vision-joined/court-03/01466421e654ca0508beaa0726640d6f4fb06bfbb31f5a8615e4d4f6b6f2fc73.md

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."
2. Amanda Ellison Address unknown at this time 561-628-4338 Ms. Ellison has knowledge concerning Plaintiff's false allegations concerning Defendant.
3. Cimberly Espinosa has knowledge concerning Plaintiff's false allegations concerning Defendant.
4. 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.
5. 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.
2. 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.
3. 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.
4. 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).
2. Email from Maxwell," (Jan. 2, 2015). Gow to various news organizations, Subject: "Ghislaine
3. "Lawyers Acknowledge Mistake In Filing Sexual Misconduct Charges Against Professor Dershowitz," Joint Statement of Brad | Paul Cassell and Alan Dershowitz (Apr. 8, 2016).
4. 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).
2. 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.
3. Employment records obtained from ET Employment Training and Recruiting Australia.
4. Education records obtained from and Forest Hills High School. Palm Beach Community High School
5. Documents received from Palm Beach County Library System.
6. 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