Mega Edition: Virginia Robert's Motion To Compel Documents From Improper Objections (Part 1-2) (3/5/26)

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1:00Using 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. What's up, everyone? And welcome back to the Epstein Chronicles. In this episode, we're going to start taking a look at the Virginia Roberts motion to compel the production of documents subject to improper objections. Case number 15-CV-074-33-RWS, Virginia Roberts, VS. Maxwell. Plaintiff, Virginia Roberts, by and through the undersigned council, respectfully submits this motion to compel production of documents

2:01in response to request numbers 1 through 39 and to compel documents subject to improper objections, including refusals, to produce documents from highly relevant time periods. For the reason set forth below, this court should grant plaintiff's motion in its entirety. One, the preliminary statement. Plaintiff first served a request for production of documents on defendant on October 27th, 2015. Now, almost four months later, and even after this court denied defendant's attempts to state discovery and directed a response, defendant is still refusing to produce highly relevant documents. Defendant is attempting to grant herself a de facto stay of discovery without court approval by refusing to produce documents or generally comply with a party's clear and unequivocal discovery obligations. Indeed, in response to 38 requests for production, the defendant has chosen to produce two emails. This represents a willful disregard

3:03of her discovery obligations, something this court should not condone. Although not unlimited relevance for purposes of discovery is an extremely broad concept. Odison versus SMBC, leasing and financing Incorporated, sweet J, 2015, WL, 459, 7542 at 2 SDNY, July, 2015, granting motion to compel. Stinson versus City of New York, sweet J, 2015, WL, 4610, 422, SDNY, July 23, 2015, granting in part motion to compel production. In the second circuit, courts of dismissed actions where a party has demonstrated willful disregard for its discovery obligations. Edwards versus American Airlines Incorporated, number 95, civ.5356, SAS, 1996, WL, 432472 at 3 SDNY, August 1, 1996.

4:07See also International Mining Company Incorporated versus Allen & Company, sweet J, 567, f.suppp777, SDNY 1983, failure to produce documents and supply adequate answers to interrogatories without justifiable excuse warranted the dismissal of the complaint. The blatant nature of the defendant's failure to participate in discovery is a kin to the conduct for which the second circuit has awarded sanctions. This case turns on whether or not Maxwell defames Roberts when she calls Miss Roberts account of her sexual abuse obvious lies. Miss Roberts intends to establish that Maxwell's defamatory statement was untrue and that Miss Roberts was telling the truth. To prove the truth of her sexual abuse, Miss Roberts seeks discovery of documents, evidencing her sexual abuse and sexual trafficking by Maxwell and her associates, including convicted sex offender Jeffrey Epstein.

5:07Therefore, documents evidencing Miss Roberts encounters with Maxwell and documents evidencing Maxwell's communications with her co-conspirators are plainly relevant and discoverable. For example, Request 6 seeks documents relating to Maxwell's communications with Sarah Kellen. At a prior deposition, Sarah Kellen invoked her Fifth Amendment privilege, one asked, question, would you agree with me that Glaine Maxwell provides underage girls to Mr. Epstein for sex? Answer, upon the instruction of my lawyer, I must invoke my Fifth Amendment privilege. Question, take a look at what we marked as exhibit 10. Do you recognize the two people in that photograph? Answer, on the instruction of my lawyer, I must invoke my Fifth Amendment privilege. Question, would you agree with me that Glaine Maxwell on the right and Jeffrey Epstein's on the left? Answer, on the instruction of my lawyer, I must invoke my Fifth Amendment privilege. Question, do you recognize the young lady shown in exhibit 11?

6:08Answer, on the instruction of my lawyer, I must invoke my Fifth Amendment privilege. Question, do you agree with me that the young girl shown in exhibit 11 was recruited by Glaine Maxwell for sexual activity with Jeffrey Epstein? Answer, on the instruction of my lawyer, I must invoke my Fifth Amendment privilege. See McCauley Declaration at exhibit 1. Clearly communications, Maxwell had with Sarah Kellen are highly relevant to establishing Maxwell's involvement in trafficking underage girls. Yet Maxwell is refusing to produce any communications with Sarah Kellen. Moreover, defendant Maxwell has admitted that non-privileged relevant documents exist. She is simply refusing to produce them. See the Declaration of Sigrid McCauley, McCauley Declaration at exhibit 2. Defendant Maxwell's response to plaintiffs' first request for production requests numbers 1, 3, 6, 7, 8, 9, 10, 11, 15, 17, 19, 21, 22, 23, 24, 32, 33, 34, and 37.

7:13Indeed, it is undisputed that Maxwell spent many years traveling with Ms. Roberts, and for years thereafter Maxwell continued her association with convicted sex offender Jeffrey Epstein. Ms. Roberts is entitled to those documents in discovery because they go directly to the claim at the issue in this litigation. Therefore, this court should compel her to produce them, the legal argument. Under Federal Rule of Civil Procedure 34A, a party may request that another party produce documents in its possession as long as the documents are within the scope of FedR Civ P26B, which allows for broad discovery regarding any non-privileged matter that is relevant to any party's claim or defense. Information within the scope of discovery need not be admissible in evidence to be discoverable. Relevance is still to be construed broadly to encompass any matter that bears on or that reasonably could lead to other matters that could bear on any party's claim or defense.

8:16State Farm Mutual Auto Insurance Company versus FATA, number 14, Civ 979, 2 WHP JCF 2015, WL 7871037 at 2 SDNY December 3rd, 2015, granting motion to compel. If the opposing party objects to producing the documents, the party seeking production can file a motion to compel with a court pursuant of FedR Civ P37 against this backdrop of broad discovery rights, Maxwell has refused to produce responsive documents. B, Maxwell's general objections fail. The centerpiece of Maxwell's general objections is her disingenuous limitation of her discovery responses to a short window of time that she has unilaterally selected. Maxwell wrongfully attempts to limit discovery to the month of December 30th, 2014 through January 31st, 2015 when her defamatory statement was issued

9:18and 1999 through 2002. Maxwell's time period limitation clearly violates both the letter and spirit of rule 26. For example, a communication by Maxwell's press agent regarding the plaintiff is just as relevant if it was made on February 1st, 2015, as the one that was made on January 3rd, 2015 and is clearly discoverable. These communications with her press agent are key documents in this case and the sole claim concerns Ms. Maxwell defaming Ms. Roberts in the press. Yet Maxwell has arbitrarily refused to produce highly relevant discovery. The abuse at issue in this case is alleged to have started in or around 1999 and there are relevant documents and communication from that point to the present and that Maxwell continued to associate with convicted pedophile Jeffrey Epstein up until at least 2015 as evidenced by her privilege log see McCauley declaration at exhibit three, Maxwell's privilege log.

10:19Accordingly plaintiff defined the relevant period for purposes of her request for production as 1999 through present. While that may seem like a substantial period of time, all of the publicly available documents demonstrate that the whole period is highly relevant to the sexual abuse allegations. For example, the flight log demonstrates that Maxwell was flying on Jeffrey Epstein's plans over 360 times from 1999 to 2005. In addition, Maxwell flew with plaintiff when she was a minor child in 2000 on Jeffrey Epstein's plans. The flight logs reveal that Maxwell continued to actively travel with Jeffrey Epstein and other unidentified female passengers through at least as late as September 5, 2005. See McCauley declaration at exhibit four. Looking for excitement? Chamba Casino is here. Play any time, play anywhere. Play on the train, play at the store, play at home, play when you're bored. Play today for your chance to win

11:20and get daily bonuses when you log in. So why are you waiting for, don't delay? Chamba Casino is free to play. Experience social gameplay like never before. Go to Chamba Casino right now to play hundreds of games, including online slots, bingo, slingo, and more. Live the Chamba Life at chambacasino.com. 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 Bathamette or at worst, 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. Moreover, there is critical activity relevant to the abuse allegations that will help you get your podcasts.

12:21We are the daily conspiracy podcast. Because reptilians don't take days off. Moreover, there is critical activity relevant to the abuse allegations, happening in the mid-2000s as evidenced by the Palm Beach Police Report that identified over 30 underage girls who were being victimized during that time period. In addition, how staff identifies Maxwell as the person in charge during this time period, Sima Kali Declaration at Exhibit 5, Alfredo Rodriguez deposition transcript at 24 and 25. The years of the mid-late, because that is during the time when convicted sex offender Jeffrey Epstein entered his plea with the government. Law enforcement conducted a trash pull from Jeffrey Epstein's residence in Florida and uncovered his house message pads. The message pads reveal that in 2004, Maxwell was coordinating training with underage girls as indicated by the redactions in the message pads.

13:23Sima Kali Declaration at Exhibit 6, Maxwell was also organizing massages for Epstein in 2004 with underage girls and indicating which girls she had lined up on given days. Sima Kali Declaration at Exhibit 6, plaintiff here received a victim notification letter on September 9, 2008. Sima Kali Declaration at Exhibit 7, in 2009 an attorney sought Maxwell's deposition in connection with various sexual abuse allegations and Maxwell dodged the deposition claiming that her mother was ill, and that she would be traveling outside the country with no plans of returning. Despite this claim to avoid her deposition, she was then photographed thereafter at Chelsea Clinton's wedding in Rhinebeck, New York. Oh well, isn't that convenient? Sima Kali Declaration at Composite 8, Maxwell Deposition Notice, Sapena and cancellation payment notice, and January 13, 2015, Daily Mail article with photograph.

14:25In 2011 Maxwell started issuing press statements through her agent Ross Gal. The offending defamatory statement was issued on January 3, 2015. As demonstrated by the timeline discussed above, any documents that Maxwell has from the period of 1999 to the present are highly relevant. Ms. Roberts respectfully requests that this court direct Maxwell to produce all responsive documents for the time period from 1999 to the present. Defended Maxwell has also asserted fundamentally and proper general objections, which should be overruled. American Rock Salt Company LLC versus North Folk, Southern Company 228FRD 426432, WDNY 2004, generalized objections that discovery requests are vague, overly broad, or unduly burdensome or not acceptable, and will be overruled. Maxwell's general objection to producing material that implicates privacy interests is equally misplaced.

15:26Maxwell does not have a privacy interest in the illegal sexual abuse and trafficking of Ms. Roberts and other minors, nor does she have a privacy interest in the communications with her co-conspirators, including convicted sex offender Jeffrey Epstein, and others. See Zorn versus How? 276 AD 2D 51 57 16 NYS 2D 128 133 2000. Finding no legitimate privacy interests in illegal activity. Unsurprisingly, Maxwell cites no authority that would shield the production of those documents. These documents are responsive and relevant. The only proper objection Maxwell can make is an assertion of her Fifth Amendment privilege failing that assertion she must produce them. Furthermore, Maxwell claims that prior to this litigation, she has long had a practice of deleting emails after they have been read. First, Ms. Roberts is entitled to a forensic examination of Ms. Maxwell's personal computers and devices

16:27to recover deleted emails and to discovery. When and if Maxwell has performed a swipe of her computer devices to permanently destroy deleted emails, while hanging out with Hillary Clinton, she probably learned from the master, huh? Second, in her motion to dismiss, Maxwell claims that both 2011 and 2015 she anticipated litigation against tabloids. Specifically, she stated that in 2011 litigation was forthcoming and in 2015, she made her press release pertinent to anticipated good faith litigation. When litigation is anticipated, it is incumbent on the party to preserve documents. C. Zublokai versus UBS Warburg LLC 220FRD2122118SDNY2003. Once a party reasonably anticipates litigation, it must ensure the preservation of relevant documents. Additionally, if Maxwell purposefully destroyed documents in 2015, this court can instruct the jury

17:29to make an adverse inference against Maxwell or enter a default judgment in favor of Ms. Roberts. C. Rule 37E2BC Federal Rule Civ P. If electronically stored information that should have been preserved in the anticipation or a conduct of litigation is lost because a party failed to take reasonable steps to preserve it, and it cannot be restored or replaced through additional discovery, the court, upon finding that the party acted with the intent to deprive another party of the information use in the litigation may instruct the jury that it may or must presume the information was unfavorable to the party or dismiss the action or enter a default judgment. Similarly, Maxwell was served with a subpoena, on September 21, 2009, seeking her testimony in relation to Epstein's underage sex ring, C. McCauley Declaration at Composite Exhibit 8, 2009, subpoena issued to Maxwell. Maxwell avoided that deposition by falsely claiming

18:30to be out of the country she was instead photographed at Chelsea Clinton's New York wedding, C. Composite Exhibit 8. Pursuant to that subpoena, Maxwell, was placed on notice that her documents were relevant depending litigation. All of these events triggering her duty to preserve documents centered on Maxwell's role in Epstein's sex crimes. Therefore, all of the documents she had a duty to preserve are relevant to this litigation. Defended Maxwell must produce these documents or explain to the court when and why they were destroyed. All right, we're going to wrap up right there and in the next episode, dealing with this topic, 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. In this episode, we're diving right back in to Virginia Roberts and her motion to have Maxwell reduce documents, subject to improper objection. Maxwell's specific objections fail.

19:31Part C. One, request number one, all documents relating to communications with Jeffrey Epstein from 1999 to present. A. Maxwell's response. Maxwell objects to this request on the grounds that it is overly broad and unduly burdensome and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Maxwell further objects to this request to the extent it seeks documents or information protected by the attorney client privilege. The work product doctrine, the common interest privilege, or any other applicable privilege. Subject two and without waving, the above objections, Maxwell, is withholding documents outside of the relevant periods described in paragraph 15 Supra and is withholding production of documents that are privileged, pursuant to a common interest agreement. B. Maxwell's objections fail as a request seeks relevant discovery. Maxwell must produce documents

20:32for the entire relevant period as discussed above. Communications with convicted sex offender Jeffrey Epstein, for whom defendant Maxwell is alleged to have assisted him with sexual trafficking activities are of the highest relevance in this case and must be produced. Additionally, Maxwell has asserted an improper privilege with regard to these documents which is addressed fully in plaintiff's motion to compel foreign proper claims of privilege. Two, request number three. All documents relating to communications with Andrew, Albert Christian Edward, Duke of York, aka Prince Andrew, from 1999 to the present. A. Maxwell's response. Maxwell objects to this request on the grounds that it is overly broad and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Maxwell further objects to this request to the extent it seeks documents or information protected by the attorney client privilege, the work product doctrine,

21:33or any other applicable privilege. Maxwell also objects to this request to the extent it implicates her right to privacy. Gateway Logistics Incorporated vs. Smay302P.3D235 Colorado 2013 FedR Evidence 501 Subject two, and without waiving the above objections, Maxwell will produce non-privileged documents responsive to this request limited to the relevant periods described in paragraph 15, Supra, and with private phone numbers and relevant information redacted. Maxwell is withholding production of documents outside of such relevant periods. B. Maxwell's objections fail. As the request seeks relevant discovery, defendant Maxwell's communications with Prince Andrew for the entire relevant period are relevant to this litigation. Maxwell is alleged to have traffic Ms. Roberts to Prince Andrew when Ms. Roberts was a minor. Indeed, there is photographic evidence

22:34of Prince Andrew with his arm around Virginia's waist, standing next to Maxwell, and Maxwell's London residents. When Virginia was a minor child, in the other email defendant did produce in response to the request for production, Maxwell instructs Prince Andrew to call me after Prince Andrew says he needs to speak about Virginia. See McCauley Declaration at Exhibit 9. Ms. Roberts is entitled to all the communications between Maxwell and Prince Andrew, not only to show the communications between them, regarding or trafficking, but also possible communications between them that would establish Maxwell. Furnishing him with other females or discussing other individuals who may have been involved with this activity. Three, request number six. All documents relating to communication with any of the following individuals from 1999 to the present. M. E. Taylor, Sarah Kellen, Eva Dubin, Glenn Dubin, Jean-Luc Brunel, and Nadia Martin-Cova. Maxwell's response. Maxwell objects to this request on the grounds

23:35that 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 and not reasonably calculated to lead to the discovery of admissible evidence. Subject two, and without waving the above objections, Maxwell is withholding production of documents relating to communications with Nadia Martin-Cova, Sarah Kellen, and Eva Dubin that are outside the relevant periods described in paragraph 15, Supra. Maxwell has been unable to locate any such documents relating to Ms. Martin-Cova, Ms. Kellen, Ms. Dubin, within the relevant periods. Maxwell has also been unable to locate any such documents responsive to this request relating to Glenn Dubin, Jean-Luc Brunel, or Emmy Taylor for any time period. B, Maxwell's objections fail

24:35as the request seeks relevant discovery. Ms. Kellen was previously deposed, regarding Jeffrey Epstein's underage sex ring, when asked about Maxwell's involvement in the sex trafficking, Ms. Kellen, asserted her fifth amendment privilege and refused to answer. Ms. Kellen's assertion implicates Maxwell in sex trafficking activity. Question, would you agree with me that Maxwell provides underage girls for Mr. Epstein for sex, answer, upon the instruction of my lawyer, I must invoke my fifth amendment privilege. See McCauley Declaration at Exhibit 1, March 24, 2010, Deposition Transcript of Sarah Kellen at 103. Maxwell's communications with Ms. Kellen at any time during the original relevant period are relevant to this actual abuse suffered by Ms. Roberts and others at the hands of Maxwell, and should not be withheld. Moreover, flight logs demonstrate that Sarah Kellen and Maxwell flew together multiple times, including with Ms. Roberts.

25:35See McCauley Declaration at Exhibit 4. Similarly, Nadia Marcincova was a co-conspirator of Maxwell and Epstein and communicated with them frequently as evidenced by the message pads law enforcement retrieved from Epstein's residents. See McCauley Declaration at Exhibit 6. Nadia Marcincova also traveled on Jeffrey Epstein's planes with Maxwell. See McCauley Declaration at Exhibit 4. Flight logs. Similarly, Emmy Taylor was Maxwell's assistant during this time frame and also traveled on Jeffrey Epstein's planes with Ms. Roberts. See McCauley Declaration at Exhibit 4. These communications are relevant for the entire original relevant period and Maxwell must produce them. Regarding Glenn and Eva Dubin, Flight logs demonstrate that they also traveled on Epstein's planes with Maxwell. Maxwell has acknowledged having communications with Eva Dubin, but she is refusing to turn them over. Eva and Glenn regularly place calls to Jeffrey Epstein and Maxwell

26:35as evidenced by police report trash pulls of message pads. See McCauley Declaration at Exhibit 6. Maxwell's communications with Glenn and Eva Dubin are relevant for the entire original relevant period and should all be produced. 4. Request Number 7. All videotapes, audio tapes, photographs, any other rent or electronic media relating to females under the age of 18 from the time period of 1999 to the present. Maxwell's response. Maxwell objects to this request on the grounds that it is overly broad, unduly burdensome, and 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. Subject 2 and without waving the above objections, Maxwell, has been unable to locate any documents

27:36responsive to this request which relate or pertain to plaintiff or any of the witnesses identified by plaintiff in a rule 26 disclosures. Maxwell is withholding production of other documents responsive to this request, including things like mainstream newspapers, magazines, videos, DVDs, or other media or family photographs which contain depictions of female children, including Maxwell herself as a child. Hey, it's Cole Swindell. After I give everything I've got to land a perfect vocal, I usually take five before jumping into the next track, and I've learned exactly how to recharge in that time. Some folks grab coffee, I hit a quick good lookspin. Next thing you know, the break is just as fun as land down the track. A better break makes for a better take. Need a break? Let's chumble. No purchase necessary, BGW Group void were prohibited by law, 21 plus TNC supply, sponsored by Chumba Casino. B, Maxwell's objections fail,

28:36as the request seeks relevant discovery to clarify, Miss Roberts is not seeking the depictions of children under the age of 18, that may include Maxwell as a child or Maxwell's relatives as children. Nor is Miss Roberts seeking mainstream images that are legally available, such as in mainstream newspapers, magazines, videos, or DVDs. Instead, Miss Roberts is seeking the depictions of underage girls possessed by Maxwell. For example, Alfredo Rodriguez, a former household manager for Epstein, testified that Maxwell kept images of naked girls on our personal computer, whose identities are unknown to Miss Roberts. Question, did they appear to be doing anything sexual? Answer, yes ma'am. Question, and in these instances, were these girls doing sexual things with other girls? Answer, yes ma'am. Question, and I'm still talking about the pictures on Maxwell's computer. Answer, yes ma'am. See McCauley Declaration at Exhibit 5.

29:37Alfredo Rodriguez, August 7, 2009. Accordingly, Maxwell's depictions of females under the age of 18, Ghostamist Roberts claims of sexual abuse and should be produced for the entire original relevant period. These pictures would reveal which underage girls Maxwell was interacting with and photographing or videotaping, which is highly relevant to this case. Importantly, this request is not limited to depictions of Miss Roberts or the individuals in Miss Roberts' rule 26 disclosures as Maxwell tries to assert in her objection. 5. Request numbers 8 and 33. All documents relating to your travel from the period of 1999 to present, including but not limited to any travel on Jeffrey Epstein's planes, commercial flights, helicopters, passport records, records indicating passengers, traveling with you, hotel records, and credit card receipts. Maxwell's response. Maxwell objects to this request on the grounds

30:37that 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 and not reasonably calculated to lead to the discovery of admissible evidence. Maxwell also objects to this request to the extended implicator right to privacy. Gateway logistics incorporated versus SMAe 302, P.3D 235 Colorado 2013, Fed.R Evidence 501. Subject 2, and without waiving, the above objections, Maxwell, is withholding production of documents outside of the relevant periods described in paragraph 15. Supra and is withholding documents within the relevant period that are private and are not reasonably calculated to lead to discovery of admissible evidence. The documents reflecting flight plans

31:37in Maxwell's possession do not identify passengers or manifests. All right folks, we're going to wrap up this episode here and in the next episode talking about the topic we'll pick up where we left off. All of the information that goes with this episode can be found in the description box.