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.447706.1330.9
6 pg
…01144. These
emails were collected as responsive to Plaintiff’s First Request for Production of
Documents in February 2016 but through clerical error were not produced at that time
or following the Court’s in camera review in April. A…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.7
9 pg
…or did they typically wear normal
24 clothes?
25 A. Normal clothes .
MAGNA8 LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1327-7 Filed 01/05/24 Page 5 of 9
Page 34
1 camera?
2 MS . MENNINGER: Objection…
giuffre-maxwell
gov.uscourts.nysd.447706.111.2
5 pg
…connect to his Rugged TBT Drive
(e.g. laptop, digital camera). Defendant’s counsel and/or representative must be given an
opportunity to inspect the port interfaces which are also in question. Plaintiff’s devices are to
remain within his…
giuffre-maxwell
gov.uscourts.nysd.447706.1158.0
17 pg
…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. She
4 was constantly taking photographs. Not only
5 photographs…
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.447706.1325.9
10 pg
…no, but then you
16 also previously stated that during the camera
17 incident that Maxwell had talked to you about not
18 finishing the job.
19 Did you understand "not finishing the job"
20 meaning bringing Jeffrey to orgasm…
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.447706.1218.14
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.447706.1257.22
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.447706.1320.26
10 pg
…no, but then you
16 also previously stated that during the camera
17 incident that Maxwell had talked to you about not
18 finishing the job.
19 Did you understand "not finishing the job"
20 meaning bringing Jeffrey to orgasm…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.6
9 pg
…CPU s hard disk .
The ends of the RCA jacks were unattached at the time of the search
and no external camera was located within this room.
The located on the right side of a desk that held a flat…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
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.447706.1328.12
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.3
21 pg
…legal advice
to his client. To the extent that any of Barden’s communications with Defendant revealed his
legal strategy work product (which the Court can easily determine based on its previous in
camera review), the disclosures in the Barden…