Speaker 1: What's up, everyone, and welcome back to the Epstein Chronicles.
Speaker 1: In this episode, we're going to start taking a look
Speaker 1: at the Virginia Roberts motion to compel the production of
Speaker 1: documents subject to improper objections Case number fifteen Dash CV
Speaker 1: DASH zero seven four three to three Dash RWs Virginia
Speaker 1: Roberts Versal A. Maxwell. Plaintiff Virginia Roberts, buy and through
Speaker 1: the undersigned Council, respectfully submits this motion to compel production
Speaker 1: of documents in response to request numbers one through thirty nine,
Speaker 1: and to compel documents subject to improper objections, including refusals
Speaker 1: to produce documents from highly relevant time periods. For the
Speaker 1: reason set forth below, this Court should grant Plaintiff's motion
Speaker 1: in its entirety. One the preliminary statement. Plaintiff first served
Speaker 1: a request for production of documents on defendant on October
Speaker 1: twenty seven, even twenty fifteen, Now almost four months later,
Speaker 1: and even after this Court denied Defendant's attempts to stay
Speaker 1: discovery and directed a response, Defendant is still refusing to
Speaker 1: produce highly relevant documents. Defendant is attempting to grant herself
Speaker 1: a de facto stay of discovery. Without court approval by
Speaker 1: refusing to produce documents or generally comply with the party's
Speaker 1: clear and unequivocal discovery obligations. Indeed, in response to thirty
Speaker 1: eight requests for production, the defendant has chosen to produce
Speaker 1: two emails. This represents a willful disregard of her discovery obligations,
Speaker 1: something this Court should not condone. Although not unlimited relevance
Speaker 1: for purposes of discovery is an extremely broad concept. Ottison
Speaker 1: versus SMBC Leasing in Finance Incorporated. Sweet Jay, twenty fifteen,
Speaker 1: w L four five nine seven five four to two
Speaker 1: at two SDN Y, July twenty fifteen, Ranting motion to
Speaker 1: compel Stintson versus City of New York's Sweet j twenty fifteen,
Speaker 1: w L four six one zero four two two SDN Y,
Speaker 1: July twenty three, twenty fifteen, Granting in part motion to
Speaker 1: compel production in the second Circuit Courts of dismissed actions
Speaker 1: where a party has demonstrated wilful disregard for its discovery obligations.
Speaker 1: Edwards versus American Airlines Incorporated. Number ninety five CIV Dot
Speaker 1: five three five six sas nineteen ninety six, w L
Speaker 1: four three two four seven two at three SDN Y,
Speaker 1: August first, nineteen ninety six. See also International Mining Company
Speaker 1: Incorporated versus Allen In Company Sweet j five sixty seven
Speaker 1: f Dot supp seven seven seven SDN Y, nineteen eighty three.
Speaker 1: Failure to produce documents and supply adequate answers to interrogatories
Speaker 1: without justifiable excuse warranted the dismissal of the complaint. The
Speaker 1: blatant nature of the defendant's failure to participate in discovery
Speaker 1: is akin to the conduct for which the Second Circuit
Speaker 1: has awarded sanctions. This case turns on whether or not
Speaker 1: Maxwell to fay Miss Roberts when she called Miss roberts
Speaker 1: account of her sexual abuse obvious lies. Miss Roberts intends
Speaker 1: to establish that Maxwell's defamatory statement was untrue and that
Speaker 1: Miss Roberts was telling the truth. To prove the truth
Speaker 1: of her sexual abuse, Miss Roberts seeks discovery of documents
Speaker 1: evidencing her sexual abuse and sexual trafficking by Maxwell and
Speaker 1: her associates, including convicted sex offender Jeffrey Epstein. Therefore, documents
Speaker 1: evidencing Miss roberts encounters with Maxwell, and documents evidencing Maxwell's
Speaker 1: communications with her co conspirators are plainly relevant and discoverable.
Speaker 1: For example, requests six seeks documents relating to Maxwell's communications
Speaker 1: with Sarah Kellen at a prior deposition, Sarah Kellen invoked
Speaker 1: her Fifth Amendment privilege when asked question, would you agree
Speaker 1: with me that Ghlainne Maxwell provides underage girls to mister
Speaker 1: Epstein for sex? Answer, upon the instruction of my lawyer,
Speaker 1: I must invoke my Fifth Amendment privilege. Question take a
Speaker 1: look at what we marked as Exhibit ten? Do you
Speaker 1: recognize the two people in that photograph? Answer on the
Speaker 1: instruction of my lawyer, I must invoke my Fifth Amendment privilege.
Speaker 1: Question would you agree with me that glaign Maxwell on
Speaker 1: the right and Jeffrey Epstein's on the left? Answer on
Speaker 1: the instruction of my lawyer, I must invoke my Fifth
Speaker 1: Amendment privilege. Question do you recognize the young lady shown
Speaker 1: in Exhibit eleven? Answer on the instruction of my lawyer,
Speaker 1: I must invoke my Fifth Amendment privilege. Question do you
Speaker 1: agree with me that the young girl shown in Exhibit
Speaker 1: eleven was recruited by Glaigne Maxwell for sexual activity with
Speaker 1: Jeffrey Epstein. Answer on the instruction of my lawyer, I
Speaker 1: must invoke my Fifth Amendment privilege see McCauley declaration at
Speaker 1: Exhibit one. Clearly, communications Maxwell had with Sarah Kellen are
Speaker 1: highly relevant to establishing Maxwell's involvement in trafficking underage girls.
Speaker 1: Yet Maxwell is refusing to produce any communications with Sarah Kellen. Moreover,
Speaker 1: Defendant Maxwell has admitted that nonprivileged relevant documents exist, she
Speaker 1: is simply refusing to produce them. See the declaration of
Speaker 1: Sigared McCauley. McCauley declaration at Exhibit two. Defendant Maxwell's response
Speaker 1: to plaintiff's first requests for production Request numbers one, three, six, seven, eight, nine, ten, eleven, fifteen, seventeen, nineteen,
Speaker 1: twenty one, twenty two, twenty three, twenty four, thirty two,
Speaker 1: thirty three, thirty four, and thirty seven. Indeed, it is
Speaker 1: undisputed that Maxwell spent many years traveling with Miss Roberts,
Speaker 1: and for years thereafter, Maxwell continued her association with convicted
Speaker 1: sex offender Jeffrey Epstein. Miss Roberts is entire to those
Speaker 1: documents in discovery because they go directly to the claim
Speaker 1: at the issue in this litigation. Therefore, this court should
Speaker 1: compel her to produce them. The legal argument Under federal
Speaker 1: Rule of Civil Procedure thirty four A, a party may
Speaker 1: request that another party produce documents in its possession as
Speaker 1: long as the documents are within the scope of fed
Speaker 1: R siv p. Twenty six B, which allows for broad
Speaker 1: discovery regarding any non privileged matter that is relevant to
Speaker 1: any party's claim or defense. Information within the scope of
Speaker 1: discovery need not be admissible in evidence to be discoverable.
Speaker 1: Relevance is still to be construed broadly to encompass any
Speaker 1: matter that bearizon or that reasonably could lead to other
Speaker 1: matters that could bear on any party's claim or defense.
Speaker 1: State Farm Mutual Auto Insurance Company versus FDA Number fourteen
Speaker 1: SIV nine seventy nine two WHP JCF twenty fifteen w
Speaker 1: L seven eight seven one zero three seven at two
Speaker 1: SDN Y, December third, twenty fifteen, granting motion to compel.
Speaker 1: If the opposing party objects to producing the documents, the
Speaker 1: party seeking production can file a motion to compel with
Speaker 1: the court pursuant of fed R sieve p. Thirty seven
Speaker 1: Against this backdrop of broad discovery rights. Maxwell has refused
Speaker 1: to produce responsive documents B. Maxwell's general objections fell the
Speaker 1: centerpiece of Maxwell's general objections is her disingenuous limitation of
Speaker 1: her discovery responses to a short window of time that
Speaker 1: she has unilaterally selected. Maxwell wrongfully attempts to limit discovery
Speaker 1: to the month of December thirtieth, twenty fourteen, through January
Speaker 1: thirty first, twenty fifteen, when her defamatory statement was issued,
Speaker 1: and nineteen ninety nine through two thousand and two. Maxwell's
Speaker 1: time period limitation clearly violates both the letter and spirit
Speaker 1: of rule time twenty six. For example, a communication by
Speaker 1: Maxwell's press agent regarding the plaintiff is just as relevant
Speaker 1: if it was made on February first, twenty fifteen as
Speaker 1: the one that was made on January third, twenty fifteen,
Speaker 1: and is clearly discoverable. These communications with her press agent
Speaker 1: are key documents in this case, and the sole claim
Speaker 1: concerns Miss Maxwell defaming Miss Roberts in the press. Yet
Speaker 1: Maxwell has arbitrarily refused to produce highly relevant discovery. The
Speaker 1: abuse that issue in this case is alleged to have
Speaker 1: started in or around nineteen ninety nine, and there are
Speaker 1: irrelevant documents in communication from that point to the present,
Speaker 1: and that Maxwell continued to associate with convicted pedophile Jeffrey
Speaker 1: Epstein up until at least twenty fifteen, as evidenced by
Speaker 1: her privileged log see McCaulay declaration at Exhibit three. Maxwell's
Speaker 1: privileged log. Accordingly, plaintiff define the relevant period for her
Speaker 1: purposes of her request for production as nineteen ninety nine
Speaker 1: through press. While that may seem like a substantial period
Speaker 1: of time, all of the publicly available documents demonstrate that
Speaker 1: the whole period is highly relevant to the sexual abuse allegations.
Speaker 1: For example, the flight log demonstrates that Maxwell was flying
Speaker 1: on Jeffrey Epstein's plans over three hundred and sixty times
Speaker 1: from nineteen ninety nine to two thousand and five. In addition,
Speaker 1: Maxwell flew with plaintiff when she was a minor child
Speaker 1: in two thousand on Jeffrey Epstein's planes. The flight logs
Speaker 1: reveal that Maxwell continued to actively travel with Jeffrey Epstein
Speaker 1: and the other unidentified female passengers through at least as
Speaker 1: late as September fifth, two thousand and five, seem Acauley
Speaker 1: declaration at Exhibit four. Moreover, there is critical activity relevant
Speaker 1: to the abuse allegations happening in the mid two thousands,
Speaker 1: as evidenced by the Palm Beach police report that identified
Speaker 1: over thirty underage girls who were being victimized during that
Speaker 1: time period. In addition, house staff identifies Maxwell as the
Speaker 1: person in charge during this time period Seemocauleey declaration at
Speaker 1: Exhibit five. Alfredo Rodriguez deposition transcript at twenty four and
Speaker 1: twenty five. The years of the mid late two thousands
Speaker 1: are so highly relevant because that is during the time
Speaker 1: when convicted sex offender Jeffrey Epstein entered his plea with
Speaker 1: the government. Law enforcement conducted a trash pull from Jeffrey
Speaker 1: Epstein's residence in Florida and uncovered his house message pads.
Speaker 1: The message pads reveal that in two thousand and four,
Speaker 1: Maxwell was coordinating training with underage girls, as indicated by
Speaker 1: the redactions in the message pads Seemacaulley declaration at Exhibit six.
Speaker 1: Maxwell was also organizing massages for Epstein in two thousand
Speaker 1: and four with underage girls and indicating which girls she
Speaker 1: had lined up on given days Seemacauley declaration at Exhibit six.
Speaker 1: Plaintiff here received a victim notification letter on September ninth,
Speaker 1: two thousand and eight. Seamacaulley declaration at Exhibit seven. In
Speaker 1: two thousand and nine, an attorney sought Maxwell's deposition in
Speaker 1: connection with various sexual abuse allegations, and Maxwell dodged the deposition,
Speaker 1: claiming that her mother was ill and that she would
Speaker 1: be traveling outside the country with no plans of returning.
Speaker 1: Despite this claim to avoid her deposition, she was then
Speaker 1: photographed thereafter at Chelsea Clinton's wedding in Rhinebeck, New York.
Speaker 1: Oh well, isn't that convenient? Cemacaulley declaration at Composite eight.
Speaker 1: Maxwell deposition notice, subpoena and cancelation payment notice and January thirteenth,
Speaker 1: twenty fifteen, daily mail article with photograph. In twenty eleven,
Speaker 1: Maxwell started issuing press statements through her agent, Ross Gal.
Speaker 1: The offending defamatory statement was issued on January third, twenty fifteen.
Speaker 1: As demonstrated by the timeline discussed above, any documents that
Speaker 1: Maxwell has from the period of nineteen ninety nine to
Speaker 1: the present are highly relevant. Miss Roberts respectfully requests that
Speaker 1: this Court direct Maxwell to produce all responsive documents for
Speaker 1: the time period from nineteen ninety nine to the present.
Speaker 1: Defendant Maxwell has also asserted fundamentally improper general objections which
Speaker 1: should be overruled. American Rock Salt Company LLC versus Norfolk
Speaker 1: Southern Company, two twenty eight FRD four twenty six four
Speaker 1: thirty two WDNY two thousand four. Generalized objections that discovery
Speaker 1: requests are vague, overly broad, or unduly burdensome are not
Speaker 1: acceptable and will be overruled. Maxwell's general objection to producing
Speaker 1: material that implicates privacy interests is equally misplaced. Maxwell does
Speaker 1: not have a privacy interest in the illegal sexual abuse
Speaker 1: in trafficking of Miss Roberts and the other miners, nor
Speaker 1: does she have a privacy interest in the communications with
Speaker 1: her co conspirators, including convicted sex offender Jeffrey Epstein and others.
Speaker 1: Sezornvers is How two seventy six a D two D
Speaker 1: fifty one fifty seven seven to one six NYS two
Speaker 1: D one twenty eight one thirty three two thousand finding
Speaker 1: no legitimate privacy interests in illegal activity. Unsurprisingly, Maxwell cites
Speaker 1: no authority that would shield the production of those documents.
Speaker 1: These documents are responsive and relevant. The only proper objection
Speaker 1: Maxwell can make is an assertion of her Fifth Amendment
Speaker 1: privilege failing that assertion, she must produce them. Furthermore, Maxwell
Speaker 1: claims that prior to this litigation, she has long had
Speaker 1: a practice of deleting emails after they have been read. First,
Speaker 1: Miss Roberts is entitled to a forensic examination of Miss
Speaker 1: Maxwell's personal computers and devices to recover deleted emails and
Speaker 1: to discovery when and if Maxwell has performed a swipe
Speaker 1: of her computer devices to permanently destroy deleted emails while
Speaker 1: hanging out with Hillary Clinton, she probably learned from the
Speaker 1: master huh second. In hemotion to DS, Maxwell claims that
Speaker 1: both twenty eleven and twenty fifteen she anticipated litigation against tabloids. Specifically,
Speaker 1: she stated that in twenty eleven litigation was forthcoming, and
Speaker 1: in twenty fifteen she made her press release pertinent to
Speaker 1: anticipated good faith litigation. When litigation is anticipated, it is
Speaker 1: incumbent on the party to preserve documents see Zubleocai versus
Speaker 1: ubs Warburg LLC two two zero FRD two one two
Speaker 1: two eighteen, SDN Y two thousand and three. Once a
Speaker 1: party reasonably anticipates litigation, it must ensure the preservation of
Speaker 1: relevant documents. Additionally, if Maxwell purposefully destroyed documents, in twenty fifteen.
Speaker 1: This court can instruct the jury to make an adverse
Speaker 1: inference against Maxwell or enter a default judgment in favor
Speaker 1: of Miss Roberts see Rule thirty seven E two b
Speaker 1: C Federal Rule SIVP. If electronically stored information that should
Speaker 1: have been preserved in the anticipation or a conduct of
Speaker 1: litigation is lost because a party failed to take reasonable
Speaker 1: steps to preserve it, and it cannot be restored or
Speaker 1: replaced through additional discovery, the court, upon finding that the
Speaker 1: party acted with the intent to deprive another party of
Speaker 1: the information use in the litigation, may instruct the jury
Speaker 1: that it may or must presume the information was unfavorable
Speaker 1: to the party, or dismiss the action or enter of
Speaker 1: the fault judgment. Similarly, Maxwell was served with a subpoena
Speaker 1: Deuces Techem on September twenty first, two thousand and nine,
Speaker 1: seeking her testimony in relation to Epstein's underage sex rank
Speaker 1: Seemacaulay declaration at Composite Exhibit eight, two thousand and nine
Speaker 1: subpoena issued to Maxwell. Maxwell avoided that deposition by falsely
Speaker 1: claiming to be out of the country. She was instead
Speaker 1: photographed at Chelsea Clinton's New York wedding see composite Exhibit eight.
Speaker 1: Pursuing to that subpoena, Maxwell was placed on notice that
Speaker 1: her documents were relevant depending litigation. All of these events
Speaker 1: triggering her duty to preserve documents center on Maxwell's role
Speaker 1: in Epstein's sex crimes. Therefore, all of the documents she
Speaker 1: had a duty to preserve are relevant to this litigation defended.
Speaker 1: Maxwell must produce these documents or explain to the court
Speaker 1: when and why they were destroyed. All right, we're gonna
Speaker 1: wrap up right there, and in the next episode dealing
Speaker 1: with this topic, we'll pick up where we left off.
Speaker 1: All of the information that goes with this episode can
Speaker 1: be found in the description box. What's up everyone, and
Speaker 1: welcome back to the Epstein Chronicles. In this episode, we're
Speaker 1: diving right back in to Virginia Roberts and her motion
Speaker 1: to have Maxwell produced documents subject to improper objection. Maxwell's
Speaker 1: specific objections fail Part C one request number one all
Speaker 1: documents relating to communications with Jeffrey Epstein from nineteen ninety
Speaker 1: nine to present a Maxwell's response. Maxwell objects to this
Speaker 1: request on the grounds that it is overly broad and
Speaker 1: unduly burdensome. And calls for the production of documents that
Speaker 1: are irrelevant to this action and not reasonably calculated to
Speaker 1: lead to the discovery of admissible evidence. Maxwell further objects
Speaker 1: to this request to the extent it seeks documents or
Speaker 1: information protected by the attorney client privilege, the work product doctrine,
Speaker 1: the common interest privilege, or any other applicable privilege subject
Speaker 1: to and without waiving the above objections, Maxwell is withholding
Speaker 1: documents outside of the relevant periods described in paragraph fifteen Supra,
Speaker 1: and is withholding production of documents that are privileged pursuant
Speaker 1: to a Common Interest Agreement B. Maxwell's objections fail. As
Speaker 1: the request seeks relevant discovery. Maxwell must produce documents for
Speaker 1: the entire relevant period as discussed above, Communications with convicted
Speaker 1: sex offender Jeffrey Epstein, for whom defendant Maxwell is alleged
Speaker 1: to have assisted him with actual trafficking activities, are of
Speaker 1: the highest relevance in this case and must be produced. Additionally,
Speaker 1: Maxwell has asserted an improper privilege with regard to these documents,
Speaker 1: which is addressed fully in Plaintiff's Motion to compel Foreign
Speaker 1: Proper Claims of Privilege two Request number three. All documents
Speaker 1: relating to communications with Andrew Albert Christian Edward, Duke of
Speaker 1: York aka Prince Andrew from nineteen ninety nine to the present.
Speaker 1: A Maxwell's response. Maxwell objects to this request on the
Speaker 1: grounds that it is overly broad and calls for the
Speaker 1: production of documents that are irrelevant to this action and
Speaker 1: not reasonably calculated to lead to the discovery of admissible evidence.
Speaker 1: Maxwell further objects to this request to the extent it
Speaker 1: seeks documents or information protected by the attorney client privilege,
Speaker 1: the work product doctrine, or any other applicable privilege. Maxwell
Speaker 1: also objects to this request to the extent it implicates
Speaker 1: her write to privacy, Gateway Logistics, and in C Corporated
Speaker 1: versus s May three O two p Dot three D
Speaker 1: two thirty five Colorado twenty thirteen fed Are Evidence five
Speaker 1: oh one, Subject two and without waiving the above objections,
Speaker 1: Maxwell will produce non privileged documents responsive to this request,
Speaker 1: limited to the relevant periods described in paragraph fifteen Supra
Speaker 1: and with private phone numbers and relevant information redacted. Maxwell
Speaker 1: is withholding production of documents outside of such relevant periods.
Speaker 1: B Maxwell's objections fail, as the request seeks relevant discovery.
Speaker 1: Defendant Maxwell's communications with Prince Andrew for the entire relevant
Speaker 1: period are relevant to this litigation. Maxwell is alleged to
Speaker 1: have traffic Miss Roberts to Prince Andrew when Miss Roberts
Speaker 1: was a minor. Indeed, there is photographic evidence of Prince
Speaker 1: Andrew with his arm around Virginia's waist standing next to
Speaker 1: Maxwell in Maxwell's London residence when Virginia was a minor child.
Speaker 1: In the other email Defendant did produce in response to
Speaker 1: the request for production, Maxwell instructs Prince Andrew to call
Speaker 1: me after Prince Andrew says he needs to speak about Virginia.
Speaker 1: Ce M. Macauley declaration at Exhibit nine. Miss Roberts is
Speaker 1: entitled to all the communications between Maxwell and Prince Andrew,
Speaker 1: not only to show the communications between them regarding her trafficking,
Speaker 1: but also possible communications between them that would establish Maxwell
Speaker 1: furnishing him with other females or discussing other individuals who
Speaker 1: may have been involved with this activity. Three Requests number
Speaker 1: six all documents relating to communication with any of the
Speaker 1: following individuals from nineteen ninety nine to the present. Emmy Taylor,
Speaker 1: Sarah Kellen, Eva Dubin, Glenn Dubin, Jean Luc Brunel, and
Speaker 1: Nadia Martinkova. Maxwell's response, Maxwell objects to this request on
Speaker 1: the grounds that it is overly broad, unduly burdensome, and
Speaker 1: or propounded for the improper purpose of annoying or harassing
Speaker 1: Max Maxwell. Maxwell further objects to this request on the
Speaker 1: grounds that it calls for the production of documents that
Speaker 1: are irrelevant to this action and not reasonably calculated to
Speaker 1: lead to the discovery of admissible evidence. Subject to and
Speaker 1: without waiving the above objections, Maxwell is withholding production of
Speaker 1: documents relating to communications with Nadia Marsenkova, Sarah Kellen, and
Speaker 1: any of A. Dubin that are outside the relevant periods
Speaker 1: described in paragraph fifteen Supra. Maxwell has been unable to
Speaker 1: locate any such documents relating to Miss marson Cova, Miss Kellen,
Speaker 1: Miss Dubin within the relevant periods. Maxwell has also been
Speaker 1: unable to locate any such documents responsive to this request
Speaker 1: relating to Glenn Dubin, Jean Luc Brunel, or Emmy Taylor
Speaker 1: for any time period b Maxwell's objections fail, as the
Speaker 1: request seeks relevant discovery. Miss Kellen was previously deposed regarding
Speaker 1: Jeffrey Epstein's under age sex ring. When asked about Maxwell's
Speaker 1: involvement in the sex trafficking, miss Kellen asserted or Fifth
Speaker 1: Amendment privilege and refused to answer. Miss Kellen's assertion implicates
Speaker 1: Maxwell in sex trafficking activity. Question would you agree with
Speaker 1: me that Maxwell provides underage girls for mister Epstein for
Speaker 1: sex Answer, upon the instruction of my lawyer, I must
Speaker 1: invoke my Fifth Amendment privilege Seemacauley declaration at Exhibit one,
Speaker 1: March twenty fourth, twenty ten. Deposition transcript of Sarah Kellen
Speaker 1: at one hundred and one oh three. Maxwell's communications with
Speaker 1: Miss Kellen at any time during the original relevant period
Speaker 1: are relevant to the sexual abuse suffered by Miss Roberts
Speaker 1: and others at the hands of Maxwell and should not
Speaker 1: be withheld. Moreover, flight logs demonstrate that Sarah Kellen and
Speaker 1: Maxwell flew together multiple times, including with Miss Roberts Seemacauley
Speaker 1: declaration at Exhibit four. Similarly, Nadia Marsenkova was a co
Speaker 1: conspirator of Maxwell and Epstein and communicated with them frequently,
Speaker 1: as evidence by the message pads law enforcement retrieved from
Speaker 1: Epstein's residence see McAuley declaration at Exhibit six. Nadia Marsenkova
Speaker 1: also traveled on Jeffrey Epstein's planes with Maxwell see McCauley
Speaker 1: declaration at exhibit four flight logs. Similarly, Emmy Taylor was
Speaker 1: Maxwell's assistant during this timeframe and also traveled on Jeffrey
Speaker 1: Epstein's planes with Miss Roberts see McAuley declaration at exhibit four.
Speaker 1: These communications are relevant for the entire original relevant period
Speaker 1: and Maxwell must produce them. Regarding Glenn and Eva Dubin,
Speaker 1: flight logs demonstrate that they also traveled on Epstein's planes
Speaker 1: with Maxwell. Maxwell has acknowledged having communications with Eva Dubin,
Speaker 1: but she is refusing to turn them over. Eva and
Speaker 1: Glenn regularly placed calls to Jeffrey Epstein and Maxwell, as
Speaker 1: evidence by police report trash pulls of message pads seamccauley
Speaker 1: declaration at exhibit six. Maxwell's communications with Glenn and Eva
Speaker 1: Dubin are relevant for the entire original relevant period and
Speaker 1: should all be produced. Four Request number seven all videotapes,
Speaker 1: audio tapes, photographs, any other rent or electronic media relating
Speaker 1: to females under the age of eighteen from the time
Speaker 1: period of nineteen ninety nine to the present Maxwell's response.
Speaker 1: Maxwell objects to this request on the grounds that it
Speaker 1: is overly broad, unduly burdensome, and propounded for the improper
Speaker 1: purpose of annoying or harassing Maxwell. Maxwell further objects to
Speaker 1: this request on the grounds that it calls for the
Speaker 1: production of documents that are irrelevant to this action and
Speaker 1: not reasonably calculated to lead to the discovery of admissible evidence.
Speaker 1: Subject to and without waiving the above objections, Maxwell has
Speaker 1: been unable to locate any documents responsive to this request
Speaker 1: which relate or pertain to Plaintiff or any of the
Speaker 1: witnesses identified Biplaintiff in her Rule twenty six disclosures. Maxwell
Speaker 1: is withholding production of other documents responsive to this request,
Speaker 1: including things like mainstream newspapers, magazines, videos, DVDs, or other media,
Speaker 1: or family photographs which contained depictions of female children, including
Speaker 1: Maxwell herself as a child. B Maxwell's objections fail, as
Speaker 1: the request seeks relevant discovery. To clarify, Miss Roberts is
Speaker 1: not seeking the depictions of children under the age of
Speaker 1: eighteen that may include Maxwell as a child or Maxwell's
Speaker 1: relatives as children, nor is Miss Roberts seeking mainstream images
Speaker 1: that are legally available, such as in mainstream newspapers, magazines, videos,
Speaker 1: or DVDs. Instead, Miss Roberts is seeking the depictions of
Speaker 1: underage girls possessed by Maxwell. For example, Alfredo Rodriguez, a
Speaker 1: former household manager for Epstein, testified that Maxwell kept images
Speaker 1: of naked girls on her personal computer whose identities are
Speaker 1: unknown to Miss Roberts. Question, did they appear to be
Speaker 1: doing anything sexual? Answer yes, ma'am. Question And in these
Speaker 1: instances were these girls doing sexual things with other girls?
Speaker 1: Answer yes, ma'am. Question, and I'm still talking about the
Speaker 1: pictures on Maxwell's computer. Answer yes, ma'am. Seemalcauley Declaration at
Speaker 1: Exhibit five, Alfredo Rodriguez, August seventh, two thousand and nine. Accordingly,
Speaker 1: Maxwell's depictions of females under the age of eighteen goes
Speaker 1: to Miss Roberts's claims of sexual abuse and should be
Speaker 1: produced for the entire original relevant period. These pictures would
Speaker 1: reveal which underage girls Maxwell was interacting with and photographing
Speaker 1: or videotaping, which is highly relevant to this case. Importantly,
Speaker 1: this request is not limited to depictions of Miss Roberts
Speaker 1: or the individuals in Miss Roberts Rule twenty six disclosures,
Speaker 1: as Maxwell tries to assert in her objection request numbers
Speaker 1: eight and thirty three, all documents relating to your travel
Speaker 1: from the period of nineteen ninety nine to present, including
Speaker 1: but not limited to, any travel on Jeffrey Epstein's planes,
Speaker 1: commercial flights, helicopters, passport records, records indicating passengers traveling with you,
Speaker 1: hotel records, and credit card receipts. Maxwell's response, Maxwell objects
Speaker 1: to this request on the grounds that it is overly broad,
Speaker 1: unduly burdensome, and or propounded for the improper purpose of
Speaker 1: annoying or harassing Maxwell. Maxwell further objects to this request
Speaker 1: on the grounds that it calls for the production of
Speaker 1: documents that are irrelevant to this action and not reasonably
Speaker 1: calculated to lead to the discovery of admissible evidence. Maxwell
Speaker 1: also objects to this request to the extent that implicates
Speaker 1: our right to privacy. Gateway Logistics Incorporated. Versus s May
Speaker 1: three oh two p Dot three D two thirty five,
Speaker 1: Colorado twenty thirteen, Evidence five oh one, Subject two, and
Speaker 1: without waiving the above objections, Maxwell is withholding production of
Speaker 1: documents outside of the relevant periods described in paragraph fifteen Supra,
Speaker 1: and is withholding documents within the relevant period that are
Speaker 1: private and are not reasonably calculated to lead to discovery
Speaker 1: of admissible evidence. The documents reflecting flight plans in Maxwell's
Speaker 1: possession do not identify passengers or manifests. All right, folks,
Speaker 1: you're gonna wrap up this episode here and in the
Speaker 1: next episode talking about the topic, we'll pick up where
Speaker 1: we left off. All of the information that goes with
Speaker 1: this episode can be found in the description box. What's up, everyone,
Speaker 1: and welcome back to the Epstein Chronicles. In this episode,
Speaker 1: we're picking up where we left off with Virginia Roberts
Speaker 1: and her motion to have Maxwell produce documents that were
Speaker 1: subject to improper objections quest number thirty three all travel
Speaker 1: records between nineteen ninety nine and the present reflecting your
Speaker 1: presence in Palm Beach, Florida, or immediately surrounding areas New York,
Speaker 1: New Mexico, US Virgin Islands, any jeder aircraft owned or
Speaker 1: controlled by Jeffrey Epstein. Maxwell's response to Request number thirty three,
Speaker 1: Miss Maxwell objects to this request on the grounds that
Speaker 1: it is overly broad, unduly burdensome for the improper purpose
Speaker 1: of annoying or harassing Maxwell. This request is also a
Speaker 1: duplicate of request number eight and fourteen above. Maxwell further
Speaker 1: objects to this request to the extent that it calls
Speaker 1: for the production of documents that are irrelevant to this
Speaker 1: action and not reasonably calculated to lead to the discovery
Speaker 1: of admissible evidence. Subject to and without waiving the above objections,
Speaker 1: Maxwell has been unable to locate any documents responsive to
Speaker 1: this request for the relevant periods as defined in paragraph fifteen.
Speaker 1: Maxwell's withholding production of documents outside of such relevant periods
Speaker 1: d Maxwell's objections fail as the request seeks relevant discovery.
Speaker 1: Popularly known in mainstream media as the Lolida Express, Epstein
Speaker 1: is alleged to have used as private plane to traffic
Speaker 1: females across state lines for sexual purposes. The flight logs
Speaker 1: available at this time to Miss Roberts only show a
Speaker 1: fraction of the flights made by the Lolita Express, but
Speaker 1: even those logs show Miss Maxwell and Miss Roberts on
Speaker 1: these flights multiple times. Seemacauli declaration at Exhibit four, this
Speaker 1: request concerning Maxwell's travel will show Maxwell's involvement in the
Speaker 1: trafficking including Miss Roberts across state lines and for Epstein,
Speaker 1: Jeffrey Epstein's private island is only reachable by helicopter or boat.
Speaker 1: Maxwell was known to fly the helicopter to the private
Speaker 1: island transporting guests. Therefore, her helicopter flight records will show
Speaker 1: which girls and other individuals that Maxwell flew to Epstein's
Speaker 1: private eye island. The records will also demonstrate when and
Speaker 1: how many times Maxwell was operating the helicopter. Maxwell's commercial flight, passport, hotel,
Speaker 1: and credit card records are highly relevant because they will show,
Speaker 1: for example, that she flew to Paris, France with Miss
Speaker 1: Roberts while Miss Roberts was a minor child. Additionally, these
Speaker 1: records will place Maxwell at other locations around the United
Speaker 1: States and internationally at the same time Miss Roberts was
Speaker 1: in those locations, which goes to the defamation claim in
Speaker 1: this case. The records will also linker to other females
Speaker 1: who may have been trafficked for sex. Finally, Maxwell's travel
Speaker 1: to Epstein's residences in Florida, New York, New Mexico, and
Speaker 1: the USVII will support the allegations that Maxwell assisted Jeffrey
Speaker 1: Epstein with his sexual trafficking operation. Accordingly, this is an
Speaker 1: improper objection. Defendant Maxwell has admitted that she is withholding
Speaker 1: responsive documents from production, and this Court should require her
Speaker 1: to produce the request number ten and number eleven. Request
Speaker 1: number ten all documents relating to payments made from Jeffrey
Speaker 1: Epstein or related entity to you from nineteen ninety nine
Speaker 1: to the present, including payments for work performed, gifts, real
Speaker 1: estate purchases, living expenses, and payments to your charitable endeavors,
Speaker 1: including the TerraMar Project. B Maxwell's response to Request number ten.
Speaker 1: Maxwell objects to this request on the grounds that is
Speaker 1: overly broad, unduly burdensome, and or propounded for the improper
Speaker 1: purpose of annoying or harassing Maxwell. Maxwell further objects to
Speaker 1: this request on the grounds that it calls for the
Speaker 1: production of documents that are irrelevant to this action and
Speaker 1: not reasonably calculated to lead to the discovery of admissible evidence.
Speaker 1: Subject to and without waiving the above objections, Maxwell has
Speaker 1: been unable to locate any documents responsive to this request
Speaker 1: during the relevant periods as defined in paragraph fifteen. Maxwell
Speaker 1: is withholding production of documents outside of such relevant periods.
Speaker 1: See Request number eleven. All documents relating to or describing
Speaker 1: any work you performed with Jeffrey Epstein or any affiliated
Speaker 1: entity from nineteen ninety nine to the present d Maxwell's
Speaker 1: response to request number eleven. Maxwell objects to this request
Speaker 1: in that the terms work with an affiliated entity are vague, undefined,
Speaker 1: and susceptible of multiple meanings and definitions. Maxwell objects to
Speaker 1: this request on the grounds that it is overly broad,
Speaker 1: unduly burdensome, and or propounded for the improper purpose of
Speaker 1: annoying or harassing Maxwell. Maxwell further objects to this request
Speaker 1: on the grounds that it calls for the production of
Speaker 1: documents that are irrelevant to this action and not reasonably
Speaker 1: calculated to lead to the discovery of admissible evidence. Subject
Speaker 1: to and without waiving the above objections, Maxwell has been
Speaker 1: unable to locate any documents responsive to this request during
Speaker 1: the relevant periods as defined in pirograph fifteen. Maxwell is
Speaker 1: withholding production of documents outside of such relevant periods. E
Speaker 1: Maxwell's objections fail, as the request seeks relevant discovery. Maxwell
Speaker 1: recruited Roberts and Groomder to perform sexual acts for Jeffrey Epstein.
Speaker 1: She also performed other services for Epstein, including recruiting and
Speaker 1: scheduling girls to perform massages for Epstein. The household staff
Speaker 1: testified that they took instructions from Maxwell Seemacaulley declaration at
Speaker 1: Exhibit five, Rodriguez at twenty four and twenty five. Therefore,
Speaker 1: her work for Epstein and related entities is relevant. Discovery
Speaker 1: concerning Maxwell's compensation, formal or informal for the work she
Speaker 1: performed for convicted sex offender Jeffrey Epstein is highly relevant
Speaker 1: for the entire relevant period from nineteen ninety nine to
Speaker 1: the present because Maxwell performed these services and receive compensation
Speaker 1: and gives during this entire time period. For example, a
Speaker 1: two thousand and three Vanity Fair article written before Jeffrey
Speaker 1: Epstein's scandal broke describes Maxwell as someone who seems to
Speaker 1: organize much of Epstein's life. She recently was making telephone
Speaker 1: inquiries to find a California based yoga instructor forum. The
Speaker 1: police records also reveal that Maxwell recruited a female to
Speaker 1: work for Jeffrey Epstein. The message pads also reveal Maxwell
Speaker 1: regularly working for Jeffrey Epstein, including organizing his schedule for
Speaker 1: training underage girls Seemacauli declaration at Exhibit six. The work
Speaker 1: she performed for Epstein and the compensation she received is
Speaker 1: relevant to the claim in the case for the entire
Speaker 1: relevant period. Therefore, Maxwell must produce the documents she is
Speaker 1: withholding seven Request Number fifteen all videotapes, audio tape, photographs,
Speaker 1: or any other print or electronic media taken at a
Speaker 1: time when you were in Jeff free Epstein's company or
Speaker 1: inside any of his residences or his aircraft. Maxwell's response.
Speaker 1: Maxwell objects to this request on the grounds that is
Speaker 1: overly broad, unduly burdensome, and or propounded for the improper
Speaker 1: purpose of annoying or harassing Maxwell. Maxwell further objects to
Speaker 1: this request on the grounds that it calls for the
Speaker 1: production of documents that are irrelevant to this action and
Speaker 1: not reasonably calculated to lead to the discovery of admissible evidence.
Speaker 1: Maxwell further objects to this request to the extent that
Speaker 1: implicates or write to privacy Gateway Logistics Incorporated. Verse May
Speaker 1: three h two, Pt. Three d two thirty five, Colorado
Speaker 1: twenty thirteen, fed our Evidence five oh one, Subject two
Speaker 1: and without waiving the above objections, Maxwell has been unable
Speaker 1: to locate any documents responsive to this request that are
Speaker 1: within the relevant periods described in paragraph fifteen. Maxwell is
Speaker 1: withholding production of documents out side of such relevant periods
Speaker 1: b Maxwell's objections fail, as the request seeks relevant discovery.
Speaker 1: Maxwell must produce these documents for the entire relevant period
Speaker 1: and not withhold any photographs and other electronic recordings which
Speaker 1: every EPSTEIN likely contain the image of other underage girls
Speaker 1: or traffic women, and therefore those photographs go to the
Speaker 1: claim in this case. Additionally, such depictions would reveal other
Speaker 1: potential witnesses in this case. Accordingly, Maxwell must not withhold
Speaker 1: these documents. Based on a revised time period limitation for
Speaker 1: discovery number eight, Request number seventeen all documents relating to
Speaker 1: communication with You and Ross Goo from two thousand and
Speaker 1: five to the present. Maxwell's response. Maxwell objects to this
Speaker 1: request on the grounds that it is overly broad, unduly burdensome,
Speaker 1: and or propounded for the improper purpose of annoying or
Speaker 1: harassing Maxwell. Maxwell further abo to this request to the
Speaker 1: extent that it calls for the production of documents that
Speaker 1: are irrelevant to this action and not reasonably calculated to
Speaker 1: lead to the discovery of admissible evidence. Maxwell also objects
Speaker 1: to this request to the extent it seeks documents or
Speaker 1: information protected by the attorney client privilege. The common interest privilege,
Speaker 1: the work product doctrine, and any other applicable privilege subject
Speaker 1: to and without waiving the above objections. Maxwell is withholding
Speaker 1: documents responsive to this request that are outside the relevant
Speaker 1: periods defined in paragraph fifteen Supra, as well as the
Speaker 1: time period of January one, twenty eleven to December thirty one,
Speaker 1: twenty eleven, and also withholding documents within the relevant periods
Speaker 1: that are privileged. Maxwell has been unable to locate any
Speaker 1: non privileged documents that are within such relevant periods of time.
Speaker 1: Maxwell's objections fail as the request seeks relevant discovery. Through
Speaker 1: her non attorney public relations professional, mac Swell, made a
Speaker 1: defamatory statement to the press, and that statement is the
Speaker 1: genesis of this defamation lawsuit. The press quoted portions of
Speaker 1: this defamatory statement in its publications. The full statement distributed
Speaker 1: to the press by Maxwell through her agent, Ross gal
Speaker 1: is clearly discoverable. Miss Maxwell is in possession of that
Speaker 1: full statement. Miss Maxwell admitted to having a January second,
Speaker 1: twenty fifteen email from Ross Gau to various news organizations
Speaker 1: subject Glenn Maxwell. Its date is the day before the
Speaker 1: known defamatory statements appeared in the press. It is clear
Speaker 1: that the full defamatory statement is contained within that January second,
Speaker 1: twenty fifteen email. It is increasingly clear that the full
Speaker 1: statement contains other defamatory remarks, which is why Miss Maxwell
Speaker 1: is trying to hide it. There are no privileges that
Speaker 1: attached to emails to the press or to press releases.
Speaker 1: Their very purpose is wide dissemination. The fact that Maxwell
Speaker 1: has has not disclosed this press release places her in
Speaker 1: clear violation of her discovery obligations. Miss Roberts is plainly
Speaker 1: entitled to the defamatory statement Maxwell released to the press
Speaker 1: upon which this lawsuit is based, including all communications with
Speaker 1: her press agent and made by her press agent. Miss
Speaker 1: Roberts presumes that the full statement contains additional defamatory statements,
Speaker 1: which would explain Maxwell's spurious attempt to circumvent her discovery
Speaker 1: obligations to trying to convince the court that a press
Speaker 1: release is somehow confidential and privileged. In addition the full
Speaker 1: statement released to the press, Miss Roberts is entitled to
Speaker 1: all previous drafts of the statement and all communications Maxwell
Speaker 1: had with mister Goal regarding the statement. Accordingly, Miss Roberts
Speaker 1: is entitled to communications relating to mister goll particularly the
Speaker 1: January two, twenty fifteen email for the entire relevant period.
Speaker 1: All right, folks, we're going to wrap up there and
Speaker 1: in the next episode we'll pick up where we left off.
Speaker 1: All of the information that goes with this episode can
Speaker 1: be found in the description box. What's up, everyone, and
Speaker 1: welcome back to the Epstein Chronicles. This episode, we're diving
Speaker 1: right back into those core documents, and once again we're
Speaker 1: taking a look at Virginia Roberts and her motion to
Speaker 1: have Maxwell turn over the documents that she says were
Speaker 1: improperly held back during discovery. So let's dive right back
Speaker 1: in number nine requests number twenty one through twenty four
Speaker 1: all telephone records associated with Hugh, including cell phone records
Speaker 1: from nineteen ninety nine to the present. Maxwell's response. Maxwell
Speaker 1: objects to this request on the grounds that it is
Speaker 1: overly broad, unduly burdensome, propounded for the improper purpose of
Speaker 1: annoying or harassing Maxwell, and seeks documents outside of Maxwell's possession, custody,
Speaker 1: or control. Maxwell further objects to this request to the
Speaker 1: extent that it calls for the production of documents that
Speaker 1: are ereal event to the action and not reasonably calculated
Speaker 1: to lead to the discovery of admissible evidence. Maxwell further
Speaker 1: objects to this request to the extent it implicates her
Speaker 1: right to privacy. Gateway Logistics Incorporated. Versus s. May three
Speaker 1: oh two p. Dot three D two thirty five, Colorado
Speaker 1: twenty thirteen, Federal Rules of Evidence five oh one. Subject
Speaker 1: to and without waiving the above objections, Maxwell has been
Speaker 1: unable to locate any documents responsive to this request during
Speaker 1: the relevant periods defined in paragraph fifteen. Maxwell is withholding
Speaker 1: production of documents outside of such relevant periods. B Request
Speaker 1: number twenty two all documents relating to calendars, schedules, or
Speaker 1: appointments for you from nineteen ninety nine to the present.
Speaker 1: Maxwell's response to Request number twenty two. Maxwell objects to
Speaker 1: this request on the grounds that is overly brought, unduly burdensome,
Speaker 1: propounded for the improper purpose of annoying or harassing Maxwell,
Speaker 1: and seeks documents outside of the Maxwell's possession, custody, or control.
Speaker 1: Maxwell further objects to this request to the extent that
Speaker 1: it calls for the production of documents that are irrelevant
Speaker 1: to this action and not reasonably calculated to lead to
Speaker 1: the discovery of admissible evidence. Maxwell further objects to this
Speaker 1: request to the extent it implicates her right to privacy
Speaker 1: Gateway Logistics Incorporated. Versus s. May three zero two P.
Speaker 1: Three D two thirty five, Colorado twenty thirteen, Federal Rules
Speaker 1: of Evidence five oh one, Subject two, and without waiving
Speaker 1: the above objections, Maxwell has been unable to locate any
Speaker 1: documents responsive to this request during the relevant periods defined
Speaker 1: in paragraph fifteen. Supra. Maxwell is withholding production of documents
Speaker 1: outside of such relevant periods. D Requests Number twenty three
Speaker 1: all documents relating to calendars, schedules, or appointments for Jeffrey
Speaker 1: Epstein from nineteen ninety nine to present. Maxwell's response. Maxwell
Speaker 1: objects to this request on the grounds that it is
Speaker 1: overly broad, unduly burdensome, propounded for the improper purpose of
Speaker 1: annoying or harassing Maxwell, and seeks documents outside of Maxwell's possession, custody,
Speaker 1: or control. Maxwell further objects to this request to the
Speaker 1: extent that it calls for the production of documents that
Speaker 1: are irrelevant to this action and not reasonably calculated to
Speaker 1: lead to the discovery of admissible evidence. Maxwell further objects
Speaker 1: to this request to the extent that implicates the right
Speaker 1: to privacy. Gateway Logistics Incorporated. Versus. S. May three two,
Speaker 1: p Dot three d two thirty five, Colorado twenty thirteen,
Speaker 1: Federal Rules of Evidence five oh one, Subject two, and
Speaker 1: without waiving the above objections, Maxwell has been unable to
Speaker 1: locate any documents responsive to this request during the relevant
Speaker 1: periods defined and paragraph fifteen Supra. Maxwell is withholding production
Speaker 1: of documents outside of such relevant periods. Request number twenty
Speaker 1: four documents relating to contact lists, phone lists, or address
Speaker 1: books for you or Jeffrey Epstein from nineteen ninety nine
Speaker 1: to the present. G Maxwell's response to Request number twenty four.
Speaker 1: Maxwell objects to this request on the grounds that it
Speaker 1: is overly broad, unduly burdensome, and or propounded for the
Speaker 1: improper purpose of annoying or harassing Maxwell. Maxwell further objects
Speaker 1: to this request to the extent that it calls for
Speaker 1: the production of documents that are irrelevant to the action
Speaker 1: and not reasonably calculated to lead to the discovery of
Speaker 1: admissible evidence. Maxwell further objects to this request to the
Speaker 1: extent that implicates the right to privacy. Gateway Logistics Incorporated
Speaker 1: Versus s May three oh two p. Dot three d
Speaker 1: two thirty five Colorado, twenty thirteen, the Federal Rules of
Speaker 1: Evidence five BH one, Subject two, and without waiving the
Speaker 1: above objections, Maxwell has been unable to locate any documents
Speaker 1: responsive to this request within the relevant periods of find
Speaker 1: In paragraph fifteen Supra, Maxwell is withholding production of documents
Speaker 1: outside of such relevant periods. H. Maxwell's objections to request
Speaker 1: twenty one through twenty four fell as the request seeks
Speaker 1: relevant discovery. Request number twenty one through twenty four see
Speaker 1: Maxwell's telephone records, Maxwell and Jeffrey Epstein's calendars, and Epstein's
Speaker 1: contact lists for the relevant period. Maxwell admits that she
Speaker 1: has documents responsive to these requests that she refuses to produce.
Speaker 1: Contact with, meetings with, and contact information for Maxwell and
Speaker 1: Epstein's underage victims and adult co conspirators will prove that
Speaker 1: Miss Roberts is truthful regarding her sexual abuse. The small
Speaker 1: grouping of message pads pulled by law enforcement reflect that
Speaker 1: Maxwell was making arrangements for Jeffrey Epstein and was in
Speaker 1: regular and frequent contact with them see SAO two eight
Speaker 1: four seven. Records of telephone calls and meetings are critical
Speaker 1: to the case. For example, in one of the two
Speaker 1: documents produced by Maxwell. She instructs co conspirator Prince Andrew
Speaker 1: to call me see McCauley declaration at exhibit nine. Another
Speaker 1: example is Jeffrey Epstein's Black Book with the contact information
Speaker 1: for underage girls and co conspirators see McCauley declaration at
Speaker 1: Exhibit ten. Accordingly, Maxwell's refusal to produce similar documents is
Speaker 1: not supported by law, and this court should order them
Speaker 1: to be produced. Similarly, Maxwell and mister Epstein's calendars, schedules,
Speaker 1: and appointments reveal who they met with and when, including
Speaker 1: underage girls and co conspirators. Maxwell and Epstein's illegal and
Speaker 1: abusive behavior is not only relevant for the period of
Speaker 1: time in which they traffick Miss Roberts, their continued trafficking
Speaker 1: until Epstein's two thousand and eight indictment, and their continued
Speaker 1: collaboration up through the present regarding the related civil suits
Speaker 1: also go to the claim in this case and support
Speaker 1: Miss roberts account of her own sexual abuse. Accordingly, Maxwell
Speaker 1: must produce the documents responsive to these four requests that
Speaker 1: she is withholding ten Requests number thirty two all documents
Speaker 1: related to communications with or interaction with Alan Dershowitz from
Speaker 1: nineteen ninety nine to the present Maxwell's response. Maxwell objects
Speaker 1: to this request on the grounds that it is overly broad,
Speaker 1: unduly burdensome, and are propounded for the improper purpose of
Speaker 1: annoying or harassing Maxwell. Maxwell further objects to this request
Speaker 1: to the extent that it calls for the production of
Speaker 1: documents that are irrelevant to this action and not reasonably
Speaker 1: calculated to lead to the discovery of admissible evidence. Maxwell
Speaker 1: further objects to this request is being interposed for an
Speaker 1: improper purpose, specifically plaintiff ender Council's civil litigation currently pending
Speaker 1: in Broward County in the matter of Cassel versus Dershowitz.
Speaker 1: Subject to and without waiving the above objection, Maxwell will
Speaker 1: produce non privileged documents responsive to this request during the
Speaker 1: relevant periods defined and paragraph fifteen Supra. Maxwell is withholding
Speaker 1: production of documents outside of such relevant periods. B Maxwell's
Speaker 1: objections fail, as the request seeks relevant discovery. Defendant Maxwell
Speaker 1: has been communicating with Alan Dershowitz about the sexual trafficking allegations,
Speaker 1: as evidence by one email she produced. Maxwell's communications with
Speaker 1: Dershowitz are directly relevant to the claim. Maxwell has admitted
Speaker 1: that she has documents responsive to this request, but refuses
Speaker 1: to produce them under her arbitrary and self serving restrictive
Speaker 1: limitation to the relevant period. Accordingly, this Court should require
Speaker 1: that Defendant Maxwell producer communications with Dershowitz number eleven, Request
Speaker 1: number thirty four all documents reflecting your ownership or control
Speaker 1: of property in London between the years of nineteen ninety
Speaker 1: nine and two thousand and two. Maxwell's response. Maxwell objects
Speaker 1: to this request to the extent that it calls for
Speaker 1: the production of documents that are irrelevant to this action
Speaker 1: and not reasonably calculated to lead to the discovery of
Speaker 1: admissible evidence. Maxwell further objects to this request on the
Speaker 1: grounds that it calls for documents that are a matter
Speaker 1: of public record and are thus equally available to the plaintiff.
Speaker 1: Subjection two and without waiving the above objections, Maxwell is
Speaker 1: withholding documents responsive to this request that are a matter
Speaker 1: of public record. B. Maxwell's objections fail, as the request
Speaker 1: seeks relevant discovery. Defending Maxwell and Jeffrey Epstein trafficked Miss
Speaker 1: Roberts when she was a minor child to Prince Andrew
Speaker 1: in Maxwell's own home in London, As evidence by the
Speaker 1: photograph of Miss Roberts, Maxwell and Prince Andrew taken in
Speaker 1: her London home when Miss Roberts was only seventeen years old.
Speaker 1: Ce McCauley declaration at Exhibit eleven evidence of Maxwell's property
Speaker 1: in London. Evidence is this incident of sexual trafficking and
Speaker 1: is there for relevant? The ownership and property records are
Speaker 1: also relevant to establish whether any other individuals have ownership
Speaker 1: rights in the property, like Jeffrey Epstein. The recent amendments
Speaker 1: to Rule twenty six B allow courts to take into
Speaker 1: account the party's relative access to relevant information. Federal Rules
Speaker 1: for Civil Procedure twenty six B one. Maxwell admitted that
Speaker 1: she already has responsive documents in her possession that she
Speaker 1: is choosing to withhold, purporting that they are a matter
Speaker 1: of public record, without giving any evidence or reason supporting
Speaker 1: that statement, nor explaining how and whether such records can
Speaker 1: be accessed by a foreigner. Indeed, Miss Robert's access to
Speaker 1: property records in a foreign jurisdiction is slight compared to
Speaker 1: Maxwell's access to documents already in her possession. The party
Speaker 1: resisting disclosure bears the burden of establishing alternative sources for
Speaker 1: the information, and Maxwell has not met that burden ce
Speaker 1: State Farm Mutual Auto Insurance Company First FDA number fourteen
Speaker 1: sieven nine S nine two WHP JCF twenty fifteen, w
Speaker 1: WELL seven eighty seven ten thirty seven at four SDNY,
Speaker 1: December third, twenty fifteen. Accordingly, Maxwell must produce her property
Speaker 1: records number twelve, request number thirty seven, all documents reflecting
Speaker 1: communications you have had with Bill or Hillary Clinton, or
Speaker 1: persons acting on their behalf, including all communications regarding your
Speaker 1: attendance at Chelsea Clinton's wedding in twenty ten. Maxwell's response.
Speaker 1: Maxwell objects to this request on the grounds that is
Speaker 1: overly broad, unduly burdensome, and or propounded for the improper
Speaker 1: purpose of annoying or harassing Maxwell. Maxwell further objects to
Speaker 1: this request to the extent that it calls for the
Speaker 1: production of documents that are irrelevant to this action and
Speaker 1: not reasonably calculated to lead to the discovery of admissible
Speaker 1: evidence Subject two. And without waiving the above objections, Maxwell
Speaker 1: has been unable to locate any documents responsive to this
Speaker 1: request for the relevant periods as defined in paragraph fifteen Supra.
Speaker 1: Maxwell's withholding production of documents outside of such relevant periods.
Speaker 1: B Maxwell's objections fail as the request seeks relevant discovery,
Speaker 1: as recounted above. In two thousand and nine, an attorney
Speaker 1: sought Maxwell's deposition in connection to various sexual abuse allegations,
Speaker 1: and Maxwell said her mother was ill and that she
Speaker 1: would be traveling outside the country with no plans or returning.
Speaker 1: Despite this claim to avoid her deposition, she was then
Speaker 1: photographed at Chelsea Clinton's wedding in Rhineback, New York. Ce
Speaker 1: McCaulay declaration at Exhibit eight, Maxwell deposition notice, subpoena in
Speaker 1: cancelation payment notice and January thirteenth, twenty fifteen daily Mail
Speaker 1: article with photograph. Maxwell admits that she has documents responsive
Speaker 1: to this request and that this court should require her
Speaker 1: to produce them. Other communications she has had with the
Speaker 1: Clintons about Miss Roberts or the alleys in this case
Speaker 1: are also highly relevant, particularly given that mister Clinton travel
Speaker 1: with Maxwell, Jeffrey Epstein, and others on Jeffrey Epstein's play
Speaker 1: in a number of times, including a trip to Thailand
Speaker 1: Number thirteen. Request number thirty nine. All documents reflecting training
Speaker 1: to fly a helicopter or experience flying a helicopter, including
Speaker 1: any records concerning your operation of a helicopter in the
Speaker 1: US Virgin Islands. A. Maxwell's response. Maxwell objects to this
Speaker 1: request to the extent that it calls for the production
Speaker 1: of documents that are irrelevant to this action and not
Speaker 1: reasonably calculated to lead to the discovery of admissible evidence.
Speaker 1: Maxwell further objects to this request to the extent it
Speaker 1: implicates her right to privacy. Gateway Logistics Incorporated. Vers. May
Speaker 1: three h two p. Dot three D two thirty five,
Speaker 1: Colorado twenty thirteen, Federal Rules of Evidence five oh one.
Speaker 1: Maxwell is withholding documents responsive to this request as irrelevant
Speaker 1: and not reasonably calculated to lead to the discovery of
Speaker 1: admissible evidence. B. Maxwell's objections fail as the request seeks
Speaker 1: relevant discovery. Epstein's private island in the United States Virgin
Speaker 1: Islands is only accessible via boat or helicopter. Maxwell flew
Speaker 1: people back and forth from Epstein's island as part of
Speaker 1: her sexual trafficking of underage girls. Records of Maxwell's operating
Speaker 1: a helicopter and training therefore is relevant to the claims
Speaker 1: of sexual abuse in the case. Maxwell has admitted that
Speaker 1: she has responsive documents. Therefore, this court should require her
Speaker 1: to produce them. Conclusion for the reason set forth above,
Speaker 1: Plaintiff Virginia Roberts, respectfully requests that the Court grant her
Speaker 1: motion to compel and direct defend at MAXWELL to produce
Speaker 1: documents responsive to request numbers one through thirty nine for
Speaker 1: the period of ninety nine to the present. This was
Speaker 1: dated February twenty six, twenty sixteen, and signed by Sacred McAuley.
Speaker 1: All of the information that goes with this episode can
Speaker 1: be found in the description box.