giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…be looking over her shoulder—that is, for reporters lurking in the
bushes, ready to pounce with voice recorders and cameras in hand. In recent months,
journalists have searched high and low for Maxwell, who had already been
maintaining a…
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.447706.1328.2
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.447706.1330.7
18 pg
…pulls. We stopped the
MAGNA9 LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1330-7 Filed 01/05/24 Page 15 of 18
Page 214
1 JOSEPH RECAREY - CONFIDENTIAL
2 Q. And so these were video cameras?
3 A…
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.447706.148.0
9 pg
…9
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------X
......
.........................................
VIRGINIA L. GIUFFRE,
Pla…
giuffre-maxwell
gov.uscourts.nysd.447706.1158.2
8 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.447706.1158.1
8 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.447706.1087.0
4 pg
…no. 1084.)
Prior to receiving Ms. Maxwell’s latest last-minute request,
the Court conducted an in camera review of Plaintiff Virginia
Giuffre’s proposed redactions to the materials, which are
described in Ms. Giuffre’s letter dated July 29…
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.447706.139.0
7 pg
…L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF, VIRGINIA GIUFFRE’S REDACTED BRIEF IN SUPPORT OF THE
PRIVILEGE CLAIMED FOR HER IN CAMERA SUBMISSION
Plaintiff Virginia L. Giuffre, by…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.1
13 pg
…Filed
Filed
07/30/20
08/10/20Page
Page
4 of
…
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.447706.1097.0_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.447706.1100.0
16 pg
…modification of the Protective Order
in the Criminal Action from Judge Nathan forthwith to permit sharing the information with
this Court, ex parte and in camera if necessary, and with the Second Circuit (likewise under
seal if necessary).
Case…
giuffre-maxwell
gov.uscourts.nysd.447706.140.3
4 pg
…at issue; rather, an in camera
assessment of the disputed documents was deemed necessary to weigh whether the particular requested documents are
shielded by a public-interest privilege against disclosure of confidential communications. 4
The public interest privilege applied, in…
giuffre-maxwell
gov.uscourts.nysd.447706.102.0
9 pg
…current law enforcement investigation – Ms. Giuffre respectfully requests leave to provide such
information to the Court via an ex parte, in camera submission.
I. Background
As the Court is well aware from previously filed pleadings, this is a single-count
…
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…