giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…Dustin Hoffman, Michael Bloomberg and Richard Branson.
Bill Clinton in 1994.
AP
ln a 2006 court filing, Palm Beach police noted that a search of Epstein's home uncovered two hidden
cameras. The Mirror reported that in 2015, a 6…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…or travel with them. Id.
He did not observe any child pornography or any photos of naked women in the home
when he went to help install cameras to catch a thief in Mr. Epstein’s home in 2002…
giuffre-maxwell
gov.uscourts.nysd.447706.589.0
24 pg
…2d 16, 22 (2d Cir. 1984) - Televised coverage
not allowed
In addition, Cernovich cites cases concerning cameras in the courtroom – cases which have
absolutely no bearing on the issue at hand. See Katzman v. Victoria’s Secret Catalogue, 923 F…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
…break-out/
82 https://filmdaily.co/obsessions/true-crime/maxwell-bail/
83 https://filmdaily.co/obsessions/true-crime/maxwell-prison-cameras/
84 https://www.nbcnewyork.com/news/ghislaine-maxwell-deposition-released-denies-epstein-had-sex-with-minors/2683145/
85 https:/…
giuffre-maxwell
gov.uscourts.nysd.447706.179.0
22 pg
…of 22
TABLE OF CONTENTS
I. INTRODUCTION .............................................................................................................. 1
II. ARGUMENT .........................................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1109.0_1
3 pg
…Maxwell, No. 15 Civ. 7433, to
submit to the Court for in camera review their comments on
Defendant Alan Dershowitz’s request in Giuffre v. Dershowitz, No.
19 Civ. 3377, that Plaintiff Virginia Giuffre
produce to him confidential discovery materials…
giuffre-maxwell
gov.uscourts.nysd.447706.1097.0_1
6 pg
…Because those comments may
discuss information that is currently under seal in Giuffre v.
Maxwell, they will be submitted directly to the Court so that the
Court can review them in camera. Comments may be sent to the
Court’s…
giuffre-maxwell
gov.uscourts.nysd.447706.39.1
7 pg
…agrees to be bound by its provisions. All such acknowledgments shall be
retained by counsel and shall be subject to in camera review by the Court if
good cause for review is demonstrated by opposing counsel.
7. Documents are designated…
giuffre-maxwell
gov.uscourts.nysd.447706.135.0
37 pg
…Du ring argument, the Cour t
held th at in camera review was warranted for purposes of
2
.,
determining whether privilege applied to the do c um e nts in
quest i on, and Defenda…
giuffre-maxwell
gov.uscourts.nysd.447706.235.2
4 pg
…April 27th, 2016.
All documents withheld on the basis of the “public interest privilege,” other
than Plaintiff’s actual statements to any law enforcement agency, which are to
be submitted for in camera review forthwith. See Resp. to RFPs…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…asserting her Fifth Amendment
20 privilege.
21 We do have with us, your Honor, for an in camera
22 submission, if you would like it. That is the way that courts
23 have dealt with this issue in the past…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…vested any control in Mr. Epstein “in regard to key facts and subject
matter of litigation.” As the Court is well aware from review of emails submitted in
camera (and later produced to Plaintiff):
o Mr. Epstein and his counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…before it was filed in September of 2015, as
evidenced by the email communications between Dershowtiz and Defendant the Court reviewed in its in camera
review before ordering Defendant to produce them. Yet Dershowitz waited until after discovery closed and…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…Giuffre whose substance has already been
widely aired in public—including, apparently, on camera to ABC News—and which have been
widely circulated for sale to publishers and journalists. Ms. Giuffre’s efforts to gain publicity
and a book deal…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…follows: Ms. Giuffre, in accordance
with the Court’s direction at the hearing on April 21, 2016, has submitted documents to the
Court for In Camera review. Ms. Giuffre met with the FBI on or about March 17, 2011. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…the start of the hearing, Maxwell rested her elbows on a table in front of the camera
and put her head on her hands.
She appeared nervous and pensive and kept looking from side to side, as she leaned into…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…it was necessary for the rendering of legal advice, I'll
15 review those materials in camera and try to reach a decision.
16 I may need something further after I have looked at them, but I
17 think that…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.20
21 pg
…heard and the motion granted in part and denied in
part on April 21 , 20 16. Plaintiff was directed to submit the
relevant materials for in camera review. Plaintiff did so on
April 28, 2016.
Plaintiff filed her motion to…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.12
35 pg
…a time -- did you ever
18 take a photography class in school?
19 A. Yes.
20 Q. And did there ever come a time when
21 Maxwell offered to buy you a camera?
22 A. Yes.
23 MS. MENNINGER: Objection…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…That's troubling as well because we went through
2 litigation in this case about our access to alleged
3 public-interest privileged documents that were not turned over
4 to us but were submitted in camera to the Court…