On 20 September 20 2015, the District Court of Amsterdam denied attempts by two plaintiffs to prevent the broadcasting of secretly recorded audiovisual materials. The first plaintiff, Volkert van der Graaf, had been conditionally released from prison, having been sentenced to 18 years after he murdered the Dutch politician Pim Fortuyn in 2002. Graaf had been released six years early from prison on, amongst others, the condition that he would refrain from contact with the media. In the secretly recorded footage at issue in this case, Graaf was recorded stating that he himself contacted a photographer of a Dutch national newspaper to take pictures of him. These pictures were published in a national newspaper in July 2014. He also stated that he violated other conditions of his release, which obliged him to reintegrate in society. Notably, in cases of violation of the conditions of release, individuals may be sent back to prison.
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