Datasets:

robbd
/

epstein-index

Case 1:15-cv-07433-LAP Document 1322-1 Filed 01/04/24 Page 1 of 19
EXHIBIT N
EFTA02792797

Case 1:15-cv-07433-LAP Document 1322-1
Filed 01/04/24 Page 2 of 19
United States District Court
Southern District Of New York
-X
Plaintiff,
V.
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
DEFENDANT GHISLAINE MAXWELL'S
THIRD SUPPLEMENTAL F.R.C.P. 26(A)(L)(A) DISCLOSURES
Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I.
IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE
INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
c/o Laura A. Menninger, Es9: P.C.
Haddon,
150 E. 10" Ave.
Denver, CO 80203
303-831-7364
LMenninger@HMFLaw.com
Ms. Maxwell is the Defendant and may have knowledge concerning matters at
issue, including the events of 1999-2002 and the publication of statements in the
press in 2011-2015.
2.
c/o Sigrid S. McCawley, Esq.
Boies, Schiller & Flexner LLP
401 East Las Olas Boulevard, Suite 1200
EFTA02792798

Case 1:15-cv-07433-LAP Document 1322-1 Filed 01/04/24 Page 3 of 19
Miami, Florida 33301
(954) 356-0011
smecawley@bsfllp.com
is the Plaintiff and has knowledge concerning the matters at issue in
her Complaint, including the events of 1996-2015 and the publication of
statements in the press in 2011-2015.
3. Kathy Alexander
Address unknown at this time
Telephone number unknown at this time
Ms. Alexander has knowledge about matters at issue, including Plaintiff's
whereabouts during 2000-2002 and her false claims concerning Defendant and
others.
4. Miles Alexander
Address unknown at this time
Telephone number unknown at this time
Mr. Alexander has knowledge about matters at issue, including Plaintiff's
whereabouts during 2000-2002 and her false claims concerning Defendant and
others.
5. James Michael Austrich
Mr. Austrich has knowledge concerning matters at issue in the Complaint,
including events of 1996-2002.
6. Philip Barden
Devonshires Solicitors LLP
30 Finsbury Circus
London, United Kingdom
EC2M 7DT
DX: 33856 Finsbury Square
(020) 7628-7576
Philip.Barden@devonshires.co.uk
Mr. Barden has knowledge concerning press statements by Plaintiff and
Defendant in 2011-2015 at issue in this matter.
7.
Address unknown at this time
Telephone number unknown at this time
2
EFTA02792799

Case 1:15-cv-07433-LAP Document 1322-1 Filed 01/04/24 Page 4 of 19
has knowledge concerning matters at issue in the Complaint,
including her own whereabouts and activities during the period 2000-2002.
8. David Boies
Boies, Schiller, Flexner LLP
575 Lexington Ave.
New York, NY 10022
(212) 446-2300
Mr. Boies has knowledge concerning matters at issue in the Complaint and in
Plaintiff's pleadings and sworn statements in other litigations, including in
particular her publicly filed allegations concerning Defendant and Alan
Dershowitz.
9. Laura Boothe
The Mar-a-Lago Club, LC.
1100 South Ocean Boulevard,
Palm Beach, FL 33480
Ms. Boothe has knowledge concerning matters at issue, including the date that
SkyL
began working at the Mar-a-Lago Club, and the human resources
department at Mar-A-Lago.
10. Evelyn
Address unknown at this time
Telephone number unknown at this time
have knowledge concerning Plaintiff's false claims against
Defendant.
11. Rebecca Boylan
Address unknown at this time
Telephone number unknown at this time
Ms. Boylan has knowledge concerning Plaintiff during the relevant time period
including claims for damages, motive and bias.
12. Joshua Bunner
Address unknown at this time
Joshua Bunner has knowledge concerning Plaintiff's credibility, including false
claims of sexual assault.
13.
Address unknown at this time
Telephone number unknown at this time
3
EFTA02792800

Case 1:15-cv-07433-LAP Document 1322-1 Filed 01/04/24 Page 5 of 19
have knowledge concerning Plaintiff's false claims against
Detendant.
14. Paul Cassell
383 South University Street
Salt Lake City, UT 84112
801-585-5202
paul.cassell@law.utah.edu
Mr. Cassell has knowledge concerning press statements by Plaintiff, Plaintiff's
court pleadings, and Plaintiff's sworn testimony.
15. Sharon Churcher
Ms. Churcher has knowledge concerning matters at issue, including Plaintiff's
statements regarding Defendant and others.
16.
Address unknown at this time
Telephone number unknown at this time
have knowledge concerning Plaintiff's false claims against
Defendant and others.
17. Alan Dershowitz
c/o Richard A. Simpson, Esq.
WILEY REIN, LLP
1776 K Street NW
Washington, D.C. 20006
(202) 719-7000
Mr. Dershowitz has knowledge concerning Plaintiff's false statements to the
press, in court pleadings, and in sworn testimony, at issue in this matter.
18. Dr. Mona Devanesan
Dr. Devanesan has knowledge about matters at issue, including Plaintiff's
whereabouts during 2001 and her claimed damages.
4
EFTA02792801

Case 1:15-cv-07433-LAP Document 1322-1 Filed 01/04/24 Page 6 of 19
19.
Address unknown at this time
Telephone number unknown at this time
may have knowledge concerning Plaintiff's false claims against
Defendant.
20.
1. Jaffe, Weissing,
425 N. Andrews Ave., Suite 2
Ft. Lauderdale, FL 33301
(954) 524-2820
brad@pathtojustice.com
Fistos & Lehrman, P.L.
Mr.
has knowledge concerning Plaintiff's false statements to the press,
in court pleadings, and in sworn testimony at issue in this matter. Mr.
also has knowledge concerning "Victim's Refuse Silence, Inc."
21. Amanda Ellison
Address unknown at this time
561-628-4338
Ms. Ellison has knowledge concerning Plaintiff's false allegations concerning
Defendant.
22. Cimberly Espinosa
has knowledge concerning Plaintiff's false allegations concerning
Defendant.
23. Jeffrey Epstein
c/o Tonja Haddad Coleman, Esq.
315 SE 7th Street, Suite 301
Fort Lauderdale, FL 33301
(954) 467-1223
Mr. Epstein has knowledge concerning Plaintiff's false statements to the press and
in court pleadings, as well as the events of 1999-2002 concerning Plaintiff and
Defendant.
24.
Address unknown at this time
Telephone number unknown at this time
5
EFTA02792802

Case 1:15-cv-07433-LAP Document 1322-1 Filed 01/04/24 Page 7 of 19
have knowledge concerning Plaintiff's false claims against
Defendant.
25.
Farmer
Address unknown at this time
Telephone number unknown at this time
have knowledge concerning Plaintiff's false claims against
Defendant.
26. Alexandra Fekkai
Address unknown at this time
Telephone number unknown at this time
have knowledge concerning Plaintiff's false claims against
Defendant and others.
27. Crystal
Address unknown at this time
have knowledge concerning matters at issue, including
Plaintiff's activities during 1996 - 2002
28. Anthony Figueroa
Mr.
activities during 1996 - 2002.
29. Lous Freeh
Address unknown at this time
has knowledge concerning matters at issue, including Plaintiff's
Mr. Freeh may have knowledge concerning travel of Bill Clinton.
30. Eric Gany
Address unknown at this time
Telephone number unknown at this time
Mr. Gany may have knowledge concerning Plaintiff whereabouts during 2000-
2002 and her false claims against Defendant.
31. Meg Garvin
& Clark Law School
6
EFTA02792803

Case 1:15-cv-07433-LAP Document 1322-1 Filed 01/04/24 Page 8 of 19
10015 S. W. Terwilliger Boulevard MSC 51
Portland, Oregon 97219
Ms. Garvin has knowledge concerning matters at issue including Victims Refuse
Silence and Plaintiff's damages.
32.
Address unknown at this time
Telephone number unknown at this time
have knowledge concerning Plaintiff's false claims
against Defendant.
33. Robert
Queensland, Australia
Mr.
| is may have knowledge concerning matters at issue, including
Plaintiff's activities during 2002-2016 and her damages allegations.
34.
Gow
Acuity Representation
23 Berkeley Square
London WIJ 6HE
Mr. Gow may have knowledge concerning matters at issue, including the
publication of statements in the press in 2011-2015 concerning Plaintiff and
Defendant.
35. Fred Graff
Address unknown at this time
Telephone number unknown at this time
Mr. Graff may have knowledge concerning Plaintiff's false claims against
Defendant.
36. Philip Guderyon
Address unknown at this time
Telephone number unknown at this time
Mr. Guderyon may have knowledge concerning matters at issue, including
Plaintiff's activities during 1996 - 2002.
37.
7
EFTA02792804

Case 1:15-cv-07433-LAP Document 1322-1 Filed 01/04/24 Page 9 of 19
may have knowledge concerning matters at issue.
38. Shannon
Address unknown at this time
Telephone number unknown at this time
have knowledge concerning Plaintiff's false claims against
Defendant.
39.
Address unknown at this time
Telephone number unknown at this time
have knowledge concerning Plaintiff's false claims against
Defendant.
40. Brittany
1. Jaffe, Weissing,
425 N. Andrews Ave., Suite 2
Ft. Lauderdale, FL 33301
Fistos & Lehrman, P.L.
has knowledge concerning matters at issue including Victims
Refuse Silence and Plaintiff's damages.
41. Brett Jafte
Address unknown at this time
Telephone number unknown at this time
Mr. Jaffe has knowledge concerning Plaintiff's false claims concerning Ms.
Maxwell including her compliance with any deposition subpoena in the CVRA
matter.
42. Carol
Kess
Address unknown at this time
Telephone number unknown at this time
[have knowledge concerning matters at issue, including Plaintiff's
activities during 1996 - 2002.
43. Dr. Karen Kutikoff
12957 Palms W Drive #101
8
EFTA02792805

Case 1:15-cv-07433-LAP Document 1322-1 Filed 01/04/24 Page 10 of 19
Loxahatchee, FL 33470
Dr. Kutifkoff may have knowledge concerning matters at issue, including
Plaintiff's whereabouts during 1998-2002 and Plaintiff's damages.
44. Peter Listerman
Address unknown at this time
Telephone number unknown at this time
Mr. Listerman may have knowledge concerning Plaintiff's false claims against
Defendant.
45. Tony
Skyhorse Publishing, Inc.
307 West 36th Street, 11th Floor
New York, NY 10018
Mr. may have knowledge concerning matters at issue, including Plaintiff's
false allegations concerning Defendant and others.
46. Bob Meister
Mr. Meister may have knowledge concerning Plaintiff's false claims against
Defendant.
47. Jamie A. Melanson
T
Mr. Melanson has knowledge concerning Plaintiff's honesty and truthfulness.
48. Lynn
have knowledge concerning matters at issue, including Plaintiff's
activities during 1996 - 2002.
49. Marvin Minsky
Address unknown at this time
Telephone number unknown at this time
9
EFTA02792806

Case 1:15-cv-07433-LAP Document 1322-1
Filed 01/04/24 Page 11 of 19
Mr. Minsky may have knowledge concerning Plaintiff's false claims against
Defendant and others.
50.
Address unknown at this time
Telephone number unknown at this time
may have knowledge concerning Plaintiff's false claims against
Defendant.
51. David Mullen
Address unknown at this time
Telephone number unknown at this time
Mr. Mullen may have knowledge concerning Plaintiff's false claims against
Defendant.
52. Joe Pagano
Address unknown at this time
Telephone number unknown at this time
Mr. Pagano may have knowledge concerning Plaintiff's false claims against
Defendant.
53. Mary Paluga
Address unknown at this time
Telephone number unknown at this time
have knowledge concerning Plaintiff's false claims against
Defendant.
54. J. Stanley Pottinger
55.
Mr. Pottinger may have knowledge concerning matters at issue, including
Plaintiff's attempts to sell her story to the media and her contacts with the media.
Recarey
2753 Misty Oaks Circle
Palm Beach, FL 33441
Telephone number unknown at this time
Mr. Recarey may have knowledge concerning Plaintiff's false claims against
Defendant.
10
EFTA02792807

Case 1:15-cv-07433-LAP Document 1322-1
Filed 01/04/24 Page 12 of 19
56. Michael Reiter
Telephone number unknown at this time
Mr. Reiter may have knowledge concerning Plaintiff's false claims against
Defendant.
57. Jason Richards
Federal Bureau of Investigations
Address unknown at this time
Mr. Richards has knowledge concerning matters at issue, including Plaintiff's
statements concerning Defendant, Alan Dershowitz and other individuals.
58. Bill
Address unknown at this time
Telephone number unknown at this time
Mr.
may have knowledge concerning Plaintiff's false claims against
Defendant and others.
59. Sky
Mr.
I may have knowledge concerning matters at issue, including
Plaintiff's activities during 1996 - 2002.
60. Scott Rothstein
U.S. Bureau of Prisons
Mr. Rothstein has knowledge concerning Plaintiff's civil claims against Jeffrey
Epstein.
61. Forest Sawyer
Address unknown at this time
Telephone number unknown at this time
Mr. Sawyer may have knowledge concerning Plaintiff's false claims against
Defendant.
62. Doug Schoetlle
Address unknown at this time
Telephone number unknown at this time
11
EFTA02792808

Case 1:15-cv-07433-LAP Document 1322-1 Filed 01/04/24 Page 13 of 19
Mr. Schoettle may have knowledge concerning Plaintiff's false claims against
Defendant.
63. Cecilia
Address unknown at this time
Telephone number unknown at this time
have knowledge concerning Plaintiff's false claims against
Defendant.
64. Mark Tafoya
Address unknown at this time
Telephone number unknown at this time
Mr. Tafoya may have knowledge concerning Plaintiff's false claims against
Defendant.
65. Brent Tindall
Address unknown at this time
Telephone number unknown at this time
66. Kevin Thompson
Address unknown at this time
Kevin Thompson has knowledge concerning Plaintiff's credibility, including false
claims of sexual assault.
67. Ed Tuttle
Address unknown at this time
Telephone number unknown at this time
Mr. Tuttle may have knowledge concerning Plaintiff's false claims against
Defendant.
68. Emma Vaghan
Address unknown at this time
Telephone number unknown at this time
have knowledge concerning Plaintiff's false claims against
Defendant.
69. Kimberly Vaughan-
Address unknown at this time
Telephone number unknown at this time
Believed to be in the UK
12
EFTA02792809

Case 1:15-cv-07433-LAP Document 1322-1 Filed 01/04/24 Page 14 of 19
has knowledge concerning facts relevant to this dispute
and Ms. Maxwell's character.
70. Cresenda Valdes
Address unknown at this time
Telephone number unknown at this time
have knowledge concerning Plaintiff's false claims against
Defendant.
71. Anthony Valladares
Address unknown at this time
Telephone number unknown at this time
Mr. Valladares may have knowledge concerning matters at issue, including
Plaintiff's activities during 1996 - 2002.
2. Maritza Vazquez
des e number unknown at this tim
have knowledge concerning Plaintiff's false claims against
Defendant.
73. Vicky
Address unknown at this time
Telephone number unknown at this time
have knowledge concerning Plaintiff's false claims against
Defendant.
74. Jarred Weisfeld
Address unknown at this time
Mr. Weisfeld may have knowledge concerning matters at issue, including
Plaintiff's attempted publication of false allegations concerning Defendant and
others.
75.
Pinellas County Jail
have knowledge concerning Plaintiff's false claims against
Defendant.
76. Daniel Wilson
Address unknown at this time
13
EFTA02792810

Case 1:15-cv-07433-LAP Document 1322-1
Filed 01/04/24 Page 15 of 19
II.
Telephone number unknown at this time
Mr. Wilson may have knowledge concerning matters at issue, including Plaintiff's
activities during 1996 - 2002.
77. Andrew Albert Christian
Address unknown at this time
Telephone number unknown at this time
of York
The
has knowledge concerning Plaintiff's false statements to the press, in
court pleadings, and in sworn testimony as well as the events of 1999-2002.
78. Witnessed identified by Plaintiff in any of the various versions of her Rule 26
disclosures.
79. Witnesses whose identities and contact information can be identified in law
enforcement reports disclosed herein.
80. Any other witness learned through the discovery process.
Defendant Ghislaine Maxwell reserves her right to supplement these disclosures as
additional witnesses are learned through the discovery process, or endorsed by
Plaintiff.
DOCUMENTS, DATA, COMPILATIONS AND TANGIBLE THINGS IN
POSSESSION, CUSTODY OR CONTROL OF DEFENDANT THAT MAY
BE USED TO SUPPORT DEFENDANT'S CLAIM OR DEFENSES
1. Documents received from any other party through disclosures and/or in
liscovery, including any deposition exhibits, will not be identified o
roduced, though they technically may fall within this category "Il", an‹
Defendant reserves the right to utilize such documents at any hearing or trial
on this matter.
2. News articles from the internet:
a.
"Sordid friends and why he isn't fit for the job:
of York risks
losing ambassador role," Daily Mail Online (Feb. 28, 2011).
b. "Prince Andrew and the 17-year-old girl his sex offender friend flew
to Britain to meet him," Daily Mail Online (corrected Mar. 2, 2011).
c. "Unsavoury association: How Robert Max well's daughter 'procured
young girls' for Prince Andrew's billionaire friend," Daily Mail Online
(Mar. S, 2011).
14
EFTA027928117

Case 1:15-cv-07433-LAP Document 1322-1 Filed 01/04/24 Page 16 of 19
d. "
account of the explosive Prince Andrew 'sex slave'
drama," Daily Mail Online (Jan. 3, 2015).
e. "Court papers put daughter of Robert Maxwell at centre of "sex slave'
scandal," The Guardian (Jan. 4, 2015).
f. "Prince Andrew denies sexual abuse allegations in unprecedented
Buckingham Palace statement: The
of York denies having
relations with alleged 'sex slave,'" The Independent (Jan. 4, 2015).
g. "Prince Andrew story runs and runs - but editors should beware," The
Guardian (Jan. 5, 2015).
h. "US lawyer sues in Prince Andrew sex claims case," Time (Jan 6,
2015).
i.
• "Harvard professor Alan Dershowitz denies charges of sex with
underage girl," Boston Globe (Jan. 22, 2015).
j.
Aunt Reveals Jeffrey Epstein Girl Says I Am In
Fear for My Life," Daily Mail Online, (Jan. 10, 2015).
k. "EXCLUSIVE: Alleged 'sex slave' of Jeffrey Epstein, Prince Andrew
accused two men of rape in 1998, but was found not credible," NY
Daily News (Feb. 23, 2015).
1. "Jeffrey Epstein accuser was not a sex slave, but a money-hungry sex
kitten, her former friends say," NY Daily News (Mar. 1, 2015).
"Twat Claims She Was Underage Sex Slave Bedding Prince Andrew,"
http://www.mgtowhq.com/viewtopic.php?t=2&t=6676 (Jan. 5, 2015).
n. "Exclusive: Prince Andrew at Heidi Klum's 'Hookers and Pimps'
arty with the New York socialite accused of procuring underage girl
or his billionaire pedophile friend" Daily Mail Online (May 10
2016).
3. Email from
Maxwell," (Jan. 2, 2015).
Gow to various news organizations, Subject: "Ghislaine
4. "Lawyers Acknowledge Mistake In Filing Sexual Misconduct Charges
Against Professor Dershowitz," Joint Statement of Brad |
Paul
Cassell and Alan Dershowitz (Apr. 8, 2016).
5.
and Cassell v. Dershowitz, In the Circuit Court of the Seventeenth
Judicial District In and For Broward County Florida to include:
15
EFTA02792812

Case 1:15-cv-07433-LAP Document 1322-1 Filed 01/04/24 Page 17 of 19
a. Deposition testimony of Paul G. Cassell, dated October 16, 2015 and
October 17, 2015.
6. Jane Doe #1 and #2 v. United States, U.S. District Court for the Southern
District of Florida, 08-cv-80736-KAM pleadings to include:
a. Motion for Limited Appearance, Consent to Designation and Request
to Electronically Receive Notices of Electronic Filing (July 28, 2008)
(Doc. # 16)
b. Notice of Change of Address and Firm Affiliation (Apr. 9, 2009) (Doc.
#37)
c. Order Denying Petitioners' Motion to Join Under Rule 21 and Motion
to Amend Under Rule 15 (Apr. 7, 2015) (Doc. #324)
d. Order Scheduling Settlement Conference Before the Magistrate Judge,
U.S. District Court (Mar. 31, 2016) (Doc. #378)
7. Epstein v. Scott Rothstein and
_J.
1. In the Circuit Court of the
Fifteenth Judicial Circuit in and for Palm Beach County, Florida, 09-ca-
040800, pleadings to include:
a. Complaint (Dec. 7, 2009).
8. Law enforcement records obtained from the Palm Beach County (Florida)
Sheriff's Office, the
Palm Beach (Florida) Police Department, the
County Court in and for Palm Beach County (Florida), the Greenacres
(Florida) Department of Public Safety, and the Fremont County (Colorado)
Sheriff's Office.
9. Employment records obtained from ET Employment Training and Recruiting
Australia.
10. Education records obtained from
and Forest Hills High School.
Palm Beach Community High School
11. Documents received from Palm Beach County Library System.
12. Documents received from any other party through disclosures and/or in
scovery, including any deposition exhibits, will not be identified ‹
oduced, though they technically may fall within this category "IT", ar
Defendant reserves the right to utilize such documents at any hearing or trial
on this matter.
16
EFTA02792813

Case 1:15-cv-07433-LAP Document 1322-1
Filed 01/04/24 Page 18 of 19
III.
IV.
Defendant reserves the right to identify additional documents, data, compilations
and tangible things as discovery continues and to supplement this list accordingly.
DESCRIPTION OF CATEGORIES OF DAMAGES SOUGHT AND
COMPUTATION OF ECONOMIC DAMAGES CLAIMED BY THE
DISCLOSING PARTY
Not applicable at this time Ms. Maxwell reserves her right to supplement these
disclosures as necessary.
INSURANCE AGREEMENT UNDER WHICH ANY PERSON CARRYING
ON AN INSURANCE BUSINESS MAY BE LIABLE TO SATISFY A PART
OR ALL OF A JUDGMENT
Ms. Maxwell's AIG Homeowners and Excess Liability insurance policies.
Coverage has been denied by AIG, as their letter of April 18, 2016 to Ms.
Maxwell, copied to Ms. McCawley, attests.
Dated: June 17, 2016.
Respectfully submitted,
s/ Laura A. Menninger
Laura A. Menninger
Jeffrey S. Pagliuca
HADDON,
AND
150 East 10" Avenue
Denver, CO 80203
Phone: 303.831.7364
Fax:
303.832.2628
Imenninger@hmflaw.com
jpagliuca@hmflaw.com
Attorneys for Ghislaine Maxwell
P.C.
17
EFTA02792814

Case 1:15-cv-07433-LAP Document 1322-1
Filed 01/04/24 Page 19 of 19
CERTIFICATE OF SERVICE
I certify that on June 17, 2016, I electronically served this DEFENDANT GHISLAINE
MAXWELL'S THIRD SUPPLEMENTAL F.R.C.P. 26(AX1) DISCLOSURES via e-mail on the
following:
Sigrid S. McCawley
Meredith |
BOIES, SCHILLER & FLEXNER, LLP
401 East Las Olas Boulevard, Ste. 1200
Ft. Lauderdale, FL 33301
smccawley@bsfllp.com
mschultz@bsfllp.com
Paul G. Cassell
383 S. University Street
alt Lake City, UT 8411:
JAFFE, WEISSING,
FISTOS & LEHRMAN, P.L.
425 North Andrews Ave., Ste. 2
Ft. Lauderdale, FL 33301
brad@pathtojustice.com
J. Stanley Pottinger
49 Twin Lakes Rd.
South Salem, NY 10590
StanPottinger@aol.com
s/
18
EFTA02792815