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Case 1:15-cv-07433-LAP Document 69-2 Filed 03/23/16 Page 1 of 21
EXHIBIT 2
Case 1:15-cv-07433-LAP Document 69-2 Filed 03/23/16 Page 2 of 21
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF, VIRGINIA GIUFFREâS REVISED DISCLOSURE
PURSUANT TO FED. R. CIV. P. 26
COMES NOW the Plaintiff, Virginia L. Giuffre, by and through her undersigned counsel,
and serves this revised disclosure pursuant to Fed. R. Civ. P. 26 and states as follows:
A. Witnesses:
1. Virginia L. Giuffre
c/o Sigrid S. McCawley, Esq.
Boies, Schiller & Flexner LLP
401 East Las Olas Boulevard, Suite 1200
Miami, Florida 33301
Tel: (954) 356-0011
Email: [email protected]
Plaintiff - information regarding Defendant, Ghislaine Maxwellâs conduct that is
the subject of this action
2. Ghislaine Maxwell
c/o Laura A. Menninger, Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Tel: (303) 831-7364
Email: [email protected]
Defendant in this action.
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3. Juan Alessi
6791 Fairway Lakes Drive, Boynton Beach, FL 33472
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors.
4. Maria Alessi
6791 Fairway Lakes Drive, Boynton Beach, FL 33472
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors.
5. Doug Band
President of Teneo Holdings, 601 Lexington Avenue, 45th Floor,
New York, NY 10022, Tel: (212) 886-1600
Was present on flights with Jeffrey Epstein and Ghislaine Maxwell and President
Clinton and may have knowledge of Jeffrey Epstein and Ghislaine Maxwellâs sexual trafficking
conduct and interactions with minors.
6. Gwendolyn Beck
P.O. Box 705, Arlington, VA 22216
(703) 656-6007
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors.
7. Sophie Biddle
388 W. Carmel Valley Road, Carmel Valley, CA 93924
Tel: (310) 394-7048
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors.
8. Nadia Bjorlin
c/o Cris Armenta, Esq.
11900 Olympic Blvd., Suite 730, Los Angeles, CA 90064
Tel: (310) 826-2826
2
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Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and Virginia
Guiffre and may have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors.
9. Kelly Bovino
16694 Via La Costa, Pacific Palisades, CA 90272
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors.
10. Jean Luc Brunel
c/o Joe Titone, Esq.
621 South East 5th Street, Pompano Beach, FL 33060
Tel: (954) 729-6490
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and Virginia
Guiffre and has information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
11. Ron Burkle
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct.
12. Dana Burns
Address unknown at this time.
Telephone number unknown at this time
Worked for Ghislaine Maxwell and has information about Ghislaine Maxwellâs
recruiting of girls for Jeffrey Epstein.
13. Alyson Chambers
c/o Marshall Dore Louis, Esq.
Sinclair, Louis & Zavertnik, P.A.
40 N.W. 3rd Street, Suite 200, Miami, FL 33128
Tel: (305) 374-0544
Worked for Jeffrey Epstein as a masseuse during the time that Virginia Giuffre was
living and traveling with Jeffrey Epstein and Ghislaine Maxwell, and has information about
Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking conduct.
3
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14. Maximilia Cordero
Address unknown at this time
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct.
15. Valdson Cotrin
Address unknown at this time
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct.
16. Chauntae Davies
1017 N. Spaulding Avenue, #8, West Hollywood, CA 90056
Telephone number unknown at this time
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and may have
information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking conduct and
interaction with underage minors.
17. Teala Davies
1212 N. Clark Street, Apt. #7, West Hollywood, CA 90069
Telephone number unknown at this time
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and may have
information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking conduct and
interaction with underage minors.
18. Anouska DeGeorgieou
536 N. Edinburgh Avenue, Los Angeles, CA 90048
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors.
19. Alan Dershowitz
c/o Richard A. Simpson, Esq.
WILEY REIN, LLP
1776 K Street NW
Washington, D.C. 20006
Tel: (202) 719-7000
4
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Has knowledge of Defendantâs conduct that is the subject of this action.
20. Ryan Dionne
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct.
21. Eva Anderson Dubin
1090 N. Lake Way, Palm Beach, FL 33480
1040 5th Avenue, #15, New York, NY 10028
Telephone number unknown at this time
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and has
information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking conduct and
interaction with underage minors.
22. Glen Dubin
1090 N. Lake Way, Palm Beach, FL 33480
1040 5th Avenue, #15, New York, NY 10028
Telephone number unknown at this time
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and has
information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking conduct and
interaction with underage minors.
23. Prince Andrew Albert Christian Edward, Duke of York
Buckingham Palace Rd, London SW1A 1AA
Tel: 020 7766 7300
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors, including Virginia Giuffre.
24. Jeffrey Epstein
c/o Tonja Haddad Coleman, Esq.
315 SE 7th Street, Suite 301
Fort Lauderdale, FL 33301
Tel: (954) 467-1223
and
c/o Marty Weinberg, Esq.
20 Park Plaza, Suite 1000, Boston, MA 02116
Tel: (617) 227-3700
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Has knowledge of Defendantâs conduct that is the subject of this action and
knowledge of his sexual trafficking operation and other co-conspirators.
25. Tatiana Espinoza
Address unknown at this time
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors.
26. Frederic Fekkai
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Defendantâs conduct that is the subject of this action.
27. Tony Figueroa
104 Houston School Ct, Red Oak, TX 75154
Telephone number unknown at this time
Has knowledge of Defendantâs conduct that is the subject of this action.
28. Luciano âJojoâ Fontanilla
18 Teneyck Avenue, Valley Stream, NY 11580-4016
917-975-4500
Jeffrey Epstein's staff member in his various homes and may have knowledge of
Defendant and Jeffrey Epsteinâs inappropriate conduct with underage girls.
29. Lynn Fontanilla
18 Teneyck Avenue, Valley Stream, NY 11580-4016
Telephone number unknown at this time
May have knowledge of Defendantâs conduct that is the subject of this action.
30. Michael Friedman
53320 Avenida Madero, La Quinta, CA 92253
Telephone number unknown at this time
Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey
Epsteinâs sexual trafficking conduct and interaction with minors.
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31. Rosalie Friedman
53320 Avenida Madero, La Quinta, CA 92253
Telephone number unknown at this time
Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey
Epsteinâs sexual trafficking conduct and interaction with minors.
32. Tiffany Kathryn Gramza
3927 Downey Ct, Simi Valley, CA 93063-2836
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors
33. Eric Gany
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct.
34. Amanda Grant
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct.
35. Lesley Groff
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct.
36. Claire Hazel
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
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37. Shelly Harrison
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
38. Stephen Kaufman
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
39. Sarah Kensington Vickers formerly Sarah Kellen
50 S. Pointe Dr, Apt. 2304, Miami Beach, FL 33139
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interactions with minors.
40. Tatiana Kovylina
1 Central Park South, #1306, New York, NY 10019-1732
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
41. Banu Kucukkoylu
4712 Admiralty Way, # 383, Marina Del Rey, CA 90292
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
42. Adam Perry Lang
Address unknown at this time
Telephone number unknown at this time
Traveling chef for Jeffrey Epstein and Ghislaine Maxwell and may have knowledge
of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking conduct and interaction with
underage minors.
8
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43. Shelly Ann Lewis
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
44. Michael Liffman
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct.
45. Peter Listerman
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
46. Cindy Lopez
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
47. Melinda Lutz
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
48. Cheri Lynch
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
9
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49. Nadia Marcinko formerly Nadia Marcinkova
301 E. 66th Street, New York, NY 10065-6205
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
50. Todd Meister
101 Seminole Avenue, Palm Beach, FL 38480
Tel: (561) 650-0083
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
51. Brahakmana Mellawa
Address unknown at this time
Telephone number unknown at this time
House staff who may have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs
sexual trafficking conduct and interaction with underage minors.
52. Jayarukshi Mellawa
Address unknown at this time
Telephone number unknown at this time
House staff who may have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs
sexual trafficking conduct and interaction with underage minors.
53. George Mitchell
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
54. Bill Peadon
617 Piedmont Rd, West Palm Beach, FL 33405-1534
Telephone number unknown at this time
House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs
sexual trafficking conduct and interaction with underage minors.
10
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55. Francis Peadon
617 Piedmont Rd, West Palm Beach, FL 33405-1534
Telephone number unknown at this time
House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs
sexual trafficking conduct and interaction with underage minors.
56. Tom Pritzker
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
57. Louella Rabuyo
Address unknown at this time
Telephone unknown at this time
House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs
sexual trafficking conduct and interaction with underage minors.
58. Bill Richardson
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
59. Rinaldo Rizzo
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
60. Haley Robson
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
11
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61. David Rogers
c/o Bruce E. Reinhart, Esq.
Tel: (561) 202-6360
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
62. Adriana Ross formerly Adriana Mucinska
c/o Alan S. Ross, Esq.
Tel: (305) 858-9550
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
63. Johanna Sjoberg
c/o Marshall Dore Louis, Esq.
40 N.W. 3rd Street, Suite 200, Miami, FL 33128
Tel: (305) 374-0544
Worked for Jeffrey Epstein during the time when Virginia Giuffre was living and
traveling with Jeffrey Epstein and Ghislaine Maxwell. Johanna Sjobjerg was also present at an
occasion with Prince Andrew, Ghislaine Maxwell, and Virginia Giuffre when Ms. Giuffre was a
minor.
64. Kelly Spamm
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
65. Emmy Taylor
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
66. Evelyn Valenzuela
Address unknown at this time
Telephone number unknown at this time
12
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May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct.
67. Larry Visosky
c/o Bruce E. Reinhart, Esq.
Tel: (561) 202-6360
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
68. Leslie Wexner
c/o John W. Zeiger, Esq., Zeiger, Tigges & Little LLP
41 South High Street, Suite 3500, Columbus, Ohio 43215
Tel: (614) 365-9900
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors..
69. Igor Zinoview
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
70. All other then-minor girls, recruited by Ghislaine Maxwell, whose identities Ms.
Giuffre will attempt to determine, with whom Defendant, Ghislaine Maxwell and
Jeffrey Epstein, have engaged in sexual activity.
71. All pilots, chauffeurs, chefs, and other employees of either Defendant Maxwell or
Jeffrey Epstein with knowledge of Defendant and Jeffrey Epsteinâs inappropriate
conduct with underage girls.
72. All staff and employees at the Mar-a-Lago Club during 1999-2002.
73. All other witnesses learned through discovery process.
B. Exhibits:
1. Palm Beach Police Department report and documents contained within Jeffrey
Epstein's criminal files, attached hereto as Exhibit 1.
13
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2. March 10, 2011 Statement on behalf of Ghislaine Maxwell by Media agent Ross
Gow, attached hereto as Exhibit 2.
3. September 3, 2008 Victim Notification Letter, attached hereto as Exhibit 3.
4. May 1, 2009 Complaint in Jane Doe No. 102 v. Jeffrey Epstein, CIV-09-80656, in
the Southern District of Florida, attached hereto as Exhibit 4.
5. FBI 302 Statement, attached hereto as Exhibit 5.
6. Flight Logs, attached hereto as Composite Exhibit 6.
7. Message Pads from Law Enforcement from trash pull of Jeffrey Epsteinâs Palm
Beach home, attached hereto as Exhibit 7.
8. Jeffrey Epsteinâs Phone Book, also referred to as his âBlack Book,â attached hereto
as Exhibit 8.
9. Deposition of Sarah Kellen, attached hereto as Composite Exhibit 9.
10. Deposition Transcripts of Juan Alessi, attached hereto as Exhibit 10.
11. Deposition Transcripts of Alfredo Rodriguez, attached hereto as Exhibit 11.
12. January 2, 2015 Corrected Joinder Motion [DE 280] filed in the CVRA action
pending in the Southern District of Florida, attached hereto as Exhibit 12. [All
paragraphs between âThe Government then concealed from Jane Doe No. 3
the existence of the NPA (pg. 3) and âThe Government was well aware of Jane
Doe No. 3 when it was negotiating the NPAâ (pg. 6) were stricken by Judge
Marra.]
13. January 21, 2015 Declaration of Jane Doe No. 3 filed in the CVRA action pending
in the Southern District of Florida, attached hereto as Exhibit 13. [Paragraphs 4, 5,
7, 11, 13, 15, 19-53, and 59 were stricken by Judge Marra]
14. February 6, 2015 Declaration of Jane Doe No. 3 filed in the CVRA action pending
in the Southern District of Florida, attached hereto as Exhibit 14. [Paragraphs 7-
12, 16, 39 and 49 were stricken by Judge Marra.]
15. November 25, 2015 Affidavit of Virginia Giuffre, filed in the Bradley Edwards and
Paul Cassell v. Alan Dershowitz matter, pending in the Seventeenth Judicial
Circuit, Broward County, Florida, attached hereto as Exhibit 15.
16. Virginia Robertsâ passport, attached hereto as Exhibit 16.
17. Judge Thomas Lynchâs January 12, 2016 Confidentiality Order regarding Virginia
Giuffreâs deposition, attached hereto as Exhibit 17.
18. Documents produced and bates labelled Non-Party VR 000001 â Non-Party VR
000644, in the Bradley Edwards and Paul Cassell v. Alan Dershowitz matter,
14
Case 1:15-cv-07433-LAP Document 69-2 Filed 03/23/16 Page 16 of 21
pending in the Seventeenth Judicial Circuit, Broward County, Florida, attached
hereto as Exhibit 18.
19. Victims Refuse Silence Articles of Incorporation and Amendment, attached hereto
as Composite Exhibit 19.
20. Victims Refuse Silence By-laws, attached hereto as Exhibit 20.
21. Victims Refuse Silence 2016 Annual Report, attached hereto as Exhibit 21.
22. January 3, 2015 Daily Mail article: âHarvard Law Professor Named Alongside
Prince Andrew in âSex Slaveâ Case Accuses Alleged Victim of âMaking Up
Stories,ââ attached hereto as Exhibit 22.
23. January 3, 2015 Press Statement issued by Ross Gow to Express set forth in
âGhislaine Maxwell: I was not a madam for paedophile,â attached as Exhibit 23.
24. January 4, 2015 Statement by Ghislaine Maxwell to New York Daily News
Reporter âAlleged Madam Accused of Supplying Prince Andrew With Underage
Teen for Sex Spotted in NYC â As Heâs Seen Cutting Swiss Vacation Short to Face
Queen,â attached hereto as Exhibit 24.
25. February 1, 2015 Mirror article: âPrince Andrewâs Pal Ghislaine Maxwell May Sue
Over Madam Allegations,â attached hereto as Exhibit 25.
26. September 23, 2007 Red Ice Creations Article âPrince Andrewâs Friend, Ghislaine
Maxwell, Some Underage Girls, and A Very Disturbing Story,â attached hereto as
Exhibit 26.
27. Photographs, attached hereto as Exhibit 27.
28. April 13, 2010 Deposition Transcript of Nadia Marcinkova, attached hereto as
Exhibit 28.
C. Computation of damages:
1. Physical, psychological and psychiatric injuries and resulting medical expenses â in
an amount of approximately $ 102,200 present value.
a. Computation Analysis:
i. Giuffre has had to receive treatment for the psychological harm as a
result of Maxwellâs conduct towards Giuffre.
ii. The average annual expenditures for mental health services for adults
18-64 in the United States is $1,751.
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iii. Giuffre needs continuing care as a result of the harm she has suffered.
Ms. Giuffre was born August 9, 1983 and was 31.4 years old at the
beginning of 2015 when the alleged harm occurred. The average
remaining life expectancy for a 31 year old female is 51.1 years.
iv. Based on a remaining life expectancy of 51.1 years, annual healthcare
cost growth of 3.3% and a discount rate of 2.7%, the present value of
expected treatment costs is $102,200 as of 1/1/2015.
b. Supporting Evidence:
i. Ms. Giuffre is in the process of collecting records from her physicians
ii. Ms. Giuffreâs testimony
iii. Ms. Giuffre is in the process of retaining an expert to calculate
damages, and will provide further information through expert
disclosure.
2. Past, present and future pain and suffering, mental anguish, humiliation,
embarrassment, loss of self-esteem, loss of standing in the community, loss of
dignity and invasion of privacy in her public and private life not less than
$30,000,000.00.
a. Computation Analysis
i. Under New York law, defamation per se as alleged in this case
presumes damages and special damages do not need to be plead and
proven. See Celle v. Filipino Reporter Enterprises Inc., 209 F.3d 163,
179 (2nd Cir. 2000) (Second Circuit holding that â[i]f a statement is
defamatory per se, injury is assumed. In such a case âeven where the
plaintiff can show no actual damages at all, a plaintiff who has
otherwise shown defamation may recover at least nominal damagesâ
and the Second Circuit also confirmed an award of punitive
damages). Ms. Giuffre has been severely damaged by the defamation
of the defendant, by calling her claims of sexual abuse âobvious liesâ.
The defamation caused Ms. Giuffre to re-live the sexual abuse she
previously endured. Ms. Giuffre has suffered and continues to suffer
from the pain, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of standing in the community, loss of dignity and
invasion of privacy in her public and private life. The computation of
this amount is in the province of the jury but Ms. Giuffre contends,
including but not limited to, awards in other similar matters, that the
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amount is not less than $30,000,000.00. Ms. Giuffre is in the process
of retaining an expert, and will provide further information through
expert disclosure.
b. Supporting Evidence
i. Ms. Giuffreâs testimony
ii. Witness testimony
iii. Awards in similar matters
iv. Ms. Giuffre is in the process of retaining an expert, and will provide
further information through expert disclosure.
3. Estimated lost income of $180,000 annually. Present value of $3,461,000 to
$5,407,000.
a. Computation Analysis
i. Ms. Giuffreâs estimated compensation capacity is $180,000 annually.
Ms. Giuffre was born August 9, 1983 and was 31.4 years old at the
beginning of 2015 when the alleged injury occurred. Her expected
remaining work life based on mortality and probability of continued
work was 20.2 years. Based on these factors, a 2% annual growth rate
and a 2.4% discount rate, the present value of lost compensation is
$3,461,000 as of 1/1/2015.
ii. Alternatively, if Ms. Giuffre is assumed to work until a normal
retirement age of 65, or 33.6 years from her age at the beginning of
2015, and based on an annual growth rate of 2.0% and a discount rate
of 2.7%, the present value of lost compensation is $5,407,000 as of
1/1/2015.
b. Supporting Evidence
i. Materials regarding compensation and work life expectancy
1) 2010 Life Table for Females, National Vital Statistics Report,
November 6, 2014, U.S. Department of Health & Human
Services, Centers for Disease Control & Prevention, National
Center for Health Statistics.
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2) âCalculation of Work life Expectancy Using the Life,
Participation, Employment Method,â Vocational Econometrics,
Inc.
3) Consumer Price Index for Urban Wage Earners and Clerical
Workers, United States Department of Labor, Bureau of Labor
Statistics.
4) Federal Reserve Statistical Release H.15, 1/5/2015.
ii. Ms. Giuffreâs testimony
iii. Ms. Giuffre is in the process of retaining a damages expert and will provide
further information through expert disclosures.
4. Punitive Damages - to be based upon all relevant factors, including the egregious
nature of Defendant, Ghislaine Maxwellâs conduct and the need for a large award to
punish and deter conduct in view of the vast wealth of Defendant Maxwell, in an
amount not less than $50,000,000.00.
a. This calculation is in the province of the jury.
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Dated March 11, 2016
Respectfully Submitted,
BOIES, SCHILLER & FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid McCawley (Pro Hac Vice)
Boies Schiller & Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale, FL 33301
(954) 356-0011
David Boies
Boies Schiller & Flexner LLP
333 Main Street
Armonk, NY 10504
Ellen Brockman
Boies Schiller & Flexner LLP
575 Lexington Ave
New York, New York 10022
(212) 446-2300
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CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the above and foregoing
Disclosure Pursuant to Fed. R. Civ. P. 26 has been provided by United States mail and electronic
mail to all counsel of record identified below, on this 11th day of March, 2016.
Laura A. Menninger, Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Tel: (303) 831-7364
Fax: (303) 832-2628
Email: [email protected]
By: /s/ Sigrid McCawley______
Sigrid McCawley
20
EXHIBIT 2
Case 1:15-cv-07433-LAP Document 69-2 Filed 03/23/16 Page 2 of 21
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF, VIRGINIA GIUFFREâS REVISED DISCLOSURE
PURSUANT TO FED. R. CIV. P. 26
COMES NOW the Plaintiff, Virginia L. Giuffre, by and through her undersigned counsel,
and serves this revised disclosure pursuant to Fed. R. Civ. P. 26 and states as follows:
A. Witnesses:
1. Virginia L. Giuffre
c/o Sigrid S. McCawley, Esq.
Boies, Schiller & Flexner LLP
401 East Las Olas Boulevard, Suite 1200
Miami, Florida 33301
Tel: (954) 356-0011
Email: [email protected]
Plaintiff - information regarding Defendant, Ghislaine Maxwellâs conduct that is
the subject of this action
2. Ghislaine Maxwell
c/o Laura A. Menninger, Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Tel: (303) 831-7364
Email: [email protected]
Defendant in this action.
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3. Juan Alessi
6791 Fairway Lakes Drive, Boynton Beach, FL 33472
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors.
4. Maria Alessi
6791 Fairway Lakes Drive, Boynton Beach, FL 33472
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors.
5. Doug Band
President of Teneo Holdings, 601 Lexington Avenue, 45th Floor,
New York, NY 10022, Tel: (212) 886-1600
Was present on flights with Jeffrey Epstein and Ghislaine Maxwell and President
Clinton and may have knowledge of Jeffrey Epstein and Ghislaine Maxwellâs sexual trafficking
conduct and interactions with minors.
6. Gwendolyn Beck
P.O. Box 705, Arlington, VA 22216
(703) 656-6007
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors.
7. Sophie Biddle
388 W. Carmel Valley Road, Carmel Valley, CA 93924
Tel: (310) 394-7048
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors.
8. Nadia Bjorlin
c/o Cris Armenta, Esq.
11900 Olympic Blvd., Suite 730, Los Angeles, CA 90064
Tel: (310) 826-2826
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Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and Virginia
Guiffre and may have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors.
9. Kelly Bovino
16694 Via La Costa, Pacific Palisades, CA 90272
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors.
10. Jean Luc Brunel
c/o Joe Titone, Esq.
621 South East 5th Street, Pompano Beach, FL 33060
Tel: (954) 729-6490
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and Virginia
Guiffre and has information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
11. Ron Burkle
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct.
12. Dana Burns
Address unknown at this time.
Telephone number unknown at this time
Worked for Ghislaine Maxwell and has information about Ghislaine Maxwellâs
recruiting of girls for Jeffrey Epstein.
13. Alyson Chambers
c/o Marshall Dore Louis, Esq.
Sinclair, Louis & Zavertnik, P.A.
40 N.W. 3rd Street, Suite 200, Miami, FL 33128
Tel: (305) 374-0544
Worked for Jeffrey Epstein as a masseuse during the time that Virginia Giuffre was
living and traveling with Jeffrey Epstein and Ghislaine Maxwell, and has information about
Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking conduct.
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14. Maximilia Cordero
Address unknown at this time
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct.
15. Valdson Cotrin
Address unknown at this time
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct.
16. Chauntae Davies
1017 N. Spaulding Avenue, #8, West Hollywood, CA 90056
Telephone number unknown at this time
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and may have
information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking conduct and
interaction with underage minors.
17. Teala Davies
1212 N. Clark Street, Apt. #7, West Hollywood, CA 90069
Telephone number unknown at this time
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and may have
information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking conduct and
interaction with underage minors.
18. Anouska DeGeorgieou
536 N. Edinburgh Avenue, Los Angeles, CA 90048
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors.
19. Alan Dershowitz
c/o Richard A. Simpson, Esq.
WILEY REIN, LLP
1776 K Street NW
Washington, D.C. 20006
Tel: (202) 719-7000
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Has knowledge of Defendantâs conduct that is the subject of this action.
20. Ryan Dionne
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct.
21. Eva Anderson Dubin
1090 N. Lake Way, Palm Beach, FL 33480
1040 5th Avenue, #15, New York, NY 10028
Telephone number unknown at this time
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and has
information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking conduct and
interaction with underage minors.
22. Glen Dubin
1090 N. Lake Way, Palm Beach, FL 33480
1040 5th Avenue, #15, New York, NY 10028
Telephone number unknown at this time
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and has
information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking conduct and
interaction with underage minors.
23. Prince Andrew Albert Christian Edward, Duke of York
Buckingham Palace Rd, London SW1A 1AA
Tel: 020 7766 7300
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors, including Virginia Giuffre.
24. Jeffrey Epstein
c/o Tonja Haddad Coleman, Esq.
315 SE 7th Street, Suite 301
Fort Lauderdale, FL 33301
Tel: (954) 467-1223
and
c/o Marty Weinberg, Esq.
20 Park Plaza, Suite 1000, Boston, MA 02116
Tel: (617) 227-3700
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Has knowledge of Defendantâs conduct that is the subject of this action and
knowledge of his sexual trafficking operation and other co-conspirators.
25. Tatiana Espinoza
Address unknown at this time
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors.
26. Frederic Fekkai
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Defendantâs conduct that is the subject of this action.
27. Tony Figueroa
104 Houston School Ct, Red Oak, TX 75154
Telephone number unknown at this time
Has knowledge of Defendantâs conduct that is the subject of this action.
28. Luciano âJojoâ Fontanilla
18 Teneyck Avenue, Valley Stream, NY 11580-4016
917-975-4500
Jeffrey Epstein's staff member in his various homes and may have knowledge of
Defendant and Jeffrey Epsteinâs inappropriate conduct with underage girls.
29. Lynn Fontanilla
18 Teneyck Avenue, Valley Stream, NY 11580-4016
Telephone number unknown at this time
May have knowledge of Defendantâs conduct that is the subject of this action.
30. Michael Friedman
53320 Avenida Madero, La Quinta, CA 92253
Telephone number unknown at this time
Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey
Epsteinâs sexual trafficking conduct and interaction with minors.
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31. Rosalie Friedman
53320 Avenida Madero, La Quinta, CA 92253
Telephone number unknown at this time
Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey
Epsteinâs sexual trafficking conduct and interaction with minors.
32. Tiffany Kathryn Gramza
3927 Downey Ct, Simi Valley, CA 93063-2836
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epsteinâs sexual
trafficking conduct and interaction with underage minors
33. Eric Gany
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct.
34. Amanda Grant
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct.
35. Lesley Groff
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct.
36. Claire Hazel
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
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37. Shelly Harrison
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
38. Stephen Kaufman
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
39. Sarah Kensington Vickers formerly Sarah Kellen
50 S. Pointe Dr, Apt. 2304, Miami Beach, FL 33139
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interactions with minors.
40. Tatiana Kovylina
1 Central Park South, #1306, New York, NY 10019-1732
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
41. Banu Kucukkoylu
4712 Admiralty Way, # 383, Marina Del Rey, CA 90292
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
42. Adam Perry Lang
Address unknown at this time
Telephone number unknown at this time
Traveling chef for Jeffrey Epstein and Ghislaine Maxwell and may have knowledge
of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking conduct and interaction with
underage minors.
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43. Shelly Ann Lewis
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
44. Michael Liffman
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct.
45. Peter Listerman
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
46. Cindy Lopez
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
47. Melinda Lutz
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
48. Cheri Lynch
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
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Case 1:15-cv-07433-LAP Document 69-2 Filed 03/23/16 Page 11 of 21
49. Nadia Marcinko formerly Nadia Marcinkova
301 E. 66th Street, New York, NY 10065-6205
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
50. Todd Meister
101 Seminole Avenue, Palm Beach, FL 38480
Tel: (561) 650-0083
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors
51. Brahakmana Mellawa
Address unknown at this time
Telephone number unknown at this time
House staff who may have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs
sexual trafficking conduct and interaction with underage minors.
52. Jayarukshi Mellawa
Address unknown at this time
Telephone number unknown at this time
House staff who may have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs
sexual trafficking conduct and interaction with underage minors.
53. George Mitchell
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
54. Bill Peadon
617 Piedmont Rd, West Palm Beach, FL 33405-1534
Telephone number unknown at this time
House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs
sexual trafficking conduct and interaction with underage minors.
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55. Francis Peadon
617 Piedmont Rd, West Palm Beach, FL 33405-1534
Telephone number unknown at this time
House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs
sexual trafficking conduct and interaction with underage minors.
56. Tom Pritzker
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
57. Louella Rabuyo
Address unknown at this time
Telephone unknown at this time
House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs
sexual trafficking conduct and interaction with underage minors.
58. Bill Richardson
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
59. Rinaldo Rizzo
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
60. Haley Robson
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
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Case 1:15-cv-07433-LAP Document 69-2 Filed 03/23/16 Page 13 of 21
61. David Rogers
c/o Bruce E. Reinhart, Esq.
Tel: (561) 202-6360
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
62. Adriana Ross formerly Adriana Mucinska
c/o Alan S. Ross, Esq.
Tel: (305) 858-9550
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
63. Johanna Sjoberg
c/o Marshall Dore Louis, Esq.
40 N.W. 3rd Street, Suite 200, Miami, FL 33128
Tel: (305) 374-0544
Worked for Jeffrey Epstein during the time when Virginia Giuffre was living and
traveling with Jeffrey Epstein and Ghislaine Maxwell. Johanna Sjobjerg was also present at an
occasion with Prince Andrew, Ghislaine Maxwell, and Virginia Giuffre when Ms. Giuffre was a
minor.
64. Kelly Spamm
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
65. Emmy Taylor
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
66. Evelyn Valenzuela
Address unknown at this time
Telephone number unknown at this time
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May have knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct.
67. Larry Visosky
c/o Bruce E. Reinhart, Esq.
Tel: (561) 202-6360
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
68. Leslie Wexner
c/o John W. Zeiger, Esq., Zeiger, Tigges & Little LLP
41 South High Street, Suite 3500, Columbus, Ohio 43215
Tel: (614) 365-9900
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors..
69. Igor Zinoview
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epsteinâs sexual trafficking
conduct and interaction with underage minors.
70. All other then-minor girls, recruited by Ghislaine Maxwell, whose identities Ms.
Giuffre will attempt to determine, with whom Defendant, Ghislaine Maxwell and
Jeffrey Epstein, have engaged in sexual activity.
71. All pilots, chauffeurs, chefs, and other employees of either Defendant Maxwell or
Jeffrey Epstein with knowledge of Defendant and Jeffrey Epsteinâs inappropriate
conduct with underage girls.
72. All staff and employees at the Mar-a-Lago Club during 1999-2002.
73. All other witnesses learned through discovery process.
B. Exhibits:
1. Palm Beach Police Department report and documents contained within Jeffrey
Epstein's criminal files, attached hereto as Exhibit 1.
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2. March 10, 2011 Statement on behalf of Ghislaine Maxwell by Media agent Ross
Gow, attached hereto as Exhibit 2.
3. September 3, 2008 Victim Notification Letter, attached hereto as Exhibit 3.
4. May 1, 2009 Complaint in Jane Doe No. 102 v. Jeffrey Epstein, CIV-09-80656, in
the Southern District of Florida, attached hereto as Exhibit 4.
5. FBI 302 Statement, attached hereto as Exhibit 5.
6. Flight Logs, attached hereto as Composite Exhibit 6.
7. Message Pads from Law Enforcement from trash pull of Jeffrey Epsteinâs Palm
Beach home, attached hereto as Exhibit 7.
8. Jeffrey Epsteinâs Phone Book, also referred to as his âBlack Book,â attached hereto
as Exhibit 8.
9. Deposition of Sarah Kellen, attached hereto as Composite Exhibit 9.
10. Deposition Transcripts of Juan Alessi, attached hereto as Exhibit 10.
11. Deposition Transcripts of Alfredo Rodriguez, attached hereto as Exhibit 11.
12. January 2, 2015 Corrected Joinder Motion [DE 280] filed in the CVRA action
pending in the Southern District of Florida, attached hereto as Exhibit 12. [All
paragraphs between âThe Government then concealed from Jane Doe No. 3
the existence of the NPA (pg. 3) and âThe Government was well aware of Jane
Doe No. 3 when it was negotiating the NPAâ (pg. 6) were stricken by Judge
Marra.]
13. January 21, 2015 Declaration of Jane Doe No. 3 filed in the CVRA action pending
in the Southern District of Florida, attached hereto as Exhibit 13. [Paragraphs 4, 5,
7, 11, 13, 15, 19-53, and 59 were stricken by Judge Marra]
14. February 6, 2015 Declaration of Jane Doe No. 3 filed in the CVRA action pending
in the Southern District of Florida, attached hereto as Exhibit 14. [Paragraphs 7-
12, 16, 39 and 49 were stricken by Judge Marra.]
15. November 25, 2015 Affidavit of Virginia Giuffre, filed in the Bradley Edwards and
Paul Cassell v. Alan Dershowitz matter, pending in the Seventeenth Judicial
Circuit, Broward County, Florida, attached hereto as Exhibit 15.
16. Virginia Robertsâ passport, attached hereto as Exhibit 16.
17. Judge Thomas Lynchâs January 12, 2016 Confidentiality Order regarding Virginia
Giuffreâs deposition, attached hereto as Exhibit 17.
18. Documents produced and bates labelled Non-Party VR 000001 â Non-Party VR
000644, in the Bradley Edwards and Paul Cassell v. Alan Dershowitz matter,
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Case 1:15-cv-07433-LAP Document 69-2 Filed 03/23/16 Page 16 of 21
pending in the Seventeenth Judicial Circuit, Broward County, Florida, attached
hereto as Exhibit 18.
19. Victims Refuse Silence Articles of Incorporation and Amendment, attached hereto
as Composite Exhibit 19.
20. Victims Refuse Silence By-laws, attached hereto as Exhibit 20.
21. Victims Refuse Silence 2016 Annual Report, attached hereto as Exhibit 21.
22. January 3, 2015 Daily Mail article: âHarvard Law Professor Named Alongside
Prince Andrew in âSex Slaveâ Case Accuses Alleged Victim of âMaking Up
Stories,ââ attached hereto as Exhibit 22.
23. January 3, 2015 Press Statement issued by Ross Gow to Express set forth in
âGhislaine Maxwell: I was not a madam for paedophile,â attached as Exhibit 23.
24. January 4, 2015 Statement by Ghislaine Maxwell to New York Daily News
Reporter âAlleged Madam Accused of Supplying Prince Andrew With Underage
Teen for Sex Spotted in NYC â As Heâs Seen Cutting Swiss Vacation Short to Face
Queen,â attached hereto as Exhibit 24.
25. February 1, 2015 Mirror article: âPrince Andrewâs Pal Ghislaine Maxwell May Sue
Over Madam Allegations,â attached hereto as Exhibit 25.
26. September 23, 2007 Red Ice Creations Article âPrince Andrewâs Friend, Ghislaine
Maxwell, Some Underage Girls, and A Very Disturbing Story,â attached hereto as
Exhibit 26.
27. Photographs, attached hereto as Exhibit 27.
28. April 13, 2010 Deposition Transcript of Nadia Marcinkova, attached hereto as
Exhibit 28.
C. Computation of damages:
1. Physical, psychological and psychiatric injuries and resulting medical expenses â in
an amount of approximately $ 102,200 present value.
a. Computation Analysis:
i. Giuffre has had to receive treatment for the psychological harm as a
result of Maxwellâs conduct towards Giuffre.
ii. The average annual expenditures for mental health services for adults
18-64 in the United States is $1,751.
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iii. Giuffre needs continuing care as a result of the harm she has suffered.
Ms. Giuffre was born August 9, 1983 and was 31.4 years old at the
beginning of 2015 when the alleged harm occurred. The average
remaining life expectancy for a 31 year old female is 51.1 years.
iv. Based on a remaining life expectancy of 51.1 years, annual healthcare
cost growth of 3.3% and a discount rate of 2.7%, the present value of
expected treatment costs is $102,200 as of 1/1/2015.
b. Supporting Evidence:
i. Ms. Giuffre is in the process of collecting records from her physicians
ii. Ms. Giuffreâs testimony
iii. Ms. Giuffre is in the process of retaining an expert to calculate
damages, and will provide further information through expert
disclosure.
2. Past, present and future pain and suffering, mental anguish, humiliation,
embarrassment, loss of self-esteem, loss of standing in the community, loss of
dignity and invasion of privacy in her public and private life not less than
$30,000,000.00.
a. Computation Analysis
i. Under New York law, defamation per se as alleged in this case
presumes damages and special damages do not need to be plead and
proven. See Celle v. Filipino Reporter Enterprises Inc., 209 F.3d 163,
179 (2nd Cir. 2000) (Second Circuit holding that â[i]f a statement is
defamatory per se, injury is assumed. In such a case âeven where the
plaintiff can show no actual damages at all, a plaintiff who has
otherwise shown defamation may recover at least nominal damagesâ
and the Second Circuit also confirmed an award of punitive
damages). Ms. Giuffre has been severely damaged by the defamation
of the defendant, by calling her claims of sexual abuse âobvious liesâ.
The defamation caused Ms. Giuffre to re-live the sexual abuse she
previously endured. Ms. Giuffre has suffered and continues to suffer
from the pain, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of standing in the community, loss of dignity and
invasion of privacy in her public and private life. The computation of
this amount is in the province of the jury but Ms. Giuffre contends,
including but not limited to, awards in other similar matters, that the
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amount is not less than $30,000,000.00. Ms. Giuffre is in the process
of retaining an expert, and will provide further information through
expert disclosure.
b. Supporting Evidence
i. Ms. Giuffreâs testimony
ii. Witness testimony
iii. Awards in similar matters
iv. Ms. Giuffre is in the process of retaining an expert, and will provide
further information through expert disclosure.
3. Estimated lost income of $180,000 annually. Present value of $3,461,000 to
$5,407,000.
a. Computation Analysis
i. Ms. Giuffreâs estimated compensation capacity is $180,000 annually.
Ms. Giuffre was born August 9, 1983 and was 31.4 years old at the
beginning of 2015 when the alleged injury occurred. Her expected
remaining work life based on mortality and probability of continued
work was 20.2 years. Based on these factors, a 2% annual growth rate
and a 2.4% discount rate, the present value of lost compensation is
$3,461,000 as of 1/1/2015.
ii. Alternatively, if Ms. Giuffre is assumed to work until a normal
retirement age of 65, or 33.6 years from her age at the beginning of
2015, and based on an annual growth rate of 2.0% and a discount rate
of 2.7%, the present value of lost compensation is $5,407,000 as of
1/1/2015.
b. Supporting Evidence
i. Materials regarding compensation and work life expectancy
1) 2010 Life Table for Females, National Vital Statistics Report,
November 6, 2014, U.S. Department of Health & Human
Services, Centers for Disease Control & Prevention, National
Center for Health Statistics.
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2) âCalculation of Work life Expectancy Using the Life,
Participation, Employment Method,â Vocational Econometrics,
Inc.
3) Consumer Price Index for Urban Wage Earners and Clerical
Workers, United States Department of Labor, Bureau of Labor
Statistics.
4) Federal Reserve Statistical Release H.15, 1/5/2015.
ii. Ms. Giuffreâs testimony
iii. Ms. Giuffre is in the process of retaining a damages expert and will provide
further information through expert disclosures.
4. Punitive Damages - to be based upon all relevant factors, including the egregious
nature of Defendant, Ghislaine Maxwellâs conduct and the need for a large award to
punish and deter conduct in view of the vast wealth of Defendant Maxwell, in an
amount not less than $50,000,000.00.
a. This calculation is in the province of the jury.
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Dated March 11, 2016
Respectfully Submitted,
BOIES, SCHILLER & FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid McCawley (Pro Hac Vice)
Boies Schiller & Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale, FL 33301
(954) 356-0011
David Boies
Boies Schiller & Flexner LLP
333 Main Street
Armonk, NY 10504
Ellen Brockman
Boies Schiller & Flexner LLP
575 Lexington Ave
New York, New York 10022
(212) 446-2300
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CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the above and foregoing
Disclosure Pursuant to Fed. R. Civ. P. 26 has been provided by United States mail and electronic
mail to all counsel of record identified below, on this 11th day of March, 2016.
Laura A. Menninger, Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Tel: (303) 831-7364
Fax: (303) 832-2628
Email: [email protected]
By: /s/ Sigrid McCawley______
Sigrid McCawley
20