giuffre-maxwell
gov.uscourts.nysd.447706.908.0
4 pg
…RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
MOTION FOR ORDER DIRECTING THE FBI IN MIAMI, FLORIDA
TO PRODUCE PHOTOGRAPHS TO THE COURT
In 2011, the Federal Bureau of Investigation (“FBI”) met with Plaintiff Virginia Giuffre
at the United States Consulate in Sydney…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…Despite these obstacles, non-party Ransome complied by producing
over 235 pages of highly relevant documents which include photographic evidence and e-mail
communications during the mid-2000s that directly contradict Defendant’s deposition testimony.
For example, Defendant swore under…
giuffre-maxwell
gov.uscourts.nysd.447706.1158.2
8 pg
…Case 1:15-cv-07433-LAP Document 1158-2 Filed 11/20/20 Page 2 of 8
Page 36
1 JOHN ALESSI
2 A. She was a -- she was very avid with
3 photographs. She had this high-tech camera…
giuffre-maxwell
gov.uscourts.nysd.447706.1158.1
8 pg
…Case 1:15-cv-07433-LAP Document 1158-1 Filed 11/20/20 Page 2 of 8
Page 36
1 JOHN ALESSI
2 A. She was a -- she was very avid with
3 photographs. She had this high-tech camera…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…se No. . . : 1-05 - 000368 (Continued)
photographed by CSI Pavlik and then videotaped by myself. The search
was concluded at approximately 3:05 p.m. whereupon Detective Recarey
and I were the last two officers in the house. Upon securing…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…se No. . . : 1-05 - 000368 (Continued)
photographed by CSI Pavlik and then videotaped by myself. The search
was concluded at approximately 3:05 p.m. whereupon Detective Recarey
and I were the last two officers in the house. Upon securing…
giuffre-maxwell
1320-13
45 pg
…se No. . . : 1-05 - 000368 (Continued)
photographed by CSI Pavlik and then videotaped by myself. The search
was concluded at approximately 3:05 p.m. whereupon Detective Recarey
and I were the last two officers in the house. Upon securing…
giuffre-maxwell
gov.uscourts.nysd.447706.909.0
3 pg
…Defendant.
________________________________/
DECLARATION OF SIGRID S. MCCAWLEY IN SUPPORT OF PLAINTIFF
VIRGINIA GIUFFRE’S MOTION FOR ORDER DIRECTING THE FBI
IN MIAMI, FLORIDA TO PRODUCE PHOTOGRAPHS TO THE COURT
I, Bradley Edwards, declare that the below is true and correct to…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.
IPlace: IDate and Time:
The following provisions of Fed. R. Civ…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…location set forth below. so Lhal lhc ,·cquesling party
rnay inspect, measure, survey, photograph, tesr, or sample the property or any des ignated object or operation on it.
Place: IDBtc and r;.,,c·
lhe fi.)llowing provisions of Fed . R…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.9
12 pg
…on
April 22nd, 2016
18
Plaintiff's Exhibit JE2 Document with titles 90
19 of books
20 Plaintiff's Exhibit JE3 Photograph depicting 101
Prince Andrew,
21 …
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…5, 14: Communications with Witnesses Related to this Case ...................... 3
B. Request 2: Fee Agreements ................................................................................................ 4
C. Request 6-7: Photographs .....................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…5, 14: Communications with Witnesses Related to this Case ...................... 3
B. Request 2: Fee Agreements ................................................................................................ 4
C. Request 6-7: Photographs .....................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…description that is or has been in Your
possession, custody or control, or of which You have knowledge, including but not limited to, e-
mails, text messages, instant messages, videotapes, photographs, notes, letters, memoranda,
forms, books, magazines, resumes, notebooks, ledgers…
giuffre-maxwell
gov.uscourts.nysd.447706.55.0
5 pg
…copy of the March 24, 2010
Deposition Transcript of Sarah Kellen.
14. Attached hereto as Exhibit 12, is a true and correct copy of a photograph taken by
Ms. Giuffre of Defendant Ghislaine Maxwell, Emmy Taylor, and Jeffrey Epstein while…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.6
134 pg
…P.A. 19 of books
One Clearlake Centre, Suite 1400 20 Plaintiff's Exhibit JE3 Photograph depicting 101
20 250 Australian Avenue South Prince Andrew,
West Palm Beach, Florida 33401 21 …
giuffre-maxwell
gov.uscourts.nysd.447706.1338.1
134 pg
…P.A. 19 of books
One Clearlake Centre, Suite 1400 20 Plaintiff's Exhibit JE3 Photograph depicting 101
20 250 Australian Avenue South Prince Andrew,
West Palm Beach, Florida 33401 21 …
giuffre-maxwell
gov.uscourts.nysd.447706.1078.3
19 pg
…MAXWELL and
Epstein were photographed together on multiple occasions,
including in the below image:
2
Case 1:15-cv-07433-LAP
Case 1:20-cr-00330-AJNDocument
Document1078-3 Filed
17 Filed 07/29/20Page
…
giuffre-maxwell
gov.uscourts.nysd.447706.931.0
15 pg
…with respect to those documents. They've objected
9 to modification with respect to two categories. One set of
10 them are a bunch of photographs. I have looked at them,
11 nothing prurient about them, they all predate the…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…CIV-
MARRA/JOHNSON, [ECF No. 291-1] (the “Federal Action”).
2. All photographs and video in the original, native format in which they were taken (not a
paper copy) of you with Alan M. Dershowitz.
3. All photographs and video…
Comments