Valley, n
(13:55):
SW from approximately twenty ten through October thirteenth, thirteen at
this location, same people, fifty thirty five Winchester Drive, Titusville, Florida,
from approximately November sixth, twenty thirteen to October of twenty fourteen.
At this location, Miss Roberts lived with the same people
(14:16):
twelve seventy j Street, Penrose, Colorado, eighty one two forty
from approximately October of twenty fourteen through October of twenty
fifteen at this location, Miss Roberts and the same people.
Response to Interrogatory number two. Miss Roberts objects to this
request in that it violates Rule thirty three dot three.
(14:39):
Miss Roberts objects to this request that is overly abroad
and seeks information solely to harass and intimidate Miss Roberts
for the period of nineteen ninety eight to the present.
Miss Roberts provides the following information. During the time period
that she was sexually trafficked by Jeffrey Epstein and the defendant.
(14:59):
The the defendant provided Miss Roberts with a cell phone
so that she could be reached by the defendant and
Jeffrey Epstein at any time. Defendant in possession of the
information relating to this cell phone that she provided to
Miss Roberts. Miss Roberts is responding with the information she
can presently recall, but to the extent she obtains additional information,
(15:21):
she will supplement this response. She can recall the following
cell numbers. She gives some cell numbers. Miss Roberts had
a Facebook account for a short time, but it's no
longer active. Per our representations during the March twenty first,
twenty fifteen meet and confer phone call. We are working
diligently to find information to supplement the above information, and
(15:42):
once that information is obtained, plaintiff will serve supplemental responses three.
Identify each attorney who has represented you from nineteen ninety
eight to the present, the dates of any such representation,
and the nature of the representation. Response to interrogati or
number three. Miss Roberts objects to this interrogatory as it
(16:04):
seeks privileged information relating to her representation by attorneys. Miss
Roberts responds as follows. Bob Joseph Berg, Katherine w eesel
Amy Eldree, among other possible Podthurst or sec PA attorneys
represented Miss Roberts as a party in the litigation styled
as Jane Doe Number one oh two vers Jeffrey Epstein
(16:26):
case numbers zero nine eight zero six five six SIV
Mara Johnson starting on January twenty seventh, two thousand and nine,
Stan Pottinger, David Boys, and Sigared McAuley, along with other
Boys Schiller and Flexner LLP. Boys Schiller Attorneys represented Miss
Roberts as a non party in the litigation styled as
(16:48):
Bradley Edwards and Paul Kassel versus Alan Dershowitz case number
fifteen dashes zero zero zero zero seven to two seventeenth
Judicial District, Broward County, Florida, starting in February of five,
twenty fifteen, Brad Edwards along with other Farmer Jaffey Weissing, Edwards, Fistos,
Ann Lherman, pl Farmer Jaffee Attorneys, Paul Cassel, Stan Pottinger,
(17:11):
David Boys, and Sigared McCauley, along with other Boys. Schiller
Attorneys represent Miss Roberts as a party in the litigation
styled Roberts versus Maxwell fifteen dash CV DASH zero seven
four three three DASH RWs in the Southern District of
New York and the complaint of which was filed in
September of twenty fifteen, Paul Casell represents Miss Roberts as
(17:35):
a non party in the litigation style is Jane Doe
Number one and Jane Doe number two first United States
Case number zero eight DASH eight zero seven three six
DASH SIV DASH Mara, Southern District of Florida. Starting in
May of twenty fourteen, Brad Edwards, along with other Farmer
Jaffey attorneys, represents Miss Roberts as a non party in
(17:57):
the litigation styled is Jane Doe number one and N
Jane do number two versus the United States Case number
zero eight DASH eight zero seven three six DASH CIV
DASH Mara, Southern District of Florida. Starting in twenty eleven,
Brad Edwards provided Miss Roberts with legal advice concerning media
inquiries Miss Roberts had received. Starting in twenty eleven, Paul Cassel,
(18:21):
Brad Edwards, along with other Farmer Jaffe attorneys, Stan Pottinger,
David Boys, along with other Boys Shiller attorneys, represented Miss Roberts,
wrote guarding investigations into potential legal action. Starting in the
second half of twenty fourteen, Paul Cassel, Brad Edwards, along
with other Farmer Jaffee attorneys Stan Pottinger, David Boys, and
(18:43):
Sigared McAuley, along with other Boys Shiller Attorneys, represent Miss
Roberts as a cooperating witness with regard to law enforcement investigation.
Starting in May of twenty fifteen, Paul Cassell provided Miss
Roberts with legal advice concerning potential legal action. Starting in
early twenty eleven, Paul Cassel and Brad Edwards, along with
(19:04):
other Farmer Jaffey Attorneys, represented Miss Roberts and victims Refuse Silence,
giving advice regarding victims refuse silence. Starting October twenty fourteen,
Meg Garvin, a law professor at Lewis and Clark Law
School and the executive director of the National Crime Victim
Law Institute, represented Miss Roberts and Victims Refuse Silence, giving
(19:27):
advice regarding victims refuse silence. Starting in October twenty fourteen,
Sigared McAuley, along with other Boys in Schiller Attorneys, represented
Miss Roberts and victims Refuse Silence, giving advice regarding victims
refuse silence. Starting in February of twenty fifteen, four identify
(19:47):
each communication, including the transmission of any document that you
or your attorney have had with any local, state, or
federal law enforcement agent or agency, whether in the United
States or any other country, whether in your capacity as
a purported victim, witness, or a perpetrator of any criminal activity,
and whether as a juvenile or as an adult, including
(20:11):
without limitation, A the date of any such communication. B
the form of any such communication, whether oral or written.
If written in the format of any such communication, see
the identities of all persons involved in the communication, including
the identity of the law enforcement agency with whom the
(20:31):
agent is or was affiliated. D The case number associated
with any such communication. E The subject matter of any
such communication. F The disposition of any case associated with
any such communication, irrespective of whether the matter was sealed, expunged,
or later dismissed. Response to Interrogatory number four, Miss Roberts
(20:57):
objects to this interrogatory in that that it violates local
Rule thirty three three. Miss Roberts objects to this interrogatory
in that it seeks protected information regarding confidential investigations. Miss
Roberts objects in that it seeks information protected by attorney
client privilege, the attorney work product privilege, joint defense, common
(21:18):
interest privilege, the public interest privilege, and any other applicable privilege.
Miss Roberts objects to the extent this seeks information regarding
sexual assaults that occurred prior to her involvement with the
defendant and Jeffrey Epstein. Miss Roberts responds as follows. Miss Roberts,
in accordance with the Court's direction at the hearing on
(21:38):
April twenty first, twenty sixteen, has submitted documents to the
Court for in camera review. Miss Roberts met with the
FBI honor about March seventeenth, twenty eleven. Miss Roberts also
corresponded with Maria Villefano the U S Attorney's Office, and
the correspondence has been produced. Five. I Identify each communication
(22:01):
that you and your attorneys have had with any author, reporter, correspondent, columnist, writer, commentator,
investigative journalist, photojournalist, newspaper person, freelance reporter, stringer, or any
other employee of any media organization or independent consultant to
the same, including a the date of any such communication,
(22:22):
b the form of any such communication, whether oral or written, and,
if written, the format of any such communication. S The
identities of all persons involved in such communication, including the
identity of the media organization with whom the agent is
or was affiliated. D the article, title, data, publication, and
(22:44):
means of publication of any article, report, or reprinting of
any such communication made by you or your attorneys. E.
The amount of income that you and your attorneys received
in exchange for any such communication. F The day on
which you and your attorneys received any such income for
any such communication. Response to Interrogatory number five. Miss Roberts
(23:10):
objects to this interrogatory in that it violates local Rule
thirty three three. Miss Roberts objects in that it seeks
information protected by attorney client privilege, the attorney work product privilege,
joint defense, common interest privilege, and the public interest privilege,
and any other applicable privilege. Miss Roberts objects in that
this request is overly broad and unduly burdensome. Six. Identify
(23:35):
any false statements attributed to Glaine Maxwell which have been
published globally, including within the Southern District of New York,
as you can tend in paragraph nine of count one
of your complaint, including a the exact false statement, b
the date of its publication, c the publishing entity and
title of any publication containing the purportedly false statement. D
(23:59):
the URL or Internet address for any Internet version of
such publication, n E the nature of the publication, whether
in print, Internet broadcast, or some other form of media.
Response to Interrogatory number six, Miss Roberts objects to this
interrogatory in that it violates local Rule thirty three dot three.
(24:21):
Miss Roberts objects in that it seeks information protected by
the attorney client privilege, the attorney work product privilege, joint defense,
common interest privilege, and the public interest privilege, and any
other applicable privilege. Miss Roberts further objects because the information
requested above is in the possession of the defendant, who
has failed to comply with her production obligations. In this matter. Seven,
(24:45):
State whether you believe that you have ever been defamed
by anyone other than Glain Maxwell, If so as to
each alleged act of defamation, state a the exact false statement,
b the date of its publication, c the publishing entity
and title of any publication containing purportedly false statement, D
(25:06):
the URL or Internet address of any Internet version of
such a publication, and e the nature of the publication,
whether in print, Internet broadcast, or some other form of media.
Response to Interrogatory number seven, Miss Roberts subjects to this request,
and that it violates local Rule thirty three dot three.
(25:26):
Miss Roberts subjects to the request and that it seeks
information protected by the attorney client work product privilege. Miss
Roberts subjects to this interrogatory and that is not limited
in time or to the subject matter of this litigation. Eight.
Identify the individual's referenced in your pleadings filed in the
US District Court for the Southern District of Florida, Jane
(25:49):
Doe one and Jane do two, first, United States of
America zero eight dash CV DASH eight zero seven three
six dash cam as the high profile non party individuals
to whom mister Jeffrey Epstein sexually trafficked you, including numerous
prominent American politicians, powerful business executives, foreign presidents, a well
(26:10):
known prime minister, and other world leaders, including as to
each episode of alleged sexual trafficking, a the date of
any such sexual trafficking, b the location of any such
sexual trafficking, c any witnesses to any such sexual trafficking,
D any income you received in exchange for such sexual trafficking,
(26:32):
and E any documents you have to support or corroborate
your claim of such sexual trafficking. All right, folks, we're
gonna wrap up right here, and in the next episode,
we're gonna pick up where we left off.
What's up, everyone, and welcome back to the Epstein Chronicles.
The journey into the underbelly of the Jeffrey Epstein criminal
enterprise continues in this episode as we begin our dive
into the plaintiff's second amended supplemental response and objections to
Defendant's first set of discovery requests to plaintiff Case number
(00:21):
fifteen DASH CV DASH zero seven four three three DASH
RWs Virginia Roberts Plaintiff Glenn Maxwell, the defendant. The plaintiff
hereby serves her second amended supplemental responses and objections to
the Defendant's first set of discovery requests. General objections. Defendant's
(00:43):
first set of discovery requests violates Local Civil Rule thirty
three point three. Defendant has served interrogatories that are in
direct violation of that rule because the integratories are not
restricted to those seeking names of witnesses with knowledge or
information relevant to the subject matter of the action, the
(01:05):
computation of each category of damage alleged, and the existence
custodian location and general description of relevant documents, including pertinent
insurance agreements and other physical evidence or information of a
similar nature. Local Civil Rule thirty three three a instead
(01:25):
they seek information under subsections B and C of Local
Civil Rule thirty three point three, and therefore they should
not be served because they are not a more practical
method of obtaining the information sought than a request for
production or a deposition, and because they were served in
advance of the period thirty days prior to the discovery
(01:48):
cutoff date Local Civil Rule thirty three point three B
and C. The interrogatories you serve to violate Local Rule
thirty three point three, and we ask that you immediately
withdraw the interrogatories s Rule thirty three dot three. Local
rules for the Southern District of New York. See also
Shannon versus New York City Transit Authority number zero zero
(02:11):
SIV five zero seven nine sweet j two thousand and one,
WL twenty eight sixty seven twenty seven AT three SDN
Y March twenty second, two thousand and one. According to
Gary Fridrich Enterprises, LLC versus Marvel Enterprises Incorporated, Number zero
eight SIV fifteen thirty three BSJ JCF twenty eleven, WL
(02:36):
one sixty four twenty three eighty one AT four SDNY,
April twenty six, twenty eleven. Specifically, ruled thirty three point
three provides a unless otherwise ordered by the court at
the commencement of discovery, interrogatories will be restricted to those
seeking names of witnesses with knowledge of information relevant to
(02:58):
the subject matter of the APA, the computation of each
category of damage alleged, and the existence custodian location and
general description of relevant documents, including pertinent insurance agreements and
other physical evidence or information of a similar nature. B
During discovery, interrogatories other than those seeking information described in
(03:22):
paragraph A above may only be served one if there
are more practical methods of obtaining the information sought than
a request for production or a debt position, or two
if ordered by the court c at the conclusion of
the discovery and at least thirty days prior to the
discovery cut off date. Interrogatory seeking the claims and contentions
(03:45):
of the opposing party may be served unless the court
has ordered otherwise. Similarly, requests for production numbers one, two, four, six, I, nine, twelve, thirty,
thirty five, and thirty seven also violate Local Rule thirty
three dot three in that they rely on the offending
(04:06):
interrogatory requests. The rule provides that a party must first
try to obtain discovery through document production and testimony. Discovery
does not close in this case until July first, twenty sixteen,
and defendant has not yet noticed a deposition. As such,
these interrogatories violate local rule thirty three dot three and
(04:27):
are premature. Defendants first set of discovery requests also violates
Rule thirty three fed dot R dot SIV, dot P,
which provides a party may serve on any other party
no more than twenty five interrogatories, including all discrete subparts.
In that defendant has served a total of fifty nine
(04:48):
interrogatories including subparts, in violation of rule thirty three. We
ask that you immediately withdraw those interrogatories that exceed the
twenty five interrogatory limits by rule thirty three. Miss Roberts
objects to Defendant's first set of discovery requests to the
extent they seek information that is protected by any applicable privilege,
(05:11):
including but not limited to, attorney client privilege, work product privilege,
joint defense, common interest privilege, public interest privilege, and any
other applicable privilege. Miss Roberts objects to the requests to
the extent Defendant's first set of discovery requests call for
the production of documents or information that is already in
(05:32):
the possession, custody, or control of the defendant. Miss Roberts
further objects to the request to the extent that defendant's
first set of discovery requests is a duplicate of documents
and information that can equally or more readily be obtained
by the defendant. Miss Roberts objects to the request to
the extent that they seek documents that are not relevant, material,
(05:55):
or necessary to this action, and thus are not reasonably
calculated to lead to the discovery of admissible evidence. Many
of the requests in the defendant's first set of discovery
seek documents that are in no way limited to their
relation to this case. Indeed, they seek documents that are
not important to resolving the issues, documents that are not
(06:16):
relevant to any party's claim or defense, and documents that
are not proportional to the needs of the case. Such
requests create a heavy burden on Miss Roberts and that
outweighs any such benefit. Such discovery is prohibited by the
Federal Rules of Civil Procedure, particularly under the twenty fifteen
(06:36):
amendments to Rule twenty six B one fed are DOT SIV,
DOT P and is wholly inappropriate. Miss Roberts objects to
the request to the extent that they are overly broad,
unduly burdensome, and individually logging all privileges responsive documents would
be overly burdensome. Plaintiff contends that request targeting such privileged
(06:59):
and information are overly broad under Rule twenty six B
one FED dot R dot SIEV dot P. Specifically, Miss
Roberts subjects to the requests as overly burdensome to the
extent that they would require logging volumes and ever increasing
privileged communications between Miss Roberts Ender Council after the date
(07:20):
litigation commenced on September twenty first, twenty fifteen. Miss Roberts
objects to the requests as overly burdensome to the extent
that they would require logging volumes of privileged documents between
Miss Roberts Ender Council related to Jane Doe number one
and Jane do number two versus United States Case number
(07:41):
zero eight DASH eight zero seven three six DASH Sieve
dash Mara pending in the Southern District of Florida. Bradley
Edwards and Paul Kassel verst Allandershowitz case number CAACEE fifteen
DASH zero zero zero zero seven two pending in the
seventeenth Judicial Circuit, Broward County, Florida and Jane Doe number
(08:02):
one oh two versus Jeffrey Epstein case number zero nine
eight zero six five six Dash Sieve Dash Mara Johnson,
Southern District of Florida. Accordingly, due to the undue burden
of individually logging responsive privileged documents related to Defendant's overly
broad requests, Plaintiff has employed categorical logging of such privileged
(08:26):
response documents pursuant to local Civil Rule twenty six dot
two C. Miss Roberts objects to Defendant's definition of your
attorneys because it includes names of attorneys that do not
represent her, including Spencer Covin and Jack Scarola. Miss Roberts's
response to Defendant's first set of discovery requests are being
(08:47):
made after reasonable inquiry into the relevant facts and are
based only upon the information and documentation that is presently
known tour. Miss Roberts reserves the right to modify and
or supplement her responses. Miss Roberts is producing documents and
information herewith and she will continue to review and produce
(09:08):
relevant documents. Until completion. Miss Roberts incorporates her above listed
general objections and the responses Herein interrogatories one state A
your present residential address. B each residential address you have
had since nineteen eighty eight, including any residential treatment facilities.
(09:30):
C dates you lived at each address. D the other
persons who live with you at each address, and for
what period of time that they lived at such address.
Response to Interrogatory one, Miss Roberts objects to this interrogatory
in part because it violates Rule thirty three dot three.
Miss Roberts objects to this interrogatory in that it seeks
(09:52):
information that is sought by defendant only to harass and
intimidate Miss Roberts, who is a victim of sexual trafficking.
Are the plaintiffs first responses and objections and per our
representations During the March twenty first, twenty sixteen Meet and
Confer call, we are working diligently. It'll find information to
supplement the blow information with regard to address end dates,
(10:15):
and once that information is obtained, plaintiff will serve supplemental responses. Additionally,
per the March twenty first, twenty sixteen Meet and Confer Call,
we are working diligently to find information to supplement the
below information with regard to addresses, end dates, and once
that information is obtained, Plaintiff will serve supplemental responses. Additionally,
(10:38):
per the March twenty first, twenty sixteen meet and confer
phone call, we are addressing with the plaintiff whether she
will reveal her address to Defendant's counsel confidentially and we
will update you with her response. A. Due to safety
concerns with respect to Miss Roberts and her minor children,
she is not at liberty to reveal her plays residential location.
(11:02):
To ensure that defendant is not prejudiced by the failure
to provide information about Miss roberts specific residential location, Miss
Roberts agrees to have her attorneys to accept service on
her behalf of any necessary communication or filings in this
matter to be addressed to Sigrid McAuley, ESQ, Boys, Schiller
(11:23):
and Flexner, LLP. Then it gives the address and b
Miss Roberts can recall living at the following addresses following
the period of nineteen ninety eight to the present. Miss
Roberts may have lived at other locations for which she
does not presently have the address. Miss Roberts is providing
the information she has presently to the best of her
(11:43):
recollection and review of documents, and will supplement to the
extent she obtains additional information responsive to this interrogatory. See.
Miss Roberts believes she has lived at the following residences.
In January nineteen ninety eight, Miss Roberts will fourteen years old.
Miss Roberts recalls one facility name Growing Together, that was
(12:05):
located in or around Palm Beach, but she does not
recall the dates when she resided at the facility. From
two thousand to two thousand and two, Miss Roberts lived
and traveled with Jeffrey Epstein and stayed at his various
mansions in New York, Palm Beach, New Mexico, and the USVII.
(12:26):
Jeffrey Epstein also rented a residence for Miss Roberts in
Royal Palm Beach. The exact address and dates of rental
are in the possession custody in control of Jeffrey Epstein,
Tony Figueroa, James Michael Austrich, and a few other individuals
for whom Miss Roberts cannot recall the names of stayed
with her from time to time at that residence that
(12:47):
Jeffrey Epstein rented. Miss Roberts' parents address was one twenty
nine fifty nine Rackley Road, Loxahatchie, Florida, and she lived
there from time to time with her mother, her father,
and her brother's two c Quentin Saint Bass Hill and
SW in approximately two thousand and three, but she is
not certain of the date. At this location, Miss Roberts
(13:09):
lived with her future husband, Robert North Paramentata, NSW from
approximately two thousand and three to two thousand and five,
but she is not certain of those dates. At this location,
Miss Roberts lived with her husband Blue Bay, NSW from
approximately two thousand and five to two thousand and eight,
but is not certain of those dates. At this location,
(13:31):
same people three Elk Street, NSW from approximately two thousand
and eight to two thousand and nine, but is not
certain of those dates. At this location, Same folks fifty
Robertson Road, bass Hill and SW from two thousand and
nine through January twenty ten. At this location, Miss Roberts
lived with her husband fifty Bundina Road, Glenning Valley, n
(13:55):
SW from approximately twenty ten through October thirteenth, thirteen at
this location, same people, fifty thirty five Winchester Drive, Titusville, Florida,
from approximately November sixth, twenty thirteen to October of twenty fourteen.
At this location, Miss Roberts lived with the same people
(14:16):
twelve seventy j Street, Penrose, Colorado, eighty one two forty
from approximately October of twenty fourteen through October of twenty
fifteen at this location, Miss Roberts and the same people.
Response to Interrogatory number two. Miss Roberts objects to this
request in that it violates Rule thirty three dot three.
(14:39):
Miss Roberts objects to this request that is overly abroad
and seeks information solely to harass and intimidate Miss Roberts
for the period of nineteen ninety eight to the present.
Miss Roberts provides the following information. During the time period
that she was sexually trafficked by Jeffrey Epstein and the defendant.
(14:59):
The the defendant provided Miss Roberts with a cell phone
so that she could be reached by the defendant and
Jeffrey Epstein at any time. Defendant in possession of the
information relating to this cell phone that she provided to
Miss Roberts. Miss Roberts is responding with the information she
can presently recall, but to the extent she obtains additional information,
(15:21):
she will supplement this response. She can recall the following
cell numbers. She gives some cell numbers. Miss Roberts had
a Facebook account for a short time, but it's no
longer active. Per our representations during the March twenty first,
twenty fifteen meet and confer phone call. We are working
diligently to find information to supplement the above information, and
(15:42):
once that information is obtained, plaintiff will serve supplemental responses three.
Identify each attorney who has represented you from nineteen ninety
eight to the present, the dates of any such representation,
and the nature of the representation. Response to interrogati or
number three. Miss Roberts objects to this interrogatory as it
(16:04):
seeks privileged information relating to her representation by attorneys. Miss
Roberts responds as follows. Bob Joseph Berg, Katherine w eesel
Amy Eldree, among other possible Podthurst or sec PA attorneys
represented Miss Roberts as a party in the litigation styled
as Jane Doe Number one oh two vers Jeffrey Epstein
(16:26):
case numbers zero nine eight zero six five six SIV
Mara Johnson starting on January twenty seventh, two thousand and nine,
Stan Pottinger, David Boys, and Sigared McAuley, along with other
Boys Schiller and Flexner LLP. Boys Schiller Attorneys represented Miss
Roberts as a non party in the litigation styled as
(16:48):
Bradley Edwards and Paul Kassel versus Alan Dershowitz case number
fifteen dashes zero zero zero zero seven to two seventeenth
Judicial District, Broward County, Florida, starting in February of five,
twenty fifteen, Brad Edwards along with other Farmer Jaffey Weissing, Edwards, Fistos,
Ann Lherman, pl Farmer Jaffee Attorneys, Paul Cassel, Stan Pottinger,
(17:11):
David Boys, and Sigared McCauley, along with other Boys. Schiller
Attorneys represent Miss Roberts as a party in the litigation
styled Roberts versus Maxwell fifteen dash CV DASH zero seven
four three three DASH RWs in the Southern District of
New York and the complaint of which was filed in
September of twenty fifteen, Paul Casell represents Miss Roberts as
(17:35):
a non party in the litigation style is Jane Doe
Number one and Jane Doe number two first United States
Case number zero eight DASH eight zero seven three six
DASH SIV DASH Mara, Southern District of Florida. Starting in
May of twenty fourteen, Brad Edwards, along with other Farmer
Jaffey attorneys, represents Miss Roberts as a non party in
(17:57):
the litigation styled is Jane Doe number one and N
Jane do number two versus the United States Case number
zero eight DASH eight zero seven three six DASH CIV
DASH Mara, Southern District of Florida. Starting in twenty eleven,
Brad Edwards provided Miss Roberts with legal advice concerning media
inquiries Miss Roberts had received. Starting in twenty eleven, Paul Cassel,
(18:21):
Brad Edwards, along with other Farmer Jaffe attorneys, Stan Pottinger,
David Boys, along with other Boys Shiller attorneys, represented Miss Roberts,
wrote guarding investigations into potential legal action. Starting in the
second half of twenty fourteen, Paul Cassel, Brad Edwards, along
with other Farmer Jaffee attorneys Stan Pottinger, David Boys, and
(18:43):
Sigared McAuley, along with other Boys Shiller Attorneys, represent Miss
Roberts as a cooperating witness with regard to law enforcement investigation.
Starting in May of twenty fifteen, Paul Cassell provided Miss
Roberts with legal advice concerning potential legal action. Starting in
early twenty eleven, Paul Cassel and Brad Edwards, along with
(19:04):
other Farmer Jaffey Attorneys, represented Miss Roberts and victims Refuse Silence,
giving advice regarding victims refuse silence. Starting October twenty fourteen,
Meg Garvin, a law professor at Lewis and Clark Law
School and the executive director of the National Crime Victim
Law Institute, represented Miss Roberts and Victims Refuse Silence, giving
(19:27):
advice regarding victims refuse silence. Starting in October twenty fourteen,
Sigared McAuley, along with other Boys in Schiller Attorneys, represented
Miss Roberts and victims Refuse Silence, giving advice regarding victims
refuse silence. Starting in February of twenty fifteen, four identify
(19:47):
each communication, including the transmission of any document that you
or your attorney have had with any local, state, or
federal law enforcement agent or agency, whether in the United
States or any other country, whether in your capacity as
a purported victim, witness, or a perpetrator of any criminal activity,
and whether as a juvenile or as an adult, including
(20:11):
without limitation, A the date of any such communication. B
the form of any such communication, whether oral or written.
If written in the format of any such communication, see
the identities of all persons involved in the communication, including
the identity of the law enforcement agency with whom the
(20:31):
agent is or was affiliated. D The case number associated
with any such communication. E The subject matter of any
such communication. F The disposition of any case associated with
any such communication, irrespective of whether the matter was sealed, expunged,
or later dismissed. Response to Interrogatory number four, Miss Roberts
(20:57):
objects to this interrogatory in that that it violates local
Rule thirty three three. Miss Roberts objects to this interrogatory
in that it seeks protected information regarding confidential investigations. Miss
Roberts objects in that it seeks information protected by attorney
client privilege, the attorney work product privilege, joint defense, common
(21:18):
interest privilege, the public interest privilege, and any other applicable privilege.
Miss Roberts objects to the extent this seeks information regarding
sexual assaults that occurred prior to her involvement with the
defendant and Jeffrey Epstein. Miss Roberts responds as follows. Miss Roberts,
in accordance with the Court's direction at the hearing on
(21:38):
April twenty first, twenty sixteen, has submitted documents to the
Court for in camera review. Miss Roberts met with the
FBI honor about March seventeenth, twenty eleven. Miss Roberts also
corresponded with Maria Villefano the U S Attorney's Office, and
the correspondence has been produced. Five. I Identify each communication
(22:01):
that you and your attorneys have had with any author, reporter, correspondent, columnist, writer, commentator,
investigative journalist, photojournalist, newspaper person, freelance reporter, stringer, or any
other employee of any media organization or independent consultant to
the same, including a the date of any such communication,
(22:22):
b the form of any such communication, whether oral or written, and,
if written, the format of any such communication. S The
identities of all persons involved in such communication, including the
identity of the media organization with whom the agent is
or was affiliated. D the article, title, data, publication, and
(22:44):
means of publication of any article, report, or reprinting of
any such communication made by you or your attorneys. E.
The amount of income that you and your attorneys received
in exchange for any such communication. F The day on
which you and your attorneys received any such income for
any such communication. Response to Interrogatory number five. Miss Roberts
(23:10):
objects to this interrogatory in that it violates local Rule
thirty three three. Miss Roberts objects in that it seeks
information protected by attorney client privilege, the attorney work product privilege,
joint defense, common interest privilege, and the public interest privilege,
and any other applicable privilege. Miss Roberts objects in that
this request is overly broad and unduly burdensome. Six. Identify
(23:35):
any false statements attributed to Glaine Maxwell which have been
published globally, including within the Southern District of New York,
as you can tend in paragraph nine of count one
of your complaint, including a the exact false statement, b
the date of its publication, c the publishing entity and
title of any publication containing the purportedly false statement. D
(23:59):
the URL or Internet address for any Internet version of
such publication, n E the nature of the publication, whether
in print, Internet broadcast, or some other form of media.
Response to Interrogatory number six, Miss Roberts objects to this
interrogatory in that it violates local Rule thirty three dot three.
(24:21):
Miss Roberts objects in that it seeks information protected by
the attorney client privilege, the attorney work product privilege, joint defense,
common interest privilege, and the public interest privilege, and any
other applicable privilege. Miss Roberts further objects because the information
requested above is in the possession of the defendant, who
has failed to comply with her production obligations. In this matter. Seven,
(24:45):
State whether you believe that you have ever been defamed
by anyone other than Glain Maxwell, If so as to
each alleged act of defamation, state a the exact false statement,
b the date of its publication, c the publishing entity
and title of any publication containing purportedly false statement, D
(25:06):
the URL or Internet address of any Internet version of
such a publication, and e the nature of the publication,
whether in print, Internet broadcast, or some other form of media.
Response to Interrogatory number seven, Miss Roberts subjects to this request,
and that it violates local Rule thirty three dot three.
(25:26):
Miss Roberts subjects to the request and that it seeks
information protected by the attorney client work product privilege. Miss
Roberts subjects to this interrogatory and that is not limited
in time or to the subject matter of this litigation. Eight.
Identify the individual's referenced in your pleadings filed in the
US District Court for the Southern District of Florida, Jane
(25:49):
Doe one and Jane do two, first, United States of
America zero eight dash CV DASH eight zero seven three
six dash cam as the high profile non party individuals
to whom mister Jeffrey Epstein sexually trafficked you, including numerous
prominent American politicians, powerful business executives, foreign presidents, a well
(26:10):
known prime minister, and other world leaders, including as to
each episode of alleged sexual trafficking, a the date of
any such sexual trafficking, b the location of any such
sexual trafficking, c any witnesses to any such sexual trafficking,
D any income you received in exchange for such sexual trafficking,
(26:32):
and E any documents you have to support or corroborate
your claim of such sexual trafficking. All right, folks, we're
gonna wrap up right here, and in the next episode,
we're gonna pick up where we left off.
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