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Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 1 of 26
EXHIBITD
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 2 of 26
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
V.
Ghislaine Maxwell,
Defendant.
- - - - - - - - - - - - - -I
PLAINTIFF, VIRGINIA GIUFFRE'S FOURTH 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 Maxwell's 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.
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 3 of 26
3. Juan Alessi
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
4. Maria Alessi
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
5. Kathy Alexander
Address unknown at this time.
Telephone number unknown at this time.
Believed to be in South Africa.
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
6. Miles Alexander
Address unknown at this time.
Telephone number unknown at this time.
Believed to be in South Africa.
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
7. Doug Band
President of Teneo Holdings, 601 Lexington Avenue, 45 th 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 Maxwell's sexual trafficking
conduct and interactions with minors.
8. Gwendolyn Beck
2
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 4 of 26
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
9. Sophie Biddle
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
10.
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and Virginia
Guiffre and may have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
11. Fary Bjorlin
Address Unknown
Telephone Number Uknown
May have information relating to Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
12. Kelly Bovino
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
13. Jean Luc Brunel
c/o Joe Titone, Esq.
621 South East 5th Street, Pompano Beach, FL 33060
Tel: (954) 729-6490
3
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 5 of 26
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and Virginia
Guiffre and has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
14. Ron Burkle
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
15. -
Address unknown at this time.
Telephone number unknown at this time
Worked for Ghislaine Maxwell and has information about Ghislaine Maxwell's
recruiting of girls for Jeffrey Epstein.
16. Carolyn Casey
Address unknown at this time.
Telephone number unknown at this time.
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
17. 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 Epstein's sexual trafficking conduct.
18. William Jefferson Clinton
55 West 125 Street
New York, NY 10027
Travelled with Jeffrey Epstein and Ghislaine Maxwell and may have information
about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct.
4
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 6 of 26
19. Maximilia Cordero
Address unknown at this time
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct.
20. Valdson Cotrin
Address unknown at this time
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct.
21. Chauntae Davies
Telephone number unknown at this time
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and may have
information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and
interaction with underage minors.
22. Teala Davies
Telephone number unknown at this time
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and may have
information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and
interaction with underage minors.
23. Anouska DeGeorgieou
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
24. Alan Dershowitz
c/o Richard A. Simpson, Esq.
WILEY REIN, LLP
1776 K Street NW
Washington, D.C. 20006
5
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 7 of 26
Tel: (202) 719-7000
Has knowledge of Defendant's conduct that is the subject of this action.
25. Ryan Dionne
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
26. Eva Anderson Dubin
Telephone number unknown at this time
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and has
information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and
interaction with underage minors.
27. Glen Dubin
Telephone number unknown at this time
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and has
information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and
interaction with underage minors.
28.
Address unknown at this time.
Telephone number unknown at this time.
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
29. Prince Andrew Albert Christian Edward, Duke of York
Buckingham Palace Rd, London SWlA lAA
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors, including Virginia Giuffre.
6
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 8 of 26
30. Records Custodian for Travel for Prince Andrew Albert Christian Edward, Duke of
York
Buckingham Palace Rd, London SWlA lAA
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors, including Virginia Giuffre.
31. Jeffrey Epstein
c/o Marty Weinberg, Esq.
20 Park Plaza, Suite 1000, Boston, MA 02116
Has knowledge of Defendant's conduct that is the subject of this action and
knowledge of his sexual trafficking operation and other co-conspirators.
32. Tatiana Espinoza
Address unknown at this time
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
33. Annie Farmer
Address unknown at this time.
Telephone number unknown at this time.
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors, including Virginia Giuffre.
34. Marie Farmer
Address unknown at this time.
Telephone number unknown at this time.
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors, including Virginia Giuffre.
35. Vicky Ward
Address unknown at this time
Telephone unknown at this time
7
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 9 of 26
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors, including Virginia Giuffre.
36. Frederic Fekkai
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Defendant's conduct that is the subject of this action.
37. Tony Figueroa
Telephone number unknown at this time
Has knowledge of Defendant's conduct that is the subject of this action.
38. Luciano "Jojo" Fontanilla
Jeffrey Epstein's staff member in his various homes and may have knowledge of
Defendant and Jeffrey Epstein's inappropriate conduct with underage girls.
39. Lynn Fontanilla
Telephone number unknown at this time
May have knowledge of Defendant's conduct that is the subject of this action.
40. Michael Friedman
Telephone number unknown at this time
Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey
Epstein's sexual trafficking conduct and interaction with minors.
41. Rosalie Friedman
Telephone number unknown at this time
8
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 10 of 26
Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey
Epstein's sexual trafficking conduct and interaction with minors.
42. Ross Gow
Acuity Representation
23 Berkeley Square
London WU 6HE
Defendant's press agent who has knowledge of the defamatory statements in this
case.
43. Tiffany Kathryn Gramza
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors
44. -
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
45. Amanda Grant
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
46. Lesley Groff
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
47.
9
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 11 of 26
Has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and abuse and interaction with underage minors.
48. Claire Hazel
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
49. Shelly Harrison
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
50. Gina Ignatieva
Address Unknown
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
51. Brett Jaffe
Address noted on Defendant's Rule 26 disclosures
Defendant's attorney.
52.
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
10
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 12 of 26
53. Sarah Kensington Vickers formerly Sarah Kellen
c/o Bruce Reinhart, Esq.
McDonald Hopkins LLC
505 S Flagler Dr Ste 300
West Palm Beach, FL 33401-5942
Tel: 561- 472-2121
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interactions with minors.
54. Tatiana Kovylina
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
55.
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
56. 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 Epstein's sexual trafficking conduct and interaction with
underage minors.
57.
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
58. Michael Liffman
11
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 13 of 26
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
59. Peter Listerman
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
60. Cindy Lopez
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
61. Melinda Lutz
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
62. Cheri Lynch
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
63. Nadia Marcinko formerly Nadia Marcinkova
c/o Jack Goldberger, Esq.
Atterbury, Goldberger, & Weiss, P.A.
250 Australian Ave South, Ste 1400
West Palm Beach, FL 33401-5012
Tel: (561) 659-8300
12
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 14 of 26
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
64. Bob Meister
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
65. Todd Meister
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
66. Brahakmana Mellawa
Address unknown at this time
Telephone number unknown at this time
House staff who may have know ledge of Ghislaine Maxwell and Jeffrey Epstein's
sexual trafficking conduct and interaction with underage minors.
67. Jayarukshi Mellawa
Address unknown at this time
Telephone number unknown at this time
House staff who may have know ledge of Ghislaine Maxwell and Jeffrey Epstein's
sexual trafficking conduct and interaction with underage minors.
68.
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
69. Andrea Mitrovich
Address Unknown
Telephone number unknown at this time.
13
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 15 of 26
Knowledge of Defendant's conduct that is the subject of this action.
70. Bill Peadon
Telephone number unknown at this time
House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's
sexual trafficking conduct and interaction with underage minors.
71. Francis Peadon
Telephone number unknown at this time
House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's
sexual trafficking conduct and interaction with underage minors.
72. Tom Pritzker
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
73. Dara Preece
Address Unknown
Telephone Unknown at this time
May have knowledge of Defendant's conduct in this action.
74. Louella Rabuyo
Address unknown at this time
Telephone unknown at this time
House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's
sexual trafficking conduct and interaction with underage minors.
75. Joseph Recarey
Telephone number unknown at this time.
14
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 16 of 26
Detective Recarey was the chief investigator of the crimes committed at Jeffrey
Epstein's Palm Beach mansion and has information about Ghislaine Maxwell and Jeffrey
Epstein's sexual trafficking conduct and interaction with underage minors.
76. Chief Michael Reiter
Telephone number unknown at this time.
Police Chief Reiter oversaw the investigation of the crimes committed at Jeffrey
Epstein's Palm Beach mansion and has information about Ghislaine Maxwell and Jeffrey
Epstein's sexual trafficking conduct and abuse of underage minors.
77. Bill Richardson
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
78. Rinaldo Rizzo
c/o Robert Lewis, Esq.
Freeman Lewis LLP
228 E. 45 th Street, 1ih Floor
New York, NY 10017
Tel: 212-980-4084
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
79. Haley Robson
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
80. Sky Roberts
15
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 17 of 26
Family member who may have knowledge of Ghislaine Maxwell and Jeffrey
Epstein's sexual trafficking conduct and interaction with underage minors.
81. David Rodgers
c/o Bruce E. Reinhart, Esq.
McDonald Hopkins LLC
505 S Flagler Dr Ste 300
West Palm Beach, FL 33401-5942
Tel: 561- 472-2121
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
82. Adriana Ross formerly Adriana Mucinska
c/o Alan S. Ross, Esq.
Tel: (305) 858-9550
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
83. 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
mmor.
84. Kelly Spamm
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
85. Cecilia Stein
Address unknown at this time
Telephone number unknown at this time
16
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 18 of 26
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
86. Emmy Taylor
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
87. Evelyn Valenzuela
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
88. 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 Epstein's sexual trafficking
conduct and interaction with underage minors.
89. 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 Epstein's sexual trafficking
conduct and interaction with underage minors.
90. Courtney Wild
c/o Bradley Edwards, Esq.
FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Tel: (954) 524-2820
17
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 19 of 26
Has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
91. Doug Wilson
Family member who may have knowledge of Ghislaine Maxwell and Jeffrey
Epstein's sexual trafficking conduct and interaction with underage minors.
92. Igor Zinoview
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
93. All females identified in the police reports or identified through the United State's
Attorney's office during or through the criminal investigation of Jeffrey Epstein
and his co-conspirators.
94. 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.
95. All pilots, chauffeurs, chefs, and other employees of either Defendant Maxwell or
Jeffrey Epstein with knowledge of Defendant and Jeffrey Epstein's inappropriate
conduct with underage girls.
96. All staff and employees at the Mar-a-Lago Club during 1999-2002.
97. All other witnesses learned through discovery process.
B. Relevant Documents:
1. All files held by the Palm Beach Police Department or the Palm Beach State
Attorney's office which are publically available.
2. All press releases of Ghislaine Maxwell or on her behalf
18
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 20 of 26
3. The video(s) of Ghislaine Maxwell adopting the January, 2015 press statement.
4. All newspaper or other media where Ghislaine Maxwell's press release appears
5. All evidence obtained by the Federal Bureau of Investigations which relate in any way
to Jeffrey Epstein or Ghislaine Maxwell.
6. All 302 statements that relate in any way to Jeffrey Epstein or Ghislaine Maxwell.
7. All evidence obtained by the FBI or United States Attorney's office by or through the
criminal investigation of Alfredo Rodriguez.
8. All documents relating to the previous subpoenas served on Defendant for her
deposition and all documents related in any way to that deposition.
9. All documents evidencing visitors or passengers at any of Jeffrey Epstein owned or
controlled property or aircraft.
10. All documents demonstrating the relationship between Bill Clinton and Jeffrey Epstein
or Ghislaine Maxwell.
11. All photos of Ghislaine Maxwell at Chelsea Clinton's wedding.
12. All documents or information refuting statements made by Ghislaine Maxwell.
13. All documents and information relating to Prince Andrews travel, including travel to
New York City and the Caribbean, in 1999 to 2002.
14. All documents and information from Shopper's Travel evidencing travel, flight records
or passenger manifests during the relevant period.
15. All documents and information from David Rigg, Aviation Insurance Agent evidencing
travel, flight records or passenger manifests during the relevant period.
C. Exhibits:
1. Palm Beach Police Department report and documents contained within Jeffrey
Epstein's criminal files, attached hereto as Exhibit 1.
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.
19
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 21 of 26
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 Epstein's Palm
Beach home, attached hereto as Exhibit 7.
8. Jeffrey Epstein's Phone Book, also referred to as his "Black Book," 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 "The Government then concealed from Jane Doe No. 3
the existence of the NPA (pg. 3) and "The Government was well aware of Jane
Doe No. 3 when it was negotiating the NPA" (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 Roberts' passport, attached hereto as Exhibit 16.
17. Judge Thomas Lynch's January 12, 2016 Confidentiality Order regarding Virginia
Giuffre's deposition, attached hereto as Exhibit 17.
18. Documents produced and bates labelled Non-Party VR 000001 - Non-Party VR
000644, in the Bradley Edwards and Paul Cassell v. Alan Dershowitz matter,
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.
20
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 22 of 26
21. Victims Refuse Silence 2016 Annual Report, attached hereto as Exhibit 21.
22. January 3, 2015 Daily Mail article: "Harvard Law Professor Named Alongside
Prince Andrew in 'Sex Slave' Case Accuses Alleged Victim of 'Making Up
Stories,"' attached hereto as Exhibit 22.
23. January 3, 2015 Press Statement issued by Ross Gow to Express set forth in
"Ghislaine Maxwell: I was not a madam for paedophile," attached as Exhibit 23.
24. January 4, 2015 Statement by Ghislaine Maxwell to New York Daily News
Reporter "Alleged Madam Accused of Supplying Prince Andrew With Underage
Teen for Sex Spotted in NYC-As He's Seen Cutting Swiss Vacation Short to Face
Queen," attached hereto as Exhibit 24.
25. February 1, 2015 Mirror article: "Prince Andrew's Pal Ghislaine Maxwell May Sue
Over Madam Allegations," attached hereto as Exhibit 25.
26. September 23, 2007 Red Ice Creations Article "Prince Andrew's Friend, Ghislaine
Maxwell, Some Underage Girls, and A Very Disturbing Story," 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.
D. Computation of damages:
1. Physical, psychological and psychiatric injuries and resulting medical expenses - in
an amount of approximately $ 102,200 present value.
a. Computation Analysis:
1. Giuffre has had to receive treatment for the psychological harm as a
result of Maxwell's conduct towards Giuffre.
11. The average annual expenditures for mental health services for adults
18-64 in the United States is $1,751.
111. 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.
1v. 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.
21
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pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 23 of 26
b. Supporting Evidence:
1. Ms. Giuffre is in the process of collecting records from her physicians
11. Ms. Giuffre's testimony
111. 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
1. 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 (2 nd Cir. 2000) (Second Circuit holding that '[i]f a statement is
defamatory per se, injury is assumed. In such a case 'even where the
plaintiff can show no actual damages at all, a plaintiff who has
otherwise shown defamation may recover at least nominal damages'
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 "obvious lies".
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
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
1. Ms. Giuffre's testimony
22
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pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 24 of 26
11. Witness testimony
111. Awards in similar matters
1v. Ms. Giuffre is in the process of retaining an expert, and will provide
further information through expert disclosure.
3. Punitive Damages - to be based upon all relevant factors, including the egregious
nature of Defendant, Ghislaine Maxwell's 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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pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 25 of 26
Dated: June 24, 2016.
Respectfully Submitted,
BOIES, SCHILLER & FLEXNER LLP
By: Isl Sigrid Mccawley
Sigrid Mccawley (Pro Hae Vice)
Meredith Schultz (Pro Hae 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
Bradley J. Edwards (Pro Hae Vice)
FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
(954) 524-2820
Paul G. Cassell (Pro Hae Vice)
S.J. Quinney College of Law
University of Utah
383 University St.
Salt Lake City, UT 84112
(801) 585-5202 1
1 This daytime business address is provided for identification and correspondence purposes only and is not intended to
imply institutional endorsement by the University of Utah for this private representation.
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Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 26 of 26
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 24th day of June, 2016.
Laura A. Menninger, Esq.
Jeffrey S. Pagliuca, , Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Tel: (303) 831-7364
Fax: (303) 832-2628
Email: [email protected]
Email: [email protected]
By: Isl Sigrid Mccawley
Sigrid Mccawley
25
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
EXHIBITD
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 2 of 26
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
V.
Ghislaine Maxwell,
Defendant.
- - - - - - - - - - - - - -I
PLAINTIFF, VIRGINIA GIUFFRE'S FOURTH 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 Maxwell's 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.
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 3 of 26
3. Juan Alessi
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
4. Maria Alessi
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
5. Kathy Alexander
Address unknown at this time.
Telephone number unknown at this time.
Believed to be in South Africa.
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
6. Miles Alexander
Address unknown at this time.
Telephone number unknown at this time.
Believed to be in South Africa.
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
7. Doug Band
President of Teneo Holdings, 601 Lexington Avenue, 45 th 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 Maxwell's sexual trafficking
conduct and interactions with minors.
8. Gwendolyn Beck
2
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pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 4 of 26
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
9. Sophie Biddle
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
10.
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and Virginia
Guiffre and may have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
11. Fary Bjorlin
Address Unknown
Telephone Number Uknown
May have information relating to Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
12. Kelly Bovino
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
13. Jean Luc Brunel
c/o Joe Titone, Esq.
621 South East 5th Street, Pompano Beach, FL 33060
Tel: (954) 729-6490
3
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pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 5 of 26
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and Virginia
Guiffre and has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
14. Ron Burkle
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
15. -
Address unknown at this time.
Telephone number unknown at this time
Worked for Ghislaine Maxwell and has information about Ghislaine Maxwell's
recruiting of girls for Jeffrey Epstein.
16. Carolyn Casey
Address unknown at this time.
Telephone number unknown at this time.
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
17. 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 Epstein's sexual trafficking conduct.
18. William Jefferson Clinton
55 West 125 Street
New York, NY 10027
Travelled with Jeffrey Epstein and Ghislaine Maxwell and may have information
about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct.
4
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 6 of 26
19. Maximilia Cordero
Address unknown at this time
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct.
20. Valdson Cotrin
Address unknown at this time
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct.
21. Chauntae Davies
Telephone number unknown at this time
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and may have
information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and
interaction with underage minors.
22. Teala Davies
Telephone number unknown at this time
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and may have
information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and
interaction with underage minors.
23. Anouska DeGeorgieou
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
24. Alan Dershowitz
c/o Richard A. Simpson, Esq.
WILEY REIN, LLP
1776 K Street NW
Washington, D.C. 20006
5
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 7 of 26
Tel: (202) 719-7000
Has knowledge of Defendant's conduct that is the subject of this action.
25. Ryan Dionne
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
26. Eva Anderson Dubin
Telephone number unknown at this time
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and has
information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and
interaction with underage minors.
27. Glen Dubin
Telephone number unknown at this time
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and has
information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and
interaction with underage minors.
28.
Address unknown at this time.
Telephone number unknown at this time.
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
29. Prince Andrew Albert Christian Edward, Duke of York
Buckingham Palace Rd, London SWlA lAA
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors, including Virginia Giuffre.
6
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 8 of 26
30. Records Custodian for Travel for Prince Andrew Albert Christian Edward, Duke of
York
Buckingham Palace Rd, London SWlA lAA
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors, including Virginia Giuffre.
31. Jeffrey Epstein
c/o Marty Weinberg, Esq.
20 Park Plaza, Suite 1000, Boston, MA 02116
Has knowledge of Defendant's conduct that is the subject of this action and
knowledge of his sexual trafficking operation and other co-conspirators.
32. Tatiana Espinoza
Address unknown at this time
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
33. Annie Farmer
Address unknown at this time.
Telephone number unknown at this time.
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors, including Virginia Giuffre.
34. Marie Farmer
Address unknown at this time.
Telephone number unknown at this time.
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors, including Virginia Giuffre.
35. Vicky Ward
Address unknown at this time
Telephone unknown at this time
7
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 9 of 26
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors, including Virginia Giuffre.
36. Frederic Fekkai
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Defendant's conduct that is the subject of this action.
37. Tony Figueroa
Telephone number unknown at this time
Has knowledge of Defendant's conduct that is the subject of this action.
38. Luciano "Jojo" Fontanilla
Jeffrey Epstein's staff member in his various homes and may have knowledge of
Defendant and Jeffrey Epstein's inappropriate conduct with underage girls.
39. Lynn Fontanilla
Telephone number unknown at this time
May have knowledge of Defendant's conduct that is the subject of this action.
40. Michael Friedman
Telephone number unknown at this time
Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey
Epstein's sexual trafficking conduct and interaction with minors.
41. Rosalie Friedman
Telephone number unknown at this time
8
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 10 of 26
Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey
Epstein's sexual trafficking conduct and interaction with minors.
42. Ross Gow
Acuity Representation
23 Berkeley Square
London WU 6HE
Defendant's press agent who has knowledge of the defamatory statements in this
case.
43. Tiffany Kathryn Gramza
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors
44. -
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
45. Amanda Grant
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
46. Lesley Groff
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
47.
9
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pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 11 of 26
Has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and abuse and interaction with underage minors.
48. Claire Hazel
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
49. Shelly Harrison
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
50. Gina Ignatieva
Address Unknown
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
51. Brett Jaffe
Address noted on Defendant's Rule 26 disclosures
Defendant's attorney.
52.
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
10
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 12 of 26
53. Sarah Kensington Vickers formerly Sarah Kellen
c/o Bruce Reinhart, Esq.
McDonald Hopkins LLC
505 S Flagler Dr Ste 300
West Palm Beach, FL 33401-5942
Tel: 561- 472-2121
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interactions with minors.
54. Tatiana Kovylina
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
55.
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
56. 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 Epstein's sexual trafficking conduct and interaction with
underage minors.
57.
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
58. Michael Liffman
11
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pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 13 of 26
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
59. Peter Listerman
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
60. Cindy Lopez
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
61. Melinda Lutz
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
62. Cheri Lynch
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
63. Nadia Marcinko formerly Nadia Marcinkova
c/o Jack Goldberger, Esq.
Atterbury, Goldberger, & Weiss, P.A.
250 Australian Ave South, Ste 1400
West Palm Beach, FL 33401-5012
Tel: (561) 659-8300
12
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 14 of 26
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
64. Bob Meister
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
65. Todd Meister
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors
66. Brahakmana Mellawa
Address unknown at this time
Telephone number unknown at this time
House staff who may have know ledge of Ghislaine Maxwell and Jeffrey Epstein's
sexual trafficking conduct and interaction with underage minors.
67. Jayarukshi Mellawa
Address unknown at this time
Telephone number unknown at this time
House staff who may have know ledge of Ghislaine Maxwell and Jeffrey Epstein's
sexual trafficking conduct and interaction with underage minors.
68.
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
69. Andrea Mitrovich
Address Unknown
Telephone number unknown at this time.
13
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 15 of 26
Knowledge of Defendant's conduct that is the subject of this action.
70. Bill Peadon
Telephone number unknown at this time
House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's
sexual trafficking conduct and interaction with underage minors.
71. Francis Peadon
Telephone number unknown at this time
House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's
sexual trafficking conduct and interaction with underage minors.
72. Tom Pritzker
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
73. Dara Preece
Address Unknown
Telephone Unknown at this time
May have knowledge of Defendant's conduct in this action.
74. Louella Rabuyo
Address unknown at this time
Telephone unknown at this time
House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's
sexual trafficking conduct and interaction with underage minors.
75. Joseph Recarey
Telephone number unknown at this time.
14
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 16 of 26
Detective Recarey was the chief investigator of the crimes committed at Jeffrey
Epstein's Palm Beach mansion and has information about Ghislaine Maxwell and Jeffrey
Epstein's sexual trafficking conduct and interaction with underage minors.
76. Chief Michael Reiter
Telephone number unknown at this time.
Police Chief Reiter oversaw the investigation of the crimes committed at Jeffrey
Epstein's Palm Beach mansion and has information about Ghislaine Maxwell and Jeffrey
Epstein's sexual trafficking conduct and abuse of underage minors.
77. Bill Richardson
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
78. Rinaldo Rizzo
c/o Robert Lewis, Esq.
Freeman Lewis LLP
228 E. 45 th Street, 1ih Floor
New York, NY 10017
Tel: 212-980-4084
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
79. Haley Robson
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
80. Sky Roberts
15
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 17 of 26
Family member who may have knowledge of Ghislaine Maxwell and Jeffrey
Epstein's sexual trafficking conduct and interaction with underage minors.
81. David Rodgers
c/o Bruce E. Reinhart, Esq.
McDonald Hopkins LLC
505 S Flagler Dr Ste 300
West Palm Beach, FL 33401-5942
Tel: 561- 472-2121
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
82. Adriana Ross formerly Adriana Mucinska
c/o Alan S. Ross, Esq.
Tel: (305) 858-9550
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
83. 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
mmor.
84. Kelly Spamm
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
85. Cecilia Stein
Address unknown at this time
Telephone number unknown at this time
16
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 18 of 26
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
86. Emmy Taylor
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
87. Evelyn Valenzuela
Address unknown at this time
Telephone number unknown at this time
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
88. 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 Epstein's sexual trafficking
conduct and interaction with underage minors.
89. 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 Epstein's sexual trafficking
conduct and interaction with underage minors.
90. Courtney Wild
c/o Bradley Edwards, Esq.
FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Tel: (954) 524-2820
17
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 19 of 26
Has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
91. Doug Wilson
Family member who may have knowledge of Ghislaine Maxwell and Jeffrey
Epstein's sexual trafficking conduct and interaction with underage minors.
92. Igor Zinoview
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with underage minors.
93. All females identified in the police reports or identified through the United State's
Attorney's office during or through the criminal investigation of Jeffrey Epstein
and his co-conspirators.
94. 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.
95. All pilots, chauffeurs, chefs, and other employees of either Defendant Maxwell or
Jeffrey Epstein with knowledge of Defendant and Jeffrey Epstein's inappropriate
conduct with underage girls.
96. All staff and employees at the Mar-a-Lago Club during 1999-2002.
97. All other witnesses learned through discovery process.
B. Relevant Documents:
1. All files held by the Palm Beach Police Department or the Palm Beach State
Attorney's office which are publically available.
2. All press releases of Ghislaine Maxwell or on her behalf
18
CONFIDENTIAL as to victims' identity
pursuant to Court's June 23, 2016 Order
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 20 of 26
3. The video(s) of Ghislaine Maxwell adopting the January, 2015 press statement.
4. All newspaper or other media where Ghislaine Maxwell's press release appears
5. All evidence obtained by the Federal Bureau of Investigations which relate in any way
to Jeffrey Epstein or Ghislaine Maxwell.
6. All 302 statements that relate in any way to Jeffrey Epstein or Ghislaine Maxwell.
7. All evidence obtained by the FBI or United States Attorney's office by or through the
criminal investigation of Alfredo Rodriguez.
8. All documents relating to the previous subpoenas served on Defendant for her
deposition and all documents related in any way to that deposition.
9. All documents evidencing visitors or passengers at any of Jeffrey Epstein owned or
controlled property or aircraft.
10. All documents demonstrating the relationship between Bill Clinton and Jeffrey Epstein
or Ghislaine Maxwell.
11. All photos of Ghislaine Maxwell at Chelsea Clinton's wedding.
12. All documents or information refuting statements made by Ghislaine Maxwell.
13. All documents and information relating to Prince Andrews travel, including travel to
New York City and the Caribbean, in 1999 to 2002.
14. All documents and information from Shopper's Travel evidencing travel, flight records
or passenger manifests during the relevant period.
15. All documents and information from David Rigg, Aviation Insurance Agent evidencing
travel, flight records or passenger manifests during the relevant period.
C. Exhibits:
1. Palm Beach Police Department report and documents contained within Jeffrey
Epstein's criminal files, attached hereto as Exhibit 1.
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.
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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 Epstein's Palm
Beach home, attached hereto as Exhibit 7.
8. Jeffrey Epstein's Phone Book, also referred to as his "Black Book," 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 "The Government then concealed from Jane Doe No. 3
the existence of the NPA (pg. 3) and "The Government was well aware of Jane
Doe No. 3 when it was negotiating the NPA" (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 Roberts' passport, attached hereto as Exhibit 16.
17. Judge Thomas Lynch's January 12, 2016 Confidentiality Order regarding Virginia
Giuffre's deposition, attached hereto as Exhibit 17.
18. Documents produced and bates labelled Non-Party VR 000001 - Non-Party VR
000644, in the Bradley Edwards and Paul Cassell v. Alan Dershowitz matter,
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.
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21. Victims Refuse Silence 2016 Annual Report, attached hereto as Exhibit 21.
22. January 3, 2015 Daily Mail article: "Harvard Law Professor Named Alongside
Prince Andrew in 'Sex Slave' Case Accuses Alleged Victim of 'Making Up
Stories,"' attached hereto as Exhibit 22.
23. January 3, 2015 Press Statement issued by Ross Gow to Express set forth in
"Ghislaine Maxwell: I was not a madam for paedophile," attached as Exhibit 23.
24. January 4, 2015 Statement by Ghislaine Maxwell to New York Daily News
Reporter "Alleged Madam Accused of Supplying Prince Andrew With Underage
Teen for Sex Spotted in NYC-As He's Seen Cutting Swiss Vacation Short to Face
Queen," attached hereto as Exhibit 24.
25. February 1, 2015 Mirror article: "Prince Andrew's Pal Ghislaine Maxwell May Sue
Over Madam Allegations," attached hereto as Exhibit 25.
26. September 23, 2007 Red Ice Creations Article "Prince Andrew's Friend, Ghislaine
Maxwell, Some Underage Girls, and A Very Disturbing Story," 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.
D. Computation of damages:
1. Physical, psychological and psychiatric injuries and resulting medical expenses - in
an amount of approximately $ 102,200 present value.
a. Computation Analysis:
1. Giuffre has had to receive treatment for the psychological harm as a
result of Maxwell's conduct towards Giuffre.
11. The average annual expenditures for mental health services for adults
18-64 in the United States is $1,751.
111. 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.
1v. 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.
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b. Supporting Evidence:
1. Ms. Giuffre is in the process of collecting records from her physicians
11. Ms. Giuffre's testimony
111. 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
1. 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 (2 nd Cir. 2000) (Second Circuit holding that '[i]f a statement is
defamatory per se, injury is assumed. In such a case 'even where the
plaintiff can show no actual damages at all, a plaintiff who has
otherwise shown defamation may recover at least nominal damages'
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 "obvious lies".
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
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
1. Ms. Giuffre's testimony
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11. Witness testimony
111. Awards in similar matters
1v. Ms. Giuffre is in the process of retaining an expert, and will provide
further information through expert disclosure.
3. Punitive Damages - to be based upon all relevant factors, including the egregious
nature of Defendant, Ghislaine Maxwell's 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: June 24, 2016.
Respectfully Submitted,
BOIES, SCHILLER & FLEXNER LLP
By: Isl Sigrid Mccawley
Sigrid Mccawley (Pro Hae Vice)
Meredith Schultz (Pro Hae 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
Bradley J. Edwards (Pro Hae Vice)
FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
(954) 524-2820
Paul G. Cassell (Pro Hae Vice)
S.J. Quinney College of Law
University of Utah
383 University St.
Salt Lake City, UT 84112
(801) 585-5202 1
1 This daytime business address is provided for identification and correspondence purposes only and is not intended to
imply institutional endorsement by the University of Utah for this private representation.
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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 24th day of June, 2016.
Laura A. Menninger, Esq.
Jeffrey S. Pagliuca, , Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Tel: (303) 831-7364
Fax: (303) 832-2628
Email: [email protected]
Email: [email protected]
By: Isl Sigrid Mccawley
Sigrid Mccawley
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