giuffre-maxwell
gov.uscourts.nysd.447706.908.0
4 pg
…RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
MOTION FOR ORDER DIRECTING THE FBI IN MIAMI, FLORIDA
TO PRODUCE PHOTOGRAPHS TO THE COURT
In 2011, the Federal Bureau of Investigation (“FBI”) met with Plaintiff Virginia Giuffre
at the United States Consulate in Sydney…
giuffre-maxwell
gov.uscourts.nysd.447706.1158.2
8 pg
…Case 1:15-cv-07433-LAP Document 1158-2 Filed 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1158.1
8 pg
…Case 1:15-cv-07433-LAP Document 1158-1 Filed 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.
IPlace: IDate and Time:
The following provisions of Fed. R. Civ…
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.447706.1331.9
12 pg
…on
April 22nd, 2016
18
Plaintiff's Exhibit JE2 Document with titles 90
19 of books
20 Plaintiff's Exhibit JE3 Photograph depicting 101
Prince Andrew,
21 …
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.447706.1202.3_1
4 pg
…1:15-cv-07433-LAP Document 1202-3 Filed 01/27/21 Page 2 of 4
Case 1:15-cv-07433-LAP Document 1202-3 Filed 01/27/21 Page 3 of 4
or other document transmissions or photography…
giuffre-maxwell
gov.uscourts.nysd.447706.1158.0
17 pg
…Case 1:15-cv-07433-LAP Document 1158-1 Filed 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…
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…
giuffre-maxwell
1320-30
27 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.30
27 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.6
9 pg
…16 When you went into the bedroom of Jeffrey
17 Epstein, everything was removed from the -- the
18 shelves, from the armoire.
19 Q. Did you find nude photographs of girls?
20 A. Yes.
21 Q. All right.
22 And…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 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.447706.223.1
14 pg
…correspondence, memoranda, notes,
notations, diaries, papers, books, accounts, newspaper and magazine articles, advertisements,
photographs, videos, notebooks, ledgers, letters, telegrams, cables, telex messages, facsimiles,
2
Case 1:15-cv-07433-RWS Document 223-1 Filed 0…
giuffre-maxwell
1320-32
27 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…
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