The Epstein Chronicles

Virginia Roberts And Her 2nd Supplemental Response To Maxwell's Discovery Request (Part 5) (10/30/26)

The Epstein Chronicles

Show Notes

In her April 29, 2016 second amended supplemental discovery response, Virginia Giuffre pushed back aggressively against Ghislaine Maxwell’s effort to obtain an enormous range of information about her personal life, allegations, relationships and communications. Giuffre argued that many of Maxwell’s interrogatories violated the Southern District of New York’s local discovery rules because they went well beyond basic identification of witnesses, damages and relevant documents and were being used prematurely as a substitute for depositions or document requests. She repeatedly objected that Maxwell’s demands were overly broad, unduly burdensome, irrelevant, invasive and, in some instances, designed to harass or intimidate her. Maxwell sought materials concerning Giuffre’s communications with Jeffrey Epstein, Maxwell, Alan Dershowitz, Prince Andrew and others; photographs and video involving those people; records surrounding her attorneys, family, marriage and Australian naturalization; writings about Epstein and Maxwell; and records connected to Giuffre’s advocacy organization Victims Refuse Silence. Giuffre also invoked attorney-client privilege, work-product protection and other privileges where applicable while maintaining that she had already produced thousands of pages of responsive material.

Giuffre nevertheless agreed to continue producing non-privileged responsive records, repeatedly noting that she had already turned over documents Bates-numbered GIUFFRE000001 through GIUFFRE005353 and would supplement those productions. At the same time, she drew hard lines around particularly sensitive material, withholding privileged documents, information connected to ongoing law-enforcement investigations and photographs revealing the faces of her minor children. She also argued that Maxwell was demanding some information that was already within Maxwell’s or Epstein’s possession while Maxwell herself was asserting privilege over related material. One of Maxwell’s broadest requests sought virtually every communication from 1998 forward concerning Maxwell, Epstein, Dershowitz, Prince Andrew, Bill Clinton and other identified individuals; Giuffre objected that such a demand swept far beyond what was reasonably necessary for the defamation case. Taken as a whole, the filing showed how fiercely the two sides were battling over discovery in 2016: Maxwell was attempting to probe nearly every aspect of Giuffre’s allegations, history and relationships, while Giuffre was cooperating with document production but arguing that Maxwell’s lawyers were using discovery to intrude into areas that had little legitimate connection to the claims being litigated.

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