La lista se dio a conocer en la evidencia N del juicio. Todas estas personas fueron llamadas como testigos y podrían haber participado en las fiestas sexuales que Epstein desarrolló. algunos nombres fueron borrados intencionalmente y omitidos pero se encuentran en otros documentos que ya ha estado circulando en varios medios de comunicación.
Case 1:15-cv-07433-LAP Document 1320-40 Filed 01/03/24 Page 1 of 19
EXHIBIT N
Case 1:15-cv-07433-LAP Document 1320-40 Filed 01/03/24 Page 2 of 19
United States District Court Southern District Of New York
————————————————–X VIRGINIA L. GIUFFRE,
Plaintiff, v.
GHISLAINE MAXWELL, Defendant.
————————————————–X
15-cv-07433-RWS
……………………………………
DEFENDANT GHISLAINE MAXWELL’S
THIRD SUPPLEMENTAL F.R.C.P. 26(A)(1)(A) DISCLOSURES
Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following disclosures:
I.
1.
IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH PARTICULARITY IN THE PLEADINGS
Ghislaine Maxwell
c/o Laura A. Menninger, Esq. Haddon, Morgan & Foreman, P.C. 150 E. 10th Ave.
Denver, CO 80203
303-831-7364 [email protected]
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.
Virginia Lee Roberts Giuffre
c/o Sigrid S. McCawley, Esq.
Boies, Schiller & Flexner LLP
401 East Las Olas Boulevard, Suite 1200
2.
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Miami, Florida 33301 (954) 356-0011 [email protected]
Ms. Giuffre 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.
- 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. - 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. - James Michael Austrich 10108 NW 261 Terrace High Springs, Florida, 32643
Mr. Austrich has knowledge concerning matters at issue in the Complaint, including events of 1996-2002. - Philip Barden
Devonshires Solicitors LLP
30 Finsbury Circus
London, United Kingdom
EC2M 7DT
DX: 33856 Finsbury Square (020) 7628-7576 [email protected]
Mr. Barden has knowledge concerning press statements by Plaintiff and Defendant in 2011-2015 at issue in this matter.
7.
Jane Doe 2
2
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Jane Doe 2
- 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. - 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 Sky Roberts began working at the Mar-a-Lago Club, and the human resources department at Mar-A-Lago. - Evelyn Boulet
Address unknown at this time Telephone number unknown at this time
Ms. Boulet may have knowledge concerning Plaintiff’s false claims against Defendant. - 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. - Joshua Bunner
Address unknown at this time
Joshua Bunner has knowledge concerning Plaintiff’s credibility, including false claims of sexual assault. - Carolyn Casey
Address unknown at this time Telephone number unknown at this time
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Ms. Casey may have knowledge concerning Plaintiff’s false claims against Defendant.
- Paul Cassell
383 South University Street Salt Lake City, UT 84112 801-585-5202 [email protected]
Mr. Cassell has knowledge concerning press statements by Plaintiff, Plaintiff’s court pleadings, and Plaintiff’s sworn testimony. - Sharon Churcher
3 Deveau Road
N. Salem, NY 10560
Ms. Churcher has knowledge concerning matters at issue, including Plaintiff’s statements regarding Defendant and others. - Alexandra Cousteau
Address unknown at this time Telephone number unknown at this time
Ms. Cousteau may have knowledge concerning Plaintiff’s false claims against Defendant and others. - 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. - Dr. Mona Devanesan PO Box 3250
601 E. Delmonte Avenue Clerwiston, FL 33440 (561) 254-2502 [email protected]
Dr. Devanesan has knowledge about matters at issue, including Plaintiff’s whereabouts during 2001 and her claimed damages.
4
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- Jane Doe 2
Address unknown at this time Telephone number unknown at this time - Bradley Edwards
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2
Ft. Lauderdale, FL 33301
(954) 524-2820
[email protected]
Mr. Edwards has knowledge concerning Plaintiff’s false statements to the press, in court pleadings, and in sworn testimony at issue in this matter. Mr. Edwards also has knowledge concerning “Victim’s Refuse Silence, Inc.” - Amanda Ellison
Address unknown at this time 561-628-4338
Ms. Ellison has knowledge concerning Plaintiff’s false allegations concerning Defendant. - Cimberly Espinosa
1113 West Columbine Ave. Santa Ana, CA 92707
Ms. Espinosa has knowledge concerning Plaintiff’s false allegations concerning Defendant. - 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. - Annie Farmer
Address unknown at this time Telephone number unknown at this time
Jane Doe 2 Jane Doe 2
5
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Ms. Farmer may have knowledge concerning Plaintiff’s false claims against Defendant.
- Marie Farmer
Address unknown at this time Telephone number unknown at this time
Ms. Farmer may have knowledge concerning Plaintiff’s false claims against Defendant. - Alexandra Fekkai
Address unknown at this time Telephone number unknown at this time
Ms. Fekkai may have knowledge concerning Plaintiff’s false claims against Defendant and others. - Crystal Figueroa
Address unknown at this time
Ms. Figueroa may have knowledge concerning matters at issue, including Plaintiff’s activities during 1996 – 2002 - Anthony Figueroa
38 Bunker View Drive Palm Coast, FL
Mr. Figueroa has knowledge concerning matters at issue, including Plaintiff’s activities during 1996 – 2002. - Louis Freeh
Address unknown at this time (202) 215-8321 [email protected]
Mr. Freeh may have knowledge concerning travel of Bill Clinton. - 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. - Meg Garvin
Lewis & Clark Law School
6
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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.
- Sheridan Gibson-Butte
Address unknown at this time
Telephone number unknown at this time
Ms. Gibson-Butte may have knowledge concerning Plaintiff’s false claims against Defendant. - Robert Giuffre Queensland, Australia
Mr. Giuffre is may have knowledge concerning matters at issue, including Plaintiff’s activities during 2002-2016 and her damages allegations. - Ross Gow
Acuity Representation
23 Berkeley Square London W1J 6HE
44 (0) 777 875 5251 [email protected]
Mr. Gow may have knowledge concerning matters at issue, including the publication of statements in the press in 2011-2015 concerning Plaintiff and Defendant. - 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. - 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.
Jane Doe 2
Jane Doe 2
7
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Jane Doe 2
-Jane Doe 2 may have knowledge concerning matters at issue.
- Shannon Harrison
Address unknown at this time Telephone number unknown at this time
Ms. Harrison may have knowledge concerning Plaintiff’s false claims against Defendant. - Victoria Hazel
Address unknown at this time Telephone number unknown at this time
Ms. Hazel may have knowledge concerning Plaintiff’s false claims against Defendant. - Brittany Henderson
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2
Ft. Lauderdale, FL 33301
Ms. Henderson has knowledge concerning matters at issue including Victims Refuse Silence and Plaintiff’s damages. - Brett Jaffe
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. - Carol Roberts Kess
Address unknown at this time Telephone number unknown at this time
Ms. Kess may have knowledge concerning matters at issue, including Plaintiff’s activities during 1996 – 2002. - Dr. Karen Kutikoff
12957 Palms W Drive #101
8
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Loxahatchee, FL 33470
Dr. Kutifkoff may have knowledge concerning matters at issue, including Plaintiff’s whereabouts during 1998-2002 and Plaintiff’s damages.
- 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. - Tony Lyons
Skyhorse Publishing, Inc.
307 West 36th Street, 11th Floor New York, NY 10018
Mr. Lyons may have knowledge concerning matters at issue, including Plaintiff’s false allegations concerning Defendant and others. - Bob Meister
101 Seminole Avenue, Palm Beach, FL 38480 (561) 650-0083
Mr. Meister may have knowledge concerning Plaintiff’s false claims against Defendant. - Jamie A. Melanson
5280 NW 53rd Ave. Coconut Creek, FL 33073
Mr. Melanson has knowledge concerning Plaintiff’s honesty and truthfulness. - Lynn Miller 936 O Street
Penrose, CO 81240
Ms. Miller may have knowledge concerning matters at issue, including Plaintiff’s activities during 1996 – 2002. - Marvin Minsky
Address unknown at this time Telephone number unknown at this time
9
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Mr. Minsky may have knowledge concerning Plaintiff’s false claims against Defendant and others.
Jane Doe 2
50.
- 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. - 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. - Mary Paluga
Address unknown at this time Telephone number unknown at this time
Ms. Paluga may have knowledge concerning Plaintiff’s false claims against Defendant. - J. Stanley Pottinger
49 Twin Lakes Rd. South Salem, NY 10590 914-763-8333
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. - Joseph Recarey
2753 Misty Oaks Circle
Royal Palm Beach, FL 33441 Telephone number unknown at this time
Mr. Recarey may have knowledge concerning Plaintiff’s false claims against Defendant.
Jane Doe 2
10
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- Michael Reiter
2335 So. Ocean Blvd., Apt. 15
Palm Beach, FL 33480
Telephone number unknown at this time
Mr. Reiter may have knowledge concerning Plaintiff’s false claims against Defendant. - 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. - Bill Richardson
Address unknown at this time Telephone number unknown at this time
Mr. Richardson may have knowledge concerning Plaintiff’s false claims against Defendant and others. - Sky Roberts
15020 SE 47th Ave Summerfield, FL 34491-5141
Mr. Roberts may have knowledge concerning matters at issue, including Plaintiff’s activities during 1996 – 2002. - Scott Rothstein
U.S. Bureau of Prisons
Mr. Rothstein has knowledge concerning Plaintiff’s civil claims against Jeffrey Epstein. - 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. - Doug Schoetlle
Address unknown at this time Telephone number unknown at this time
11
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Mr. Schoettle may have knowledge concerning Plaintiff’s false claims against Defendant.
- Cecilia Stein
Address unknown at this time Telephone number unknown at this time
Ms. Stein may have knowledge concerning Plaintiff’s false claims against Defendant. - 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. - Brent Tindall
Address unknown at this time Telephone number unknown at this time - Kevin Thompson
Address unknown at this time
Kevin Thompson has knowledge concerning Plaintiff’s credibility, including false claims of sexual assault. - 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. - Emma Vaghan
Address unknown at this time Telephone number unknown at this time
Ms. Vaghan may have knowledge concerning Plaintiff’s false claims against Defendant. - Kimberly Vaughan-Edwards
Address unknown at this time Telephone number unknown at this time Believed to be in the UK
12
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Ms. Vaughan-Edwards has knowledge concerning facts relevant to this dispute and Ms. Maxwell’s character.
- Cresenda Valdes
Address unknown at this time Telephone number unknown at this time
Ms. Valdes may have knowledge concerning Plaintiff’s false claims against Defendant. - 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. - Maritza Vazquez
Address unknown at this time Telephone number unknown at this time
Ms. Vazquez may have knowledge concerning Plaintiff’s false claims against Defendant. - Vicky Ward
Address unknown at this time Telephone number unknown at this time
Ms. Ward may have knowledge concerning Plaintiff’s false claims against Defendant. - 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. - Courtney Wild Pinellas County Jail
Ms. Wild may have knowledge concerning Plaintiff’s false claims against Defendant. - Daniel Wilson
Address unknown at this time
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Telephone number unknown at this time
Mr. Wilson may have knowledge concerning matters at issue, including Plaintiff’s activities during 1996 – 2002.
- Andrew Albert Christian Edwards, Duke of York Address unknown at this time
Telephone number unknown at this time
The Duke 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. - Witnessed identified by Plaintiff in any of the various versions of her Rule 26 disclosures.
- Witnesses whose identities and contact information can be identified in law enforcement reports disclosed herein.
- 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.
II. DOCUMENTS, DATA, COMPILATIONS AND TANGIBLE THINGS IN POSSESSION, CUSTODY OR CONTROL OF DEFENDANT THAT MAY BE USED TO SUPPORT DEFENDANT’S CLAIM OR DEFENSES - Documents received from any other party through disclosures and/or in discovery, including any deposition exhibits, will not be identified or produced, though they technically may fall within this category “II”, and Defendant reserves the right to utilize such documents at any hearing or trial on this matter.
- News articles from the internet:
a. “Sordid friends and why he isn’t fit for the job: Duke 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 Maxwell’s daughter ‘procured young girls’ for Prince Andrew’s billionaire friend,” Daily Mail Online (Mar. 5, 2011).
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d. “Virginia Roberts’ 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 Duke 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. “Virginia Roberts’s 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).
l. “Jeffrey Epstein accuser was not a sex slave, but a money-hungry sex kitten, her former friends say,” NY Daily News (Mar. 1, 2015).
m. “Twat Claims She Was Underage Sex Slave Bedding Prince Andrew,” http://www.mgtowhq.com/viewtopic.php?f=2&t=6676 (Jan. 5, 2015).
n. “Exclusive: Prince Andrew at Heidi Klum’s ‘Hookers and Pimps’ party with the New York socialite accused of procuring underage girls for his billionaire pedophile friend” Daily Mail Online (May 10, 2016).
- Email from Ross Gow to various news organizations, Subject: “Ghislaine Maxwell,” (Jan. 2, 2015).
- “Lawyers Acknowledge Mistake In Filing Sexual Misconduct Charges Against Professor Dershowitz,” Joint Statement of Brad Edwards, Paul Cassell and Alan Dershowitz (Apr. 8, 2016).
- Edwards and Cassell v. Dershowitz, In the Circuit Court of the Seventeenth Judicial District In and For Broward County Florida to include:
15
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a. Deposition testimony of Paul G. Cassell, dated October 16, 2015 and October 17, 2015.
- 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) - Epstein v. Scott Rothstein and Bradley J. Edwards, 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). - Law enforcement records obtained from the Palm Beach County (Florida) Sheriff’s Office, the Royal 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.
- Employment records obtained from ET Employment Training and Recruiting Australia.
- Education records obtained from Royal Palm Beach Community High School and Forest Hills High School.
- Documents received from Palm Beach County Library System.
- Documents received from any other party through disclosures and/or in discovery, including any deposition exhibits, will not be identified or produced, though they technically may fall within this category “II”, and Defendant reserves the right to utilize such documents at any hearing or trial on this matter.
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Defendant reserves the right to identify additional documents, data, compilations and tangible things as discovery continues and to supplement this list accordingly.
III. 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.
IV. 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, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628 [email protected] [email protected]
Attorneys for Ghislaine Maxwell
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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(A)(1) DISCLOSURES via e-mail on the following:
Sigrid S. McCawley
Meredith Schultz
BOIES, SCHILLER & FLEXNER, LLP
401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 [email protected] [email protected]
Bradley J. Edwards
FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Ave., Ste. 2
Ft. Lauderdale, FL 33301 [email protected]
s/
Paul G. Cassell
383 S. University Street Salt Lake City, UT 84112 [email protected]
J. Stanley Pottinger
49 Twin Lakes Rd. South Salem, NY 10590 [email protected]
18
