Mega Edition: Virginia Robert's Amended Reply To Ghislaine Maxwell's Discovery Motion (Part 3-4) (12/9/25)

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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Episode Transcript

Speaker 1 (00:00):
What's up everyone, and welcome back to the Epstein Chronicles.
In this episode, we're going to pick up where we
left off with the Rule fifty six dot one Court
Document nine. Identify any employment you have had from nineteen
ninety six until the present, including, without limitation, the name
of your employer or the name of any person who

(00:21):
engaged you for such employment, and the address and telephone
number for any such employment, the beginning and ending dates
of any such employment, your job title in any such employment,
and your income from such employment. Response to Interrogatory number nine,
Miss Roberts subjects to this request in that it is

(00:41):
overly broad and unduly burdensome, and seeks information that is
not relevant to this case. Miss Roberts responds as follows.
Miss Roberts worked at mar A Lago as a locker
room attendant for the Spy Area. Records produced in this
case identify the date of employment as two thousand, as
she recalled being there in the summer. Miss Roberts previously

(01:02):
attempted to gather employment records from mar A Lago see
Roberts zero zero two seven two six. She earned approximately
nine dollars an hour. The address is eleven hundred South
Ocean Boulevard, Palm Beach, Florida, thirty three four eighty with
the telephone number of five six one eight three two
two six zero zero. Miss Roberts worked at Roadhouse Grill

(01:26):
as a waitress in approximately two thousand and two, but
Miss Roberts is unsure of the exact dates of employment.
Her wages primarily consisted of tips. Miss Roberts does not
recall the location of the Roadhouse Grill. A Google search
for the same yields and address of eighty eight sixty
five Southern Boulevard in West Palm Beach, Florida. Miss Roberts

(01:47):
worked at Employment Training and Recruiting Australia from approximately two
thousand and five through January of two thousand and six,
but Miss Roberts is unsure of the exact dates of employment.
Miss Roberts was a receipttionist, earning approximately fifteen dollars per
hour to the best of her recollection. Upon information and belief,
this corporation is currently located in a different location from

(02:11):
the location at which Miss Roberts was employed. Upon information
and belief based on an Internet search, the new location
of this entity is one two three Donna Forne Street,
Gotford and sw Miss Roberts worked at Gemma Catering wedding
receptions in approximately two thousand and four. She received approximately

(02:32):
ten dollars an hour. She does not recall the name
of the proprietor nor its location. Miss Roberts worked at
Manway Logistics in approximately two thousand and three. Miss Roberts
recalls it located in or around Sydney, Australia. An Internet
search yielded an address of two forty six Miller Road. Ten.

(02:53):
Identify any income from any source other than your employment
that you have received from January first, ninety nine until
the present, including the person or entity providing such income,
the amount of the income, the dates on which any
such income was received, and the nature of the income,
whether alan investment proceeds, legal settlement, asset, seal, gift, or

(03:16):
other source. Response to Interrogatory number ten, Miss Roberts objects
to this interrogatory in that it violates Local Rule thirty
three three. Miss Roberts objects to this request in that
it is overly broad and seeks confidential financial information. Miss
Roberts objects to this interrogatory in that it seeks information

(03:36):
covered by confidentiality provisions. Miss Roberts objects to this information
in that any payment information for the sexual trafficking she
endured at the hands of Jeffrey Epstein and Glen Maxwell
is in possession, custody and control of the defendant and
Jeffrey Epstein. Miss Roberts is in possession of a responsive
document that contains the confidentiality provision and obtains and produces

(04:01):
to Miss Roberts a written waiver from her co conspirator
mister Epstein of the confidentiality provision, freeing Miss Roberts from
any liability whatsoever under the confidentiality provision. She will produce
that document eleven. Identify any facts upon which you base
your contention that you have suffered as a result of

(04:22):
the alleged defamation by Glen Maxwell, pasted in future lost
wages and passed in future loss of earning capacity and
actual earnings precise amounts yet to be computed, but not
less than five million. Response to interrogatory number eleven, Miss
Roberts objects to this interrogatory in that it violates local
Rule thirty three three. Miss Roberts objects to this interrogatory

(04:45):
in that its prematurely seeks expert witness disclosures. Miss Roberts
incorporates by reference herein her revised Rule twenty six disclosures,
which includes her computation of damages. Twelve. Identify any healthcare
from whom you received any treatment for any physical, mental,
or emotional condition that you suffered from subsequent to any

(05:09):
alleged defamation by gland Maxwell, including A the healthcare provider's name, address,
and telephone number. B the type of consultation examination or
a treatment provided. C the dates you receive the consultation
examination or the treatment, D whether such treatment was on
an inpatient or outpatient basis. E the medical expenses to date,

(05:32):
F whether health insurance or some other person or organization
or entity has paid for the medical expenses, and g
for each such healthcare provider. Please execute the medical and
mental healthcare Records release attached Heier two as exhibit a
response to Interrogatory Number twelve. Pursu into this Court's order,

(05:53):
Miss Roberts will provide information for healthcare providers from nineteen
ninety nine through the present. Ms Roberts continues to search
for medical providers that appear in documents. Doctor Stephen Olsen,
doctor Mona Devin Shawn, doctor Chris Donahue, doctor John Harris,
doctor Wah Wah, doctor m Cell Thori Royal Oaks Medical Center,

(06:19):
doctor Carol Hayik, New York Presbyterian Hospital, Campbelltown Hospital, Sydney
West Hospital, Westmead Hospital, and as defendant requested, medical releases
have been provided for doctor Karen Kudakov, Wellington Imaging Associates
and Growing Together. Thirteen. I identify any healthcare provider from

(06:42):
whom you received any treatment for any physical, mental, or
emotional condition, including addiction to alcohol, prescription or illegal drugs,
that you suffered from prior to the alleged defamation by
Glenn Maxwell, including A the healthcare provider's name, address and
telephone number, b D the type of consultation, examination or

(07:03):
treatment provided See the dates you receive the consultation, examination
or treatment. D Whether such treatment was on an inpatient
or outpatient basis See the medical expenses to date. F
Whether health insurance or some other person or organization or
entity has paid for the medical expenses and G for

(07:25):
each such healthcare provider. Please execute the medical and mental
health records release attached. Heer to as exhibit a response
to interrogatory Number thirteen. Miss Roberts objects to this interrogatory
in that it violates local Rule thirty three dot three.
Miss Roberts objects to this request in that it's overbroad
and seeks confidential medical information of a sex abuse victim

(07:48):
and is not limited in scope to the issues in
this case. Miss Roberts objects in that it seeks information
protected by attorney client privilege, the attorney work product privilege,
joint defense, common interest privilege, and any other applicable privilege.
Miss Roberts objects to this request and that is not
limited in scope to the medical information relating to the

(08:09):
abuse she suffered from the defendant and Jeffrey Epstein. Number fourteen.
Identify any person you believe subjected you to, or with
whom you engaged in any illegal or inappropriate sexual contact,
conduct or assault prior to June nineteen ninety nine, including
the names of the individuals involved, the dates of any

(08:30):
such illegal or inappropriate sexual contact, conduct, or assault, whether
income was received by you or anyone else concerning such
an event, whether a police report was ever filed concerning
such event, and the outcome of any such case, as
well as the address and the location of any such event.
Response to Interrogatory Number fourteen. Miss Roberts objects to this

(08:54):
interrogatory in that it violates local Rule thirty three dot three.
Miss Roberts objected to this request in that it is
overbroad and seeks confidential medical information of a sex abuse victim.
Miss Roberts objects to this request and that it seeks
sexual assault information for a period of time prior to
the sexual abuse that issue in this matter, for a

(09:16):
period when she was a minor child, from the time
Miss Roberts was born until she was fifteen. Miss Roberts
objects to this request in that it sought solely to
harass and intimidate Miss Roberts, who is a victim of
sexual abuse by the defendant request for production one all
communications and documents identified in interrogatories one through fourteen above

(09:40):
response to Requests number one. Miss Roberts objects to this
request and that defendants interrogatories violate local Rule thirty three three.
Miss Roberts objects in that it seeks information protected by
the attorney client privilege, the attorney work product privilege, joint defense,
common interest privilege, the public interest privilege, and any other

(10:00):
applicable privilege. Miss Roberts objects to this request on the
grounds that it is overly broad and unduly burdensome, incorporating
the interrogatories that total fifty nine subparts, and calls for
the production of documents that are irrelevant to this action
and not reasonably calculated to lead to the discovery of
admissible evidence. Miss Roberts objects to this request in that

(10:23):
it seeks to invade the privacy rights of a sex
abuse victim and is meant for the improper purpose of
harassing and intimidating this victim. Subject to and without waiving
the above objections, Miss Roberts is withholding production of documents
that are privileged pursuing to the attorney client privilege, the
work product privilege, and the public interest privilege. Miss Roberts

(10:45):
is also withholding electronic renditions of photographs that depict the
faces of her minor children, including school portraits and other
photographs taken that reveal the faces of her minor children
Subjection two. And without waving the above objection. Ms Roberts
has already produced documents baits labeled Roberts zero zero zero
zero zero one and Roberts zero zero five to three

(11:09):
five three, and will produce non privileged documents responsive to
this request limited to documents that do not depict images
of her minor children as described Supra, and will continue
to supplement her production. All right, folks, we're gonna wrap
up right here, and in the next episode discussing the topic,
we'll pick up where we left off. All of the

(11:29):
information that goes with this episode can be found in
the description box. What's up, everyone, and welcome back to
the Epstein Chronicles. In this episode, we're gonna pick up
where we left off with the Virginia Roberts second supplemental
response to the discovery requests and the objections by Glenn Maxwell.

(11:50):
Number three All documents from any law enforcement agency, whether local, state,
or federal, whether in the United States or elsewhere, which
concern or relate to you in any way. These documents
should include, without limitation, any witness statements, including statements made
by you. Response to requests Number three, Miss Roberts objects

(12:13):
to this request in that it seeks information that is
protected by the attorney work client privilege, the work product
public interest privilege, and other applicable privileges. Miss Roberts objects
to this request in that it's not limited in the
time period subject to and without waiving the above objections.
Miss Roberts has already produced documents bates labeled Roberts zero

(12:36):
zero zero zero one to Roberts zero zero five to
three five three, and will produce non privileged documents responsive
to this request and will continue to supplement her production.
Miss Roberts is withholding documents that concern or relate to
any currently ongoing investigation by any law enforcement agency under
the public interest privilege and other applicable privileges, or all

(13:00):
documents reflecting any letter of engagement, any fee agreement, or
any other type of writing reflecting an engagement of any
attorney identified in response to interrogatory number three. Response to
Request number four, Miss Roberts objects to this request in
that it seeks information that is protected by the attorney
client work product, joint defense, and other applicable privileges. Miss

(13:25):
Roberts is withholding documents based on this objection. Specifically, Miss
Roberts is withholding documents reflecting the engagements between herself and
her attorneys she has engaged in relation to the above
captioned action and other actions, as those documents involve privileged communications.
Number five all documents relating to any communication occurring from

(13:48):
nineteen ninety eight, to the present with any of the
following individuals, or with their attorneys, agents, or representatives. A.
Jeffrey Epstein, B. Glaine Maxwell, any witness disclosed in Plaintiff
Rule twenty six disclosures, D any witness identified by you.
In response to Interrogatory Number eight and number fourteen E.

(14:11):
Sky Roberts, f Lynn Roberts, G. Kimberley Roberts, H. Daniel Lnu,
half brother of plaintiff I, Carol Roberts, Quss Jay, Philip Guderian,
K Anthony Valderis, L Anthony Figueroa, and m Ron Eppinger.
Response to Requests number five. Miss Roberts objection to this

(14:34):
request on the grounds that is overly broad and unduly
burdens them, particularly as it seeks documents relating to over
sixty individuals and calls for the production of documents that
are irrelevant to this action and not reasonably calculated to
lead to the discovery of admissible evidence. Miss Roberts objects
because compliance with this request is on duly burdensome. Miss

(14:57):
Roberts objects to this request and that doc documents responsive
to this request or within the possession, custody and control
of the defendant and Jeffrey Epstein, with whom she claims
the joint defense privilege, and defendant has refused to produce
responsive documents to Miss roberts request seeking communications between the
defendant and Miss Roberts, and between Jeffrey Epstein and Miss Roberts.

(15:22):
Miss Roberts objects to this request to the extent it
seeks documents protected by our attorney client, work product, joint defense,
public interest, or any other applicable privilege. Miss Roberts objects
to this request in that it is sought solely to
harass and intimidate Miss Roberts and invade her privacy by
seeking her private communication with her various family members, including aunts, uncles,

(15:47):
and parents and siblings. Subject to and without having the
above objections, Miss Roberts is withholding production of documents that
are privileged pursuant to the attorney client privilege, the work
product privilege, and the public interest privilege. Miss Roberts is
also withholding electronic renditions of photographs that depict the faces

(16:08):
of her minor children, including school portraits and other photographs
taking that reveal of the faces of her minor children,
subject to and without waiving the above objections, Miss Roberts
has already produced Bates documents and will produce non privileged
documents responsive to this request, limited to the documents that

(16:28):
do not depict images of her minor children as described Supra,
and will continue to supplement this production. Number six all
photographs or video containing any image of you and the
following individuals. To the extent you have such photographs and
videos in their original native format, please produce them in

(16:48):
that format, not a paper copy. A. Glenn Maxwell, B.
Alan Dershowitz, C. Jeffrey Epstein, D Andrew Albert Christian Edwards,
the Duke of York aka Prince Andrew aka the Joe
Exotic of the Windsor family. You mean e. Ron Eppinger, F,

(17:08):
Bill Clinton, G. Stephen Hawking, H. Al Gore I, any
of the individuals identified by you in response to Interrogatory
number eight and number fourteen. Response to Request number six,
Miss Roberts objects to this request and that documents responsive
to this request are within the possession, custody and control

(17:29):
of the defendant and Jeffrey Epstein, with whom she claims
the joint defense privilege, and defendant has refused to produce
responsive documents to Miss Roberts's requests seeking communications between the
defendant and Miss Roberts, and between Jeffrey Epstein and Miss
Roberts Subject two, and without waiving the above objections. Miss

(17:50):
Roberts has already produced Bates documents and will produce non
privileged documents responsive to this request and will continue to
supplement her production. Miss Roberts does not have original native
format as requested, so she is producing the paper copies
she has in her possession, custody and control. Number seven.

(18:12):
All photographs in video of view in any of Jeffrey
Epstein's properties, including but not limited to, his home in
Palm Beach, Florida, his home in New York City, his
ranch in Santa Fe, and Little Saint James Island in
the US Virgin Islands. To the extent you have such
photographs and video in their original native format, please produce

(18:33):
them in that format, not a paper copy. Response to
Request number seven, Miss Roberts objects to this request and
that the documents responsive to this request are within the possession,
custody and control of the defendant and Jeffrey Epstein, with
whom she claims a joint defense privilege, and defendant has
refused to produce responsive documents to Miss Roberts and has

(18:56):
ignored the request seeking communications between the defendant and Miss
Roberts and between Jeffrey Epstein and Miss Roberts, subject to
and without waiving the above objections. Miss Roberts has already
produced documents and will produce documents responsive to this request
and will continue to supplement her production. Miss Roberts does

(19:17):
not have original native format as requested, so she is
producing the paper copies she has in her possession, custody
and control. The defendant has documents responsive to this request
that she should produce number eight all photographs of video
of you in any of Miss Maxwell's properties, including her
home in London, England, and her home in New York City.

(19:40):
To the extent you have such photographs or video in
their original native format, please produce them in that format,
not a paper copy. Response to Request number eight, Miss
Roberts objects to this request in that the documents responsive
to this request are within the possession, custody and control
of the defendant and j. Geffrey Epstein, with whom she

(20:01):
claims the joint defense privilege, and defendant has refused to
produce responsive documents to Miss Roberts's request seeking communications between
the defendant and Miss Roberts and between Jeffrey Epstein and
Miss Roberts, subject to and without waiving the above objections.
Miss Roberts has already produced documents and will produce non

(20:22):
privileged documents responsive to this request and will continue to
supplement her production. Miss Roberts does not have original native
format as requested, so she is producing the paper copy
she has in her possession, custody and control. The defendant
has documents responsive to this request that she should produce

(20:43):
number nine any documents reflecting rental agreements or purchase agreements
for the residential addresses identified by you in response to
interrogatory number one. Response to Request number nine, Miss Roberts
objections to this request on the grounds that it is
overly broad and unduly burdensome and calls for the production

(21:04):
of documents that is irrelevant to this action and not
reasonably calculated to lead to the discovery of admissible evidence.
Miss Roberts objects to this request and that it seeks
confidential financial information that is irrelevant to this action. Miss
Roberts objects to this request to the extent it seeks
documents protected by the attorney client work product joint defense,

(21:26):
public interest, or any other applicable privilege. Miss Roberts objects
to this request and that the information regarding rental agreements
for the apartments that the defendant and Jeffrey Epstein rented
for are in the Defendant's possession, control, or custody. Subject
to and without waiving the above objections. Miss Roberts has
already produced documents and will produce non privileged documents responsive

(21:51):
to this request, and will continue to supplement its production.
Number ten all documents relating to your employment and or
association with La mar A Lago Club located in Palm Beach, Florida,
including any application for employment. Response to Request number ten,
Miss Roberts objects to this request to the extent it

(22:12):
seeks documents protected by the attorney, client, work product, joint defense,
public interest, or any other applicable privilege, subject to and
without waiving the above objections. Miss Roberts has already produced
documents and will produce non privileged documents responsive to this request,
and will continue to supplement this production. All right, folks,

(22:32):
We're going to wrap up this episode right here, and
in the next episode we'll pick up where we left off.
All of the information that goes with this episode can
be found in the description box.