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Yes, this problem still persists. I have worked all my life with UNIX terminal, I know ’sudo rm’ by heart... nothing.
I would recommend —before going wild with risky rm commands —that one closely examines a full listing of all trashed items first, to see precisely what is where... and which owner/group/flags/perms/ACLs the problem items actually have.

This command will measure trash size everywhere (except /var/root/.Trash):

sudo du -sch /Volumes/*/{,Users/*/}.Trash*

...and this one lists all the gory details:

sudo ls -GlObFReak /Volumes/*/{,Users/*/}.Trash*

[note: those commands assume we're running a Bash shell, or one capable of doing the brace expansions.]

If some file(s) supposedly can't be deleted... then at least let everyone see exactly what's going on.

[edit: hopefully the external volume isn't mounted as read-only.]
 
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