giuffre-maxwell
gov.uscourts.nysd.447706.931.0
15 pg
…with respect to those documents. They've objected
9 to modification with respect to two categories. One set of
10 them are a bunch of photographs. I have looked at them,
11 nothing prurient about them, they all predate the…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…5, 14: Communications with Witnesses Related to this Case ...................... 3
B. Request 2: Fee Agreements ................................................................................................ 4
C. Request 6-7: Photographs .....................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…5, 14: Communications with Witnesses Related to this Case ...................... 3
B. Request 2: Fee Agreements ................................................................................................ 4
C. Request 6-7: Photographs .....................................................................................…
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.447706.35.0
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.447706.363.6
15 pg
…See Exhibit 6, Request no. 16.
Defendant also demands that this non-party produce photographs and videos of her as a minor
child while she was being sexually trafficked by convicted sex offender Jeffrey Epstein. See
Exhibit 6, Request nos…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…privileged documents bates labelled
GIUFFRE000001 to GIUFFRE003190 and will continue to supplement this production.
6. All photographs or video containing any image of You and the following
individuals. To the extent You have such photographs and video in their original…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…Despite these obstacles, non-party Ransome complied by producing
over 235 pages of highly relevant documents which include photographic evidence and e-mail
communications during the mid-2000s that directly contradict Defendant’s deposition testimony.
For example, Defendant swore under…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…they went out and badgered the victims, they
went through all social media, found photographs of these victims either holding an alcoholic beverage and calling
them -- you see they're not saints. You know, they're consuming alcohol under the…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…confidentiality designation of police reports made when individuals
attempted to break into Ms. Giuffre’s home that she shared with her minor children. The police
report shows photographs of Ms. Giuffre's former home, which implicates her privacy interests.
Therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…Ms. Giuffre is also withholding electronic
renditions of photographs that depict the faces of her minor children, including school portraits
and other photographs taken that reveal the faces of her minor children.
Subjection to and without waiving the above objections…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…is pretty spiritual so he said the
best thing to do would be burn them.
Q. Is there anything you decided to keep and not burn?
A. Just the photographs.
Q. Anything else that you can think of?
A. Photographs…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…to
accomplish that purpose. Ms. Ransome also produced numerous photographs of her travels to
Epstein’s Little Saint James Island, which unequivocally establish Defendant’s presence during the
years that she swore under oath that she was hardly around. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…to
accomplish that purpose. Ms. Ransome also produced numerous photographs of her travels to
Epstein’s Little Saint James Island, which unequivocally establish Defendant’s presence during the
years that she swore under oath that she was hardly around. Ms…
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.447706.1331.35
11 pg
…and description that is or has been in Your
possession, custody or control, or of which You have knowledge, including but not
limited to, emails, text messages, instant messages, videotapes, photographs, notes,
letters, memoranda, forms, books, magazines, resumes, notebooks, ledgers…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…documents in non-party Sarah Ransome’s
possession are attached hereto as RANSOME_000001-000016, which should be treated as
Confidential pursuant to the parties’ Protective Order.
6. Any photographs containing any image of Virginia Roberts, Ghislaine Maxwell, Jeffrey Epstein,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.12
35 pg
…be able to please him as much as he needed and
16 that is why there were other girls around.
17 Q. Did there ever come a time -- did you ever
18 take a photography class in school?
19 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…Ms. Giuffre is also withholding electronic
renditions of photographs that depict the faces of her minor children, including school portraits
and other photographs taken that reveal the faces of her minor children.
Subjection to and without waiving the above objections…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…se No. . . : 1-05 - 000368 (Continued)
photographed by CSI Pavlik and then videotaped by myself. The search
was concluded at approximately 3:05 p.m. whereupon Detective Recarey
and I were the last two officers in the house. Upon securing…
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