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Case 18-2868, Document 281, 08/09/2019, 2628234, Page58 of 66 the house had already been sanitized, revealed photographs of nudity displayed, including a photograph of Maxwell herself in the nude. See McCawley Dec. at Exhibit 44, Search Warrant Video attached to the Deposition of Recarey. Johanna Sjorberg testified that the Defendant bought her a camera for the specific purpose of her taking nude photos of herself. See McCawley Dec. at Exhibit 16 Sjoberg Tr. at 150. Finally, Virginia Giuffre testified that there was a nude photograph of her at the house. See McCawley Dec. at Exhibit 5 Virginia Giuffre Tr. at 232 and 333. DEFENDANT’S PURPORTED FACTS 50. Ms. Giuffre intentionally destroyed her “journal” and “dream journal” regarding her “memories” of this case in 2013 while represented by counsel. Ms. Giuffre drafted a “journal” describing individuals to whom she claims she was sexually trafficked as well as her memories and thoughts about her experiences with Epstein. In 2013, she and her husband created a bonfire in her backyard in Florida and burned the journal together with other documents in her possession. Jd. Ms. Giuffre also kept a “dream journal” regarding her thoughts and memories that she possessed in January 2016. To date, Ms. Giuffre cannot locate the “dream journal.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS The dream journal contained memories of Ms. Giuffre’s dreams. While Ms. Giuffre has looked for this journal, which is wholly irrelevant to this case, she has been unable to locate it. Ms. Giuffre also wrote in a personal journal some of her experiences with Maxwell and Epstein, which were harmful and painful. In an effort to relieve herself of those past painful experiences, Ms. Giuffre followed the advice of a therapist, and burned the journal as a form of cathartic release at a time when she was under no obligation to maintain the personal memorialization of personal and painful experiences. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 205:13- 206:10. 58

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Filename DocumentCloud_Epstein_Docs_p00951.png
File Size 302.5 KB
OCR Confidence 94.8%
Has Readable Text Yes
Text Length 2,036 characters
Indexed 2026-02-04 12:27:11.831552