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.447706.1328.2
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.447706.589.0
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.447706.1158.2
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.447706.1330.9
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.447706.140.3
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.447706.1158.0
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.447706.102.0
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…
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.447706.1325.9
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.447706.1328.41
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…