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Extracted Text (OCR)
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.
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Extracted Information
Dates
Document Details
| 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 |