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Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 194 of 465 Page 193 G Maxwell - Confidential pictures of people that would end up -- or a friend of his that he would have -- not naked or not inappropriate in any way, that he might have somewhere in his house. Q. Name for me all the individuals who you took these pictures of? A. It's entirely impossible for me to name people. First of all, it was just -- it would not be possible, I took thousands of photos, not of people, I mostly take pictures of landscapes and things. I have no recollection specifically of people that I took pictures of. Q. So you can't remember, is it your testimony you can't remember one person that you took a picture of in either a naked or semi naked state? A. I seriously cannot recall. I just don't recall. Q. Did you take a picture of Virginia Roberts either alone or with another individual in a naked state? A. I have never taken, I believe, any pictures of two people in any type of MAGNA® LEGAL SERVICES