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.447706.1328.2
26 pg
…Pretty much trash pulls. We stopped the
Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 15 of 26
Page 214
1 JOSEPH RECAREY - CONFIDENTIAL
2 Q. And so these were video cameras?
3 A. …
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.447706.235.2
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.447706.1328.30
40 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.447706.1257.22
40 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.447706.1078.5
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.447706.1328.15
6 pg
…21 BY MR. KUVIN: 21 MR. KUVIN: All me to show it to the
22 Q. Were you ever promised anything regarding 22 camera first.
23 your modeling career by Jean-Luc Brunel? 23 MR. RHEINHART: Okay.
24 MR. RHEINHART:…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…s hand on their
respective breasts. (p. 83)
! Johanna testified that Maxwell bought a camera for her and asked her to take naked
pictures of herself for Jeffrey. (p. 145)
! Johanna testified that Maxwell would not give her the camera…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…to the world that she “cried rape,”13 and to
humiliate her family (including three minor children) by publicizing she was the victim of
domestic abuse in 2015. As the Court saw during its in camera review, Defendant and Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.29
35 pg
…of 35
Page 106
1 sitting, and I believe Jeffrey took the photo. I
2 was just sitting on a couch upstairs in the
3 bathroom.
4 Q. It wasn't taken by a hidden camera?
5 A. No. No…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.12
179 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.447706.46.0
22 pg
…subject matter” of the communications. Plaintiff cites three cases from the Southern District of
15
New York, describes them as “controlling precedent” and demands an in camera review of the
subject documents.
First, Ms. Maxwell’s privilege log satisfies the…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…COURT: All right. You will recall that it was a
19 demand, a request for production, and I said submit it in
20 camera to see if it is relevant. It was just submitted just
21 recently, parenthetically, two days…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.18_1
40 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.447706.78.0
30 pg
…to disclose the information.
Ms. Giuffre can immediately provide clear evidence to this Court of how the investigation
would be impaired if the Court directs her to make an in camera submission to this Court. In
evaluating the competing interests…
giuffre-maxwell
gov.uscourts.nysd.447706.43.0
15 pg
…at *4 (noting that “[i]n camera
review is ‘a practice both long-standing and routine in cases involving claims of privilege.”).
Defendant’s current attempt to stall discovery is through the submission of improper,
sweeping objections alleging overbreadth of…
giuffre-maxwell
1320-10
28 pg
…s hand on their
respective breasts. (p. 83)
! Johanna testified that Maxwell bought a camera for her and asked her to take naked
pictures of herself for Jeffrey. (p. 145)
! Johanna testified that Maxwell would not give her the camera…
giuffre-maxwell
1320-30
27 pg
… I think it just I
23 don't remember. I just remember there's a date on
24 it.
25 Q Whose camera was it taken with?
VIRGINIA GIUFFRE 5/3/2016 210
Agren Blando
Case 1:15-cv…
giuffre-maxwell
1320-12
179 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…