Mega Edition: Virginia Robert's Motion To Compel Documents From Improper Objections (Part 3-4) (3/6/26)

0:00Tyler Reddick here from 2311 Racing. Another checkered flag for the books. Time to celebrate with Jamba. Jump in at JambaCasino.com. Let's Jamba. No purchase necessary, BTW Group. Boy, we're prohibited by law. CCNC is 21 plus sponsored by JambaCasino. I'm Lee, here to dig into conspiracies that will make you question everything. And I'm Ollie, here to make sure we don't contact aliens again. Tune into the daily conspiracy podcast where we uncover the bizarre and the unexplained. And I try to make sure we don't summon anything like bathroomette or worse, like my mother-in-law. If you're ready to question reality with a grin, listen to us wherever you get your podcasts. We are the daily conspiracy podcast. Because reptilians don't take days off. What's up, everyone?

1:00And welcome back to the Epstein Chronicles. In this episode, we're picking up where we left off with Virginia Roberts and her motion to have Maxwell produce documents that were subject to improper objections. Request number 33. All travel records between 1999 and the present reflecting your presence in Palm Beach, Florida or immediately surrounding areas. New York, New Mexico, US Virgin Islands, any jet or aircraft owned or controlled by Jeffrey Epstein. Maxwell's response to request number 33. This Maxwell objects to this request on the grounds that it is overly broad, unduly burdensome for the improper purpose of annoying or harassing Maxwell. This request is also a duplicate of request number eight and 14 above. Maxwell further objects to this request to the extent that it calls for the production of documents that are irrelevant to this action

2:00and not reasonably calculated to lead to the discovery of admissible evidence. Subject two and without waving the above objections, Maxwell has been unable to locate any documents responsive to this request for the relevant periods as defined in paragraph 15. Maxwell is withholding production of documents outside of such relevant periods. D, Maxwell's objections fail as the request seeks relevant discovery popularly known in mainstream media as the Lolita Express. Epstein is alleged that he is used as private plane to traffic females across state lines for sexual purposes. The flight logs available at this time to Ms. Roberts only show a fraction of the flights made by the Lolita Express, but even those logs show Ms. Maxwell and Ms. Roberts on these flights multiple times. See McCauley declaration at exhibit four. This request concerning Maxwell's travel will show Maxwell's involvement in the trafficking, including Ms. Roberts across state lines and for Epstein. Jeffrey Epstein's private island is only reachable

3:03by helicopter or boat. Maxwell was known to fly the helicopter to the private island transporting guests. Therefore, her helicopter flight records will show which girls and other individuals that Maxwell flew to Epstein's private island. The records will also demonstrate when and how many times Maxwell was operating the helicopter. Maxwell's commercial flight, passport, hotel, and credit card records are highly relevant because they will show, for example, that she flew to Paris, France, with Ms. Roberts while Ms. Roberts was a minor child. Additionally, these records will place Maxwell at other locations around the United States and internationally at the same time Ms. Roberts was in those locations, which goes to the defamation claim in this case. The records will also link her to other females who may have been trafficked for sex. Finally, Maxwell's travel to Epstein's residences in Florida, New York, New Mexico, and the USVI will support the allegations that Maxwell assisted Jeffrey Epstein with his sexual trafficking operation.

4:06Accordingly, this is an improper objection. Defend that Maxwell has admitted that she is withholding responsive documents from production and this court should require her to produce them. Request number 10 and number 11. Request number 10. All documents relating to payments made from Jeffrey Epstein or related entity to you from 1999 to the present, including payments for work performed, gifts, real estate purchases, living expenses, and payments to your charitable endeavors, including the Terramar project. B, Maxwell's response to request number 10. Maxwell objects to this request on the grounds that is overly broad, unduly burdensome, and or propounded for the improper purpose of annoying or harassing Maxwell. Maxwell further objects to this request on the grounds that it calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence.

5:06Subject two and without waiving the above objections, Maxwell has been unable to locate any documents responsive to this request during the relevant periods as defined in paragraph 15. Maxwell is withholding production of documents outside of such relevant periods. C, Request number 11. All documents relating to or describing any work you performed with Jeffrey Epstein or any affiliated entity from 1999 to the present. D, Maxwell's response to request number 11. Maxwell objects to this request in that the terms work with an affiliated entity or vague, undefined, and susceptible of multiple meanings and definitions. Maxwell objects to this request on the grounds that it is overly broad, unduly burdensome, and or propounded for the improper purpose of annoying or harassing Maxwell. Maxwell further objects to this request on the grounds that it calls for the production of documents that are irrelevant to this action

6:07and not reasonably calculated to lead to the discovery of admissible evidence. Subject two and without waiving the above objections, Maxwell has been unable to locate any documents responsive to this request during the relevant periods as defined in paragraph 15. Maxwell is withholding production of documents outside of such relevant periods. E, Maxwell's objections fail as the request seeks relevant discovery. Maxwell recruited Roberts and Grumder to perform sexual acts for Jeffrey Epstein. She also performed other services for Epstein, including recruiting and scheduling girls to perform massages for Epstein. The household staff testified that they took instructions from Maxwell, Simalcali Declaration, at exhibit five, Rodriguez at 24 and 25. Therefore, her work for Epstein and related entities is relevant, discovery concerning Maxwell's compensation, formal or informal for the work she performed before convicted sex offender, Jeffrey Epstein,

7:10is highly relevant for the entire relevant period. From 1999 to the present, because Maxwell performed these services and received compensation and gives during this entire time period. For example, a 2003 Vanity Fair article written before Jeffrey Epstein's scandal broke, describes Maxwell as someone who seems to organize much of Epstein's life. She recently was making telephone inquiries to find a California-based yoga instructor forum. The police records also reveal that Maxwell recruited a female to work for Jeffrey Epstein. The message pads also reveal Maxwell regularly working for Jeffrey Epstein, including organizing his schedule for training underage girls. Simalcali Declaration at exhibit six. The work she performed for Epstein and the compensation she received is relevant to the claim in the case for the entire relevant period. Therefore, Maxwell must produce the documents she is withholding. Seven, request number 15. All videotapes, audio tape, photographs,

8:12or any other print or electronic media taken at a time when you were in Jeffrey Epstein's company or inside any of his residences or his aircraft. Maxwell's response. Maxwell objects to this request on the grounds that is overly broad, unduly burdensome, and or propounded for the improper purpose of annoying or harassing Maxwell. Maxwell further objects to this request on the grounds that it calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Maxwell further objects to this request to the extended implicates her right to privacy, Gateway Logistics Incorporated, vs. May 302p.3t235 Colorado 2013. FedRevidence 501, subject to and without waiving the above objections, Maxwell has been unable to locate any documents responsive to this request that are within the relevant periods described in paragraph 15.

9:12Maxwell is withholding production of documents outside of such relevant periods. B, Maxwell's objections fail as the request seeks relevant discovery. Maxwell must produce these documents for the entire relevant period and not withhold any. Photographs and other electronic recordings with Jeffrey Epstein likely contain the image of other underage girls or traffic women and therefore those photographs go to the claim in this case. Additionally, such depictions would reveal other potential witnesses in this case. Accordingly Maxwell must not withhold these documents based on a revised time period limitation for discovery. Number 8, Request Number 17. All documents relating to communication with you and Ross Gal from 2005 to the present. Maxwell's response. Maxwell objects to this request on the grounds that it is overly broad, unduly burdensome, and or propounded for the improper purpose

10:12of annoying or harassing Maxwell. Maxwell further objects to this request to the extent that it calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Maxwell also objects to this request to the extent it seeks documents or information protected by the attorney client privilege, the common interest privilege, the work product doctrine, and any other applicable privilege. Subject 2 and without waping the above objections, Maxwell is withholding documents, responsive to this request that are outside the relevant periods defined in paragraph 15, Supra as well as the time period of January 1st, 2011, 2 December 31st, 2011, and also withholding documents within the relevant periods that are privileged. Maxwell has been unable to locate any non-privileged documents that are within such relevant periods of time. Maxwell's objections fail. As a request seeks relevant discovery

11:12through her non-atranny, public relations professional, Maxwell made a defamatory statement to the press, and that statement is the genesis of this defamation lawsuit. The press quoted portions of this defamatory statement in its publications. The full statement distributed to the press by Maxwell through her agent, Ross Gow, is clearly discoverable. Miss Maxwell is in possession of that full statement. Miss Maxwell admitted to having a January 2nd, 2015 email from Ross Gow to various news organizations, how to have fun, anytime, anywhere. Step 1, go to ChambaCasino.com. ChambaCasino.com. Got it. Step 2, collect your welcome bonus. Come to Papa, welcome bonus. Step 3, play hundreds of casino-style games for free. That's a lot of games, all for free. Step 4, unleash your excitement. ChambaCasino has been delivering thrills for over a decade, so claim your free welcome bonus now and live the Chamba life. Visit ChambaCasino.com. No purchase necessary VGW group void

12:12were prohibited by law, 21 plus terms and conditions apply. According to statistics, the average person walks past 36 murders in their lifetime. Thirty-year-old, oh my God, she was murdered. She was murdered. Unlike in Hollywood movies, they're not easy to spot. Where is she, buddy? Where is she? The devil made me turn her to ashes. They seamlessly blend into our everyday lives, assuming rules, as friendly neighbors, helpful colleagues, or even the person lying beside each night. I wanted to be out of jail. I couldn't wait till I got out. I was in there with someone who was clearly psychopathic. Using investigative research and primary audio, morbidology is an award-winning trick-rime podcast that shines a light on the darkest corners of humanity. Through our investigation, we have attained evidence, which we are not releasing at this time, which leads us to believe Jolene is not alive. Turn into morbidology each week, across all podcast platforms. They keep telling you

13:12that the Jeffrey Epstein story is finished, that it was investigated, that it was handled. But here's the part that they never explained, why the charges were so narrow, when the conduct was so broad. How does a man with multiple properties, private aircraft, international travel, and a documented pipeline of victims get treated like a lone offender? Why were logistics treated as background noise instead of evidence? Why were facilitators reduced to footnotes instead of defendants? Well, that's where we come in. The Epstein Chronicles exists because those questions were never answered. This podcast breaks down what the public record actually shows, the deals that caps exposure, the decisions that limited scope, and the moments where prosecutors chose restraint, overreach. If you ever wondered why this case feels unfinished, why accountability stopped at the perimeter, or why so many names remain officially invisible, you've come to the right place. Welcome to the Epstein Chronicles. Subject, Glan Maxwell.

14:12Its date is the day before the known defamatory statements appeared in the press. It is clear that the full defamatory statement is contained within that January 2nd, 2015 email. It is increasingly clear that the full statement contains other defamatory remarks, which is why Ms. Maxwell is trying to hide it. There are no privileges that attach the emails to the press or to press releases. Their very purpose is wide dissemination. The fact that Maxwell has not disclosed this press release places her in clear violation of her discovery obligations. Ms. Roberts is plainly entitled to the defamatory statement, Maxwell released to the press, upon which this lawsuit is based, including all communications, with her press agent, and made by her press agent. Ms. Roberts presumes that the full statement contains additional defamatory statements, which would explain Maxwell's spurious attempt to circumvent her discovery obligations, to trying to convince the court that a press release is somehow confidential

15:12and privileged. In addition, the full statement, released to the press, Ms. Roberts is entitled to all previous drafts of the statement, and all communications, Maxwell had with Mr. Gal, regarding this statement. Accordingly, Ms. Roberts is entitled to communications relating to Mr. Gal, particularly the January 2nd, 2015 email. For the entire relevant period. All right, folks, we're going to wrap up there, 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. What's up everyone, and welcome back to the Epstein Chronicles. This episode we're diving right back into those court documents, and once again, we're taking a look, at Virginia Roberts and her motion, to have Maxwell, turn over the documents, that she says were improperly, held back during discovery. So, let's dive right back in. Number 9. Request number 21 through 24. All telephone records

16:12associated with you, including cell phone records, from 1999 to the present. Maxwell's response. Maxwell objects to this request on the ground, that it is overly broad, unduly burdensome, propounded for the improper purpose of annoying, or harassing Maxwell, and seeks documents out of Maxwell's possession. Custody or control. Maxwell further objects to this request, to the extent, that it calls for the production of documents that are irrelevant, to the action, and not reasonably calculated, to lead to the discovery of admissible evidence. Maxwell further objects, to this request, to the extent, it implicates her right to privacy, Gateway Logistics Incorporated, versus SMA-302P, .3D-235 Colorado, 2003, Federal Rules of Evidence 501. Subject 2, and without waving the above objections, Maxwell has been unable to locate any documents responsive, to this request during the relevant periods defined in paragraph 15.

17:13Maxwell is withholding production of documents outside of such relevant periods. B, request number 22. All documents relating to calendars, schedules, or appointments for you, from 1999 to the present. Maxwell's response to request, number 22. Maxwell objects to this request, on the grounds, that it is overly broad, unduly burdensome, propounded for the improper purpose, of annoying or harassing Maxwell, and seeks documents outside of Maxwell's possession, custody, or control. Maxwell further objects, to this request, to the extent, that it calls for the production of documents, that are irrelevant to this action, and not reasonably calculated, to lead to the discovery, of admissible evidence. Maxwell further objects, to this request, to the extent, it implicates the right to privacy, gateway logistics, incorporated, versus SMA-302P, 3D-235, Colorado-2013, Federal Rules of Evidence-501.

18:15Subject 2, and without waving, the above objections, Maxwell has been unable to locate any documents responsive to this request, during the relevant periods, defined in paragraph 15, Supra, Maxwell is withholding production of documents outside of such relevant periods, D, request number 23. All documents relating to calendars, schedules, or appointments for Jeffrey Epstein, from 1999 to present, Maxwell's response. Maxwell objects, to this request, on the grounds, that it is overly broad, unduly burdensome, propounded for the improper purpose, of annoying or harassing Maxwell, and seeks documents outside, of Maxwell's possession, custody or control. Maxwell further objects, to this request, to the extent that it calls for the production of documents, that are irrelevant to this action, and not reasonably calculated to lead to the discovery, of admissible evidence. Maxwell further objects, to this request, to the extended implicates a right to privacy, gateway logistics, incorporated, versus SMA-302P,

19:16dot 3D-235, Colorado-2013, Federal Rules of Evidence-501. Subject two, and without waiving the above objections, Maxwell, has been unable to locate any documents responsive, to this request, during the relevant periods, defined and paragraph 15, Supra, Maxwell's withholding, production of documents outside of such relevant periods. Request number 24. All documents relating to contact lists, phone lists, or address books, for you, or Jeffrey Epstein, from 1999 to the present. G. Maxwell's response to request number 24. Maxwell objects to this request, on the grounds, that it is overly broad, unduly burdensome, and or propounded, for the improper purpose, of annoying or harassing Maxwell. Maxwell further objects, to this request, to the extent, that it calls for the production of documents, that are irrelevant, to the action, and not reasonably calculated, to lead to the discovery of admissible evidence. Maxwell further objects,

20:17to this request, to the extended implicate, to write the privacy, Gateway Logistics Incorporated, versus SMAe 302P.3D235, Colorado 2013, the Federal Rules of Evidence 501. Subject two, and without waving, the above objections, Maxwell, has been unable to locate any documents responsive, to this request, within the relevant periods, defined and paragraph 15, Supra, Maxwell's withholding, production of documents, outside of such relevant periods. H, Maxwell's objections, to request 21, through 24 fell, as the request seeks relevant discovery. Request number 21, through 24, seek Maxwell's telephone records, Maxwell and Jeffrey Epstein's calendars, and Epstein's contact list, for the relevant period. Maxwell admits that she has documents, responsive, to these requests, that she refuses to produce. Contact with, meetings with, and contact information for Maxwell, and Epstein's underage victims,

21:17and adult co-conspirators, will prove that Ms. Roberts is truthful, regarding her sexual abuse. The small grouping of message pads, pulled by law enforcement, reflect that Maxwell was making arrangements, for Jeffrey Epstein, and was in regular and frequent contact with him. See, SAO 2847. Records of telephone calls and meetings are critical to this case, for example, in one of the two documents produced by Maxwell, she instructs co-conspirator, Prince Andrew Takalmi, see McCauley Declaration at Exhibit 9. Another example is Jeffrey Epstein's black book, with the contact information for underage girls and co-conspirators, see McCauley Declaration at Exhibit 10. Accordingly, Maxwell's refusal to produce similar documents is not supported by law, and this court should order, them to be produced, similarly Maxwell, and Mr. Epstein's calendars, schedules, and appointments reveal who they met with, and when,

22:17including underage girls, and co-conspirators. Maxwell and Epstein's illegal and abusive behavior is not only relevant for the period of time, in which they traffic Ms. Roberts. They continue trafficking until Epstein's 2008 indictment, and their continued collaboration, up through the present, regarding the related civil suits, also go to the claim in this case, and support Ms. Roberts' account of her own sexual abuse. Accordingly, Maxwell must produce the document's responsive to these four requests that she is withholding. 10. Request No. 32. All documents related to communications, with or interaction with Alan Dershowitz, from 1999 to the present. Maxwell's response. Maxwell objects to this request on the grounds that it is overly broad, unduly burdensome, and or propounded for the improper purpose of annoying or harassing Maxwell. Maxwell further objects to this request, to the extent that it calls for the production of documents that are irrelevant to this action,

23:18and not reasonably calculated to lead to the discovery of admissible evidence. Maxwell further objects to this request as being interposed for an improper purpose, specifically plaintiff and her councils, civil litigation, currently pending, in Broward County. In the matter of Cassel vs. Dershowitz. Subject 2 and without waiving the above objections, Maxwell will produce non-privileged documents responsive to this request during the relevant periods, defined in paragraph 15 Supra. Maxwell is withholding production of documents outside of such relevant periods. B. Maxwell's objections fail. As the request seeks relevant discovery, defendant Maxwell has been communicating with Alan Dershowitz about the sexual trafficking allegations as evidence by a one email she produced. Maxwell's communications with Dershowitz are directly relevant to the claim. Maxwell has admitted that she has documents responsive to this request, but refuses to produce them under her arbitrary

24:19and self-serving restrictive limitation to the relevant period. Accordingly, this court should require that defendant Maxwell produce her communications with Dershowitz. Number 11, request number 34. All documents reflecting your ownership or control of property and London between the years of 1999 and 2002. Maxwell's response. Maxwell objects to this request to the extent that it calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Maxwell further objects to this request on the grounds that it calls for documents that are a matter of public record and are thus equally available to the plaintiff. Subjection 2 and without waiving the above objections, Maxwell, is withholding documents responsive to this request that are a matter of public record. B. Maxwell's objections fail as the request seeks relevant discovery. Defended Maxwell and Jeffrey Epstein traffic Miss Roberts when she was a minor child, the Prince Andrew,

25:21in Maxwell's own home in London as evidenced by the photograph of Miss Roberts, Maxwell, and Prince Andrew taken in her London home when Miss Roberts was only 17 years old. See McCauley Declaration at Exhibit 11. Evidence of Maxwell's property in London, evidence is this incident of sexual trafficking and is therefore relevant. The ownership and property records are also relevant to establish whether any other individuals have ownership rights in the property, like Jeffrey Epstein. The recent amendments to Rule 26b allow courts to take into account the party's relative access to relevant information. Federal rules for civil procedure, 26b1, Maxwell admitted that she already has responsive documents in her possession, that she is choosing to withhold, reporting that they are a matter of public record without giving any evidence or reasons supporting that statement, nor explaining how and whether such records can be accessed by a foreigner, indeed Miss Roberts access to property records

26:21in a foreign jurisdiction, is slight compared to Maxwell's access to documents already in her possession. The party resisting disclosure bears the burden of establishing alternative sources for the information, and Maxwell has not met that burden. See state Farm Mutual Auto Insurance Company, 1st Veda, 14th Civ 9792 WHP, JCF 2015, WL 787 1037, at 4 SDNY December 3, 2015. Accordingly, Maxwell must produce her property records. 12. Request number 37, all documents reflecting communications, you have had with Bill or Hillary Clinton, or persons acting on their behalf, including all communications regarding your attendance, at Chelsea Clinton's wedding in 2010. Maxwell's response, Maxwell objects to this request on the grounds that it is overly broad, unduly burdensome, and or propounded for the improper purpose of annoying or harassing Maxwell.

27:22Maxwell further objects to this request to the extent that it calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Tyler Reddick here from 2311 Racing. Victory Lane? Yeah, it's even better with Chamba by my side. Race to ChambaCasino.com, let's Chamba. No purchase necessary, VTW Group, voidware prohibited by law, CT and C's, 21 plus, sponsored by ChambaCasino. Subject 2, and without waving, the above objections, Maxwell, has been unable to locate any documents responsive to this request for the relevant periods as defined in paragraph 15 Supra. Maxwell is withholding production of documents outside of such relevant periods. B, Maxwell's objections fail as the request seeks relevant discovery, as recounted above in 2009 an attorney sought Maxwell's deposition in connection to various sexual abuse allegations and Maxwell said her mother was ill

28:22and that she would be travelling outside the country with no plans or return in. Despite this claim to avoid her deposition, she was then photographed at Chelsea Clinton's wedding in Rhineback, New York, C. McCauley Declaration at Exhibit 8, Maxwell deposition notice, Sabina in cancellation payment notice, and January 13th 2015 Daily Mail article with photograph. Maxwell admits that she has documents responsive to this request and that this court should require her to produce them. Other communications she has had with the Clintons about Ms. Roberts or the allegations in this case are also highly relevant, particularly given that Mr. Clinton travel with Maxwell, Jeffrey Epstein, and others on Jeffrey Epstein's playing a number of times, including a trip to Thailand. Number 13, request number 39. All documents reflecting training to fly a helicopter or experience flying a helicopter, including any records concerning your operation of a helicopter in the US Virgin Islands. A, Maxwell's response.

29:22Maxwell objects to this request to the extent that it calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Maxwell further objects to this request to the extended implicator or write the privacy. Gateway logistics incorporated versus May 302 p.3d to 35 Colorado 2013 federal rules of evidence 501. Maxwell is withholding documents responsive to this request as irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. B, Maxwell's objections fail as a request seeks relevant discovery. Epstein's private island in the United States Virgin Islands is only accessible via boat or helicopter. Maxwell flew people back and forth from Epstein's island as part of her sexual trafficking of underage girls, records of Maxwell's operating a helicopter and training therefore is relevant to the claims of sexual abuse in the case. Maxwell has admitted

30:22that she has responsive documents therefore this court should require her to produce them. Conclusion. For the reason set forth, above Plaintiff Virginia Roberts respectfully requests that the court grant her a motion to compel and direct defendant Maxwell to produce documents responsive to request numbers one through 39 for the period of 99 to the present. This was dated February 26, 2016 and signed by Sigurd McCauley. All of the information that goes with this episode can be found in the description box. Tyler Reddick here from 2311 Racing. Victory Lane? Yeah, it's even better with Chamba by my side. Race to ChambaCasino.com Let's Chamba. No purchase necessary, VTW Group. Voidware prohibited by law.