giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…location set forth below. so Lhal lhc ,·cquesling party
rnay inspect, measure, survey, photograph, tesr, or sample the property or any des ignated object or operation on it.
Place: IDBtc and r;.,,c·
lhe fi.)llowing provisions of Fed . R…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…description that is or has been in Your
possession, custody or control, or of which You have knowledge, including but not limited to, e-
mails, text messages, instant messages, videotapes, photographs, notes, letters, memoranda,
forms, books, magazines, resumes, notebooks, ledgers…
giuffre-maxwell
gov.uscourts.nysd.447706.55.0
5 pg
…copy of the March 24, 2010
Deposition Transcript of Sarah Kellen.
14. Attached hereto as Exhibit 12, is a true and correct copy of a photograph taken by
Ms. Giuffre of Defendant Ghislaine Maxwell, Emmy Taylor, and Jeffrey Epstein while…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.6
134 pg
…P.A. 19 of books
One Clearlake Centre, Suite 1400 20 Plaintiff's Exhibit JE3 Photograph depicting 101
20 250 Australian Avenue South Prince Andrew,
West Palm Beach, Florida 33401 21 …
giuffre-maxwell
gov.uscourts.nysd.447706.1338.1
134 pg
…P.A. 19 of books
One Clearlake Centre, Suite 1400 20 Plaintiff's Exhibit JE3 Photograph depicting 101
20 250 Australian Avenue South Prince Andrew,
West Palm Beach, Florida 33401 21 …
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…as
a convicted sex offender;
She loved to take nude photographs of girls and allegedly took many of the pictures
displayed on the walls of Epstein’s mansions.
According to one witness, she felt ‘indebted’ to Epstein for helping her…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…when they went out and badgered the
21 victims, they went through all social media,
22 found photographs of these victims either
23 holding an alcoholic beverage and calling
24 them -- you see they're not saints. You know,
25 …
giuffre-maxwell
gov.uscourts.nysd.447706.928.0
11 pg
…and cannot be considered here.’”
(citing Fonte v. Bd. of Managers of Cont'l Towers Condo., 848 F.2d 24, 25 (2d Cir. 1988))); Bill
Diodato Photography LLC v. Avon Prod., Inc., No. 12 CIV. 847 RWS, 2012 WL 3240428…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…by any means, regardless of
technology or form. It includes, without limitation, correspondence, memoranda, notes,
notations, diaries, papers, books, accounts, newspaper and magazine articles, advertisements,
photographs, videos, notebooks, ledgers, letters, telegrams, cables, telex messages, facsimiles,
contracts, offers, agreeme…
giuffre-maxwell
gov.uscourts.nysd.447706.55.12
21 pg
…6 5
7 STUART MERMELSTEIN, ESQUIRE
MERMELSTEIN & HOROWITZ, P.A.
6 Exhibit number 1 Photographs 45
8 18205 Biscayne Boulevar…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…memoranda, notes,
notations, diaries, papers, books, accounts, newspaper and magazine articles, advertisements,
1
Case 1:15-cv-07433-LAP Document 1219-29 Filed 07/15/21 Page 6 of 24
photographs, videos, notebooks, ledgers, letters, telegrams, cables, telex messages…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…of my lawyer, I must invoke my Fifth Amendment privilege.
Q. Take a look at what we marked as Exhibit 10. Do you recognize the two people in
that photograph?
A. On the instruction of my lawyer, I must invoke…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…there.” Cassell Decl., ¶ 21(k). He then asserts that “Alessi was able to identify a
photograph of Ms. Giuffre as someone who was at the mansion as [sic] the same time as
Dershowitz.” Id. Mr. Cassell’s characterization of the…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…To
wit, Plaintiff was paid more than $100,000 for her false story to the Daily Mail as well as the sale
of a photograph purporting to be of herself and Prince Andrew. Plaintiff then further sought
public attention to…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…visited
Epstein's Palm Beach mansion four or five times a year, staying two or three days
when he went there — and Alessi was able to identify a photograph of Ms. Giuffre
as someone who was at the mansion as…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…there.” Cassell Decl., ¶ 21(k). He then asserts that “Alessi was able to identify a
photograph of Ms. Giuffre as someone who was at the mansion as [sic] the same time as
Dershowitz.” Id. Mr. Cassell’s characterization of the…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.29
35 pg
…05/24 Page 21 of 35
Page 103
1 BY MS. MENNINGER:
2 Q. You were asked some questions with
3 Ms. McCawley about nude photographs that were
4 present in the home? Homes?
5 A. Uh-huh.
6 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.43
8 pg
…at the house, frequent guests,
12 CONTINUED INDEX OF EXHIBITS
13 PLAINTIFF'S PAGE 15 friends from Harvard.
14 3 Drawing 315 16 Do you remember that testimony?
i6 5 Photo9raph 33…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…her the witness --
19 we served the witness with a subpoena accepted by counsel for
20 plaintiff, and approximately 18 pages of documents were
21 produced and some photographs. The photographs apparently were
22 given to her by another person…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.3
7 pg
…it?
21 A Not in front of me, no.
22 Q Where is the original of the photograph
23 that has been widely circulated in the press of you
24 with Prince Andrew?
25 A I probably still have it…