Case 1:15-cv-07433-LAP Document 1320-40 Filed 01/03/24 Page 1 of 19

EXHIBIT N
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United States District Court

Southern District Of New York

--------------------------------------------------X

..........................................
VIRGINIA L. GIUFFRE,

Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,

Defendant.

--------------------------------------------------X

DEFENDANT GHISLAINE MAXWELL’S

THIRD SUPPLEMENTAL F.R.C.P. 26(A)(1)(A) DISCLOSURES

Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following

disclosures:

I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE

INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS

1. Ghislaine Maxwell
c/o Laura A. Menninger, Esq.
Haddon, Morgan & Foreman, P.C.
150 E. 10th Ave.
Denver, CO 80203
303-831-7364
LMenninger@HMFLaw.com

Ms. Maxwell is the Defendant and may have knowledge concerning matters at
issue, including the events of 1999-2002 and the publication of statements in the
press in 2011-2015.

2. Virginia Lee Roberts Giuffre

c/o Sigrid S. McCawley, Esq.
Boies, Schiller & Flexner LLP
401 East Las Olas Boulevard, Suite 1200
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Miami, Florida 33301

(954) 356-0011
smccawley@bsfllp.com

Ms. Giuffre is the Plaintiff and has knowledge concerning the matters at issue in
her Complaint, including the events of 1996-2015 and the publication of
statements in the press in 2011-2015.

3. Kathy Alexander
Address unknown at this time
Telephone number unknown at this time

Ms. Alexander has knowledge about matters at issue, including Plaintiff’s

whereabouts during 2000-2002 and her false claims concerning Defendant and
others.

4. Miles Alexander
Address unknown at this time
Telephone number unknown at this time

Mr. Alexander has knowledge about matters at issue, including Plaintiff’s

whereabouts during 2000-2002 and her false claims concerning Defendant and
others.

5. James Michael Austrich

10108 NW 261 Terrace
High Springs, Florida, 32643

Mr. Austrich has knowledge concerning matters at issue in the Complaint,

including events of 1996-2002.

6. Philip Barden
Devonshires Solicitors LLP
30 Finsbury Circus
London, United Kingdom
EC2M 7DT
DX: 33856 Finsbury Square
(020) 7628-7576
Philip.Barden@devonshires.co.uk

Mr. Barden has knowledge concerning press statements by Plaintiff and

Defendant in 2011-2015 at issue in this matter.

7. Jane Doe 2

2
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Jane Doe 2

8. David Boies
Boies, Schiller, Flexner LLP
575 Lexington Ave.
New York, NY 10022
(212) 446-2300

Mr. Boies has knowledge concerning matters at issue in the Complaint and in
Plaintiff’s pleadings and sworn statements in other litigations, including in
particular her publicly filed allegations concerning Defendant and Alan
Dershowitz.

9. Laura Boothe
The Mar-a-Lago Club, LC.
1100 South Ocean Boulevard,
Palm Beach, FL 33480

Ms. Boothe has knowledge concerning matters at issue, including the date that
Sky Roberts began working at the Mar-a-Lago Club, and the human resources
department at Mar-A-Lago.

10. Evelyn Boulet

Address unknown at this time
Telephone number unknown at this time

Ms. Boulet may have knowledge concerning Plaintiff’s false claims against
Defendant.

11. Rebecca Boylan

Address unknown at this time
Telephone number unknown at this time

Ms. Boylan has knowledge concerning Plaintiff during the relevant time period
including claims for damages, motive and bias.

12. Joshua Bunner

Address unknown at this time

Joshua Bunner has knowledge concerning Plaintiff’s credibility, including false

claims of sexual assault.

13. Carolyn Casey

Address unknown at this time
Telephone number unknown at this time

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Ms. Casey may have knowledge concerning Plaintiff’s false claims against
Defendant.

14. Paul Cassell

383 South University Street
Salt Lake City, UT 84112
801-585-5202
paul.cassell@law.utah.edu

Mr. Cassell has knowledge concerning press statements by Plaintiff, Plaintiff’s

court pleadings, and Plaintiff’s sworn testimony.

15. Sharon Churcher

3 Deveau Road
N. Salem, NY 10560

Ms. Churcher has knowledge concerning matters at issue, including Plaintiff’s

statements regarding Defendant and others.

16. Alexandra Cousteau

Address unknown at this time
Telephone number unknown at this time

Ms. Cousteau may have knowledge concerning Plaintiff’s false claims against
Defendant and others.

17. Alan Dershowitz

c/o Richard A. Simpson, Esq.
WILEY REIN, LLP
1776 K Street NW
Washington, D.C. 20006
(202) 719-7000

Mr. Dershowitz has knowledge concerning Plaintiff’s false statements to the

press, in court pleadings, and in sworn testimony, at issue in this matter.

18. Dr. Mona Devanesan

PO Box 3250
601 E. Delmonte Avenue
Clerwiston, FL 33440
(561) 254-2502
modev358@aol.com

Dr. Devanesan has knowledge about matters at issue, including Plaintiff’s

whereabouts during 2001 and her claimed damages.

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19. Jane Doe 2

Address unknown at this time
Telephone number unknown at this time

Jane
Jane Doe
Doe 2 2

20. Bradley Edwards

Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.
425 N. Andrews Ave., Suite 2
Ft. Lauderdale, FL 33301
(954) 524-2820
brad@pathtojustice.com

Mr. Edwards has knowledge concerning Plaintiff’s false statements to the press,
in court pleadings, and in sworn testimony at issue in this matter. Mr. Edwards
also has knowledge concerning “Victim’s Refuse Silence, Inc.”

21. Amanda Ellison

Address unknown at this time
561-628-4338

Ms. Ellison has knowledge concerning Plaintiff’s false allegations concerning

Defendant.

22. Cimberly Espinosa

1113 West Columbine Ave.
Santa Ana, CA 92707

Ms. Espinosa has knowledge concerning Plaintiff’s false allegations concerning

Defendant.

23. Jeffrey Epstein

c/o Tonja Haddad Coleman, Esq.
315 SE 7th Street, Suite 301
Fort Lauderdale, FL 33301
(954) 467-1223

Mr. Epstein has knowledge concerning Plaintiff’s false statements to the press and
in court pleadings, as well as the events of 1999-2002 concerning Plaintiff and
Defendant.

24. Annie Farmer

Address unknown at this time
Telephone number unknown at this time

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Ms. Farmer may have knowledge concerning Plaintiff’s false claims against
Defendant.

25. Marie Farmer

Address unknown at this time
Telephone number unknown at this time

Ms. Farmer may have knowledge concerning Plaintiff’s false claims against
Defendant.

26. Alexandra Fekkai

Address unknown at this time
Telephone number unknown at this time

Ms. Fekkai may have knowledge concerning Plaintiff’s false claims against
Defendant and others.

27. Crystal Figueroa

Address unknown at this time

Ms. Figueroa may have knowledge concerning matters at issue, including

Plaintiff’s activities during 1996 – 2002

28. Anthony Figueroa

38 Bunker View Drive
Palm Coast, FL

Mr. Figueroa has knowledge concerning matters at issue, including Plaintiff’s

activities during 1996 – 2002.

29. Louis Freeh

Address unknown at this time
(202) 215-8321
Freeh@FreehGroup.com

Mr. Freeh may have knowledge concerning travel of Bill Clinton.

30. Eric Gany

Address unknown at this time
Telephone number unknown at this time

Mr. Gany may have knowledge concerning Plaintiff whereabouts during 2000-
2002 and her false claims against Defendant.

31. Meg Garvin

Lewis & Clark Law School

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10015 S.W. Terwilliger Boulevard MSC 51

Portland, Oregon 97219

Ms. Garvin has knowledge concerning matters at issue including Victims Refuse
Silence and Plaintiff’s damages.

32. Sheridan Gibson-Butte

Address unknown at this time
Telephone number unknown at this time
Ms. Gibson-Butte may have knowledge concerning Plaintiff’s false claims
against Defendant.

33. Robert Giuffre

Queensland, Australia

Mr. Giuffre is may have knowledge concerning matters at issue, including

Plaintiff’s activities during 2002-2016 and her damages allegations.

34. Ross Gow

Acuity Representation
23 Berkeley Square
London W1J 6HE
44 (0) 777 875 5251
ross@acuityreputation.com

Mr. Gow may have knowledge concerning matters at issue, including the
publication of statements in the press in 2011-2015 concerning Plaintiff and
Defendant.

35. Fred Graff

Address unknown at this time
Telephone number unknown at this time

Mr. Graff may have knowledge concerning Plaintiff’s false claims against
Defendant.

36. Philip Guderyon

Address unknown at this time
Telephone number unknown at this time

Mr. Guderyon may have knowledge concerning matters at issue, including

Plaintiff’s activities during 1996 – 2002.

37. Jane Doe 2

Jane Doe 2

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Jane Doe 2

-
Jane Doe 2
may have knowledge concerning matters at issue.

38. Shannon Harrison

Address unknown at this time
Telephone number unknown at this time

Ms. Harrison may have knowledge concerning Plaintiff’s false claims against
Defendant.

39. Victoria Hazel

Address unknown at this time
Telephone number unknown at this time

Ms. Hazel may have knowledge concerning Plaintiff’s false claims against
Defendant.

40. Brittany Henderson

Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.
425 N. Andrews Ave., Suite 2
Ft. Lauderdale, FL 33301

Ms. Henderson has knowledge concerning matters at issue including Victims

Refuse Silence and Plaintiff’s damages.

41. Brett Jaffe

Address unknown at this time
Telephone number unknown at this time

Mr. Jaffe has knowledge concerning Plaintiff’s false claims concerning Ms.
Maxwell including her compliance with any deposition subpoena in the CVRA
matter.

42. Carol Roberts Kess

Address unknown at this time
Telephone number unknown at this time

Ms. Kess may have knowledge concerning matters at issue, including Plaintiff’s
activities during 1996 – 2002.

43. Dr. Karen Kutikoff

12957 Palms W Drive #101

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Loxahatchee, FL 33470

Dr. Kutifkoff may have knowledge concerning matters at issue, including

Plaintiff’s whereabouts during 1998-2002 and Plaintiff’s damages.

44. Peter Listerman

Address unknown at this time
Telephone number unknown at this time

Mr. Listerman may have knowledge concerning Plaintiff’s false claims against
Defendant.

45. Tony Lyons

Skyhorse Publishing, Inc.
307 West 36th Street, 11th Floor
New York, NY 10018

Mr. Lyons may have knowledge concerning matters at issue, including Plaintiff’s
false allegations concerning Defendant and others.

46. Bob Meister

101 Seminole Avenue,
Palm Beach, FL 38480
(561) 650-0083

Mr. Meister may have knowledge concerning Plaintiff’s false claims against
Defendant.

47. Jamie A. Melanson

5280 NW 53rd Ave.
Coconut Creek, FL 33073

Mr. Melanson has knowledge concerning Plaintiff’s honesty and truthfulness.

48. Lynn Miller

936 O Street
Penrose, CO 81240

Ms. Miller may have knowledge concerning matters at issue, including Plaintiff’s
activities during 1996 – 2002.

49. Marvin Minsky

Address unknown at this time
Telephone number unknown at this time

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Mr. Minsky may have knowledge concerning Plaintiff’s false claims against
Defendant and others.

50. Jane Doe 2

Jane Doe 2

51. David Mullen

Address unknown at this time
Telephone number unknown at this time

Mr. Mullen may have knowledge concerning Plaintiff’s false claims against
Defendant.

52. Joe Pagano

Address unknown at this time
Telephone number unknown at this time

Mr. Pagano may have knowledge concerning Plaintiff’s false claims against
Defendant.

53. Mary Paluga

Address unknown at this time
Telephone number unknown at this time

Ms. Paluga may have knowledge concerning Plaintiff’s false claims against
Defendant.

54. J. Stanley Pottinger

49 Twin Lakes Rd.
South Salem, NY 10590
914-763-8333

Mr. Pottinger may have knowledge concerning matters at issue, including

Plaintiff’s attempts to sell her story to the media and her contacts with the media.

55. Joseph Recarey

2753 Misty Oaks Circle
Royal Palm Beach, FL 33441
Telephone number unknown at this time

Mr. Recarey may have knowledge concerning Plaintiff’s false claims against
Defendant.

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56. Michael Reiter

2335 So. Ocean Blvd., Apt. 15
Palm Beach, FL 33480
Telephone number unknown at this time

Mr. Reiter may have knowledge concerning Plaintiff’s false claims against
Defendant.

57. Jason Richards

Federal Bureau of Investigations
Address unknown at this time

Mr. Richards has knowledge concerning matters at issue, including Plaintiff’s

statements concerning Defendant, Alan Dershowitz and other individuals.

58. Bill Richardson

Address unknown at this time
Telephone number unknown at this time

Mr. Richardson may have knowledge concerning Plaintiff’s false claims against
Defendant and others.

59. Sky Roberts

15020 SE 47th Ave
Summerfield, FL 34491-5141

Mr. Roberts may have knowledge concerning matters at issue, including

Plaintiff’s activities during 1996 – 2002.

60. Scott Rothstein

U.S. Bureau of Prisons

Mr. Rothstein has knowledge concerning Plaintiff’s civil claims against Jeffrey
Epstein.

61. Forest Sawyer

Address unknown at this time
Telephone number unknown at this time

Mr. Sawyer may have knowledge concerning Plaintiff’s false claims against
Defendant.

62. Doug Schoetlle

Address unknown at this time
Telephone number unknown at this time

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Mr. Schoettle may have knowledge concerning Plaintiff’s false claims against
Defendant.

63. Cecilia Stein

Address unknown at this time
Telephone number unknown at this time

Ms. Stein may have knowledge concerning Plaintiff’s false claims against
Defendant.

64. Mark Tafoya

Address unknown at this time
Telephone number unknown at this time

Mr. Tafoya may have knowledge concerning Plaintiff’s false claims against
Defendant.

65. Brent Tindall

Address unknown at this time
Telephone number unknown at this time

66. Kevin Thompson

Address unknown at this time

Kevin Thompson has knowledge concerning Plaintiff’s credibility, including false

claims of sexual assault.

67. Ed Tuttle
Address unknown at this time
Telephone number unknown at this time

Mr. Tuttle may have knowledge concerning Plaintiff’s false claims against
Defendant.

68. Emma Vaghan

Address unknown at this time
Telephone number unknown at this time

Ms. Vaghan may have knowledge concerning Plaintiff’s false claims against
Defendant.

69. Kimberly Vaughan-Edwards

Address unknown at this time
Telephone number unknown at this time
Believed to be in the UK

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Ms. Vaughan-Edwards has knowledge concerning facts relevant to this dispute

and Ms. Maxwell’s character.

70. Cresenda Valdes

Address unknown at this time
Telephone number unknown at this time

Ms. Valdes may have knowledge concerning Plaintiff’s false claims against
Defendant.

71. Anthony Valladares

Address unknown at this time
Telephone number unknown at this time

Mr. Valladares may have knowledge concerning matters at issue, including

Plaintiff’s activities during 1996 – 2002.

72. Maritza Vazquez

Address unknown at this time
Telephone number unknown at this time

Ms. Vazquez may have knowledge concerning Plaintiff’s false claims against
Defendant.

73. Vicky Ward

Address unknown at this time
Telephone number unknown at this time

Ms. Ward may have knowledge concerning Plaintiff’s false claims against
Defendant.

74. Jarred Weisfeld

Address unknown at this time

Mr. Weisfeld may have knowledge concerning matters at issue, including

Plaintiff’s attempted publication of false allegations concerning Defendant and
others.

75. Courtney Wild

Pinellas County Jail

Ms. Wild may have knowledge concerning Plaintiff’s false claims against
Defendant.

76. Daniel Wilson

Address unknown at this time

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Telephone number unknown at this time

Mr. Wilson may have knowledge concerning matters at issue, including Plaintiff’s
activities during 1996 – 2002.

77. Andrew Albert Christian Edwards, Duke of York

Address unknown at this time
Telephone number unknown at this time

The Duke has knowledge concerning Plaintiff’s false statements to the press, in
court pleadings, and in sworn testimony as well as the events of 1999-2002.

78. Witnessed identified by Plaintiff in any of the various versions of her Rule 26
disclosures.

79. Witnesses whose identities and contact information can be identified in law
enforcement reports disclosed herein.

80. Any other witness learned through the discovery process.

Defendant Ghislaine Maxwell reserves her right to supplement these disclosures as

additional witnesses are learned through the discovery process, or endorsed by
Plaintiff.

II. DOCUMENTS, DATA, COMPILATIONS AND TANGIBLE THINGS IN

POSSESSION, CUSTODY OR CONTROL OF DEFENDANT THAT MAY
BE USED TO SUPPORT DEFENDANT’S CLAIM OR DEFENSES

1. Documents received from any other party through disclosures and/or in

discovery, including any deposition exhibits, will not be identified or
produced, though they technically may fall within this category “II”, and
Defendant reserves the right to utilize such documents at any hearing or trial
on this matter.

2. News articles from the internet:

a. “Sordid friends and why he isn't fit for the job: Duke of York risks
losing ambassador role,” Daily Mail Online (Feb. 28, 2011).

b. “Prince Andrew and the 17-year-old girl his sex offender friend flew
to Britain to meet him,” Daily Mail Online (corrected Mar. 2, 2011).

c. “Unsavoury association: How Robert Maxwell's daughter 'procured

young girls' for Prince Andrew's billionaire friend,” Daily Mail Online
(Mar. 5, 2011).

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d. “Virginia Roberts' account of the explosive Prince Andrew 'sex slave'

drama,” Daily Mail Online (Jan. 3, 2015).

e. “Court papers put daughter of Robert Maxwell at centre of ‘sex slave’

scandal,” The Guardian (Jan. 4, 2015).

f. “Prince Andrew denies sexual abuse allegations in unprecedented

Buckingham Palace statement: The Duke of York denies having
relations with alleged ‘sex slave,’” The Independent (Jan. 4, 2015).

g. “Prince Andrew story runs and runs - but editors should beware,” The
Guardian (Jan. 5, 2015).

h. “US lawyer sues in Prince Andrew sex claims case,” Time (Jan 6,
2015).

i. “Harvard professor Alan Dershowitz denies charges of sex with

underage girl,” Boston Globe (Jan. 22, 2015).

j. “Virginia Roberts’s Aunt Reveals Jeffrey Epstein Girl Says I Am In

Fear for My Life,” Daily Mail Online, (Jan. 10, 2015).

k. “EXCLUSIVE: Alleged ‘sex slave’ of Jeffrey Epstein, Prince Andrew

accused two men of rape in 1998, but was found not credible,” NY
Daily News (Feb. 23, 2015).

l. “Jeffrey Epstein accuser was not a sex slave, but a money-hungry sex
kitten, her former friends say,” NY Daily News (Mar. 1, 2015).

m. “Twat Claims She Was Underage Sex Slave Bedding Prince Andrew,”
http://www.mgtowhq.com/viewtopic.php?f=2&t=6676 (Jan. 5, 2015).

n. “Exclusive: Prince Andrew at Heidi Klum’s ‘Hookers and Pimps’

party with the New York socialite accused of procuring underage girls
for his billionaire pedophile friend” Daily Mail Online (May 10,
2016).

3. Email from Ross Gow to various news organizations, Subject: “Ghislaine

Maxwell,” (Jan. 2, 2015).

4. “Lawyers Acknowledge Mistake In Filing Sexual Misconduct Charges

Against Professor Dershowitz,” Joint Statement of Brad Edwards, Paul
Cassell and Alan Dershowitz (Apr. 8, 2016).

5. Edwards and Cassell v. Dershowitz, In the Circuit Court of the Seventeenth

Judicial District In and For Broward County Florida to include:

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a. Deposition testimony of Paul G. Cassell, dated October 16, 2015 and

October 17, 2015.

6. Jane Doe #1 and #2 v. United States, U.S. District Court for the Southern
District of Florida, 08-cv-80736-KAM pleadings to include:

a. Motion for Limited Appearance, Consent to Designation and Request

to Electronically Receive Notices of Electronic Filing (July 28, 2008)
(Doc. # 16)

b. Notice of Change of Address and Firm Affiliation (Apr. 9, 2009) (Doc.

# 37)

c. Order Denying Petitioners’ Motion to Join Under Rule 21 and Motion

to Amend Under Rule 15 (Apr. 7, 2015) (Doc. #324)

d. Order Scheduling Settlement Conference Before the Magistrate Judge,

U.S. District Court (Mar. 31, 2016) (Doc. #378)

7. Epstein v. Scott Rothstein and Bradley J. Edwards, In the Circuit Court of the
Fifteenth Judicial Circuit in and for Palm Beach County, Florida, 09-ca-
040800, pleadings to include:

a. Complaint (Dec. 7, 2009).

8. Law enforcement records obtained from the Palm Beach County (Florida)
Sheriff’s Office, the Royal Palm Beach (Florida) Police Department, the
County Court in and for Palm Beach County (Florida), the Greenacres
(Florida) Department of Public Safety, and the Fremont County (Colorado)
Sheriff’s Office.

9. Employment records obtained from ET Employment Training and Recruiting

Australia.

10. Education records obtained from Royal Palm Beach Community High School
and Forest Hills High School.

11. Documents received from Palm Beach County Library System.

12. Documents received from any other party through disclosures and/or in
discovery, including any deposition exhibits, will not be identified or
produced, though they technically may fall within this category “II”, and
Defendant reserves the right to utilize such documents at any hearing or trial
on this matter.

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Defendant reserves the right to identify additional documents, data, compilations

and tangible things as discovery continues and to supplement this list accordingly.

III. DESCRIPTION OF CATEGORIES OF DAMAGES SOUGHT AND

COMPUTATION OF ECONOMIC DAMAGES CLAIMED BY THE
DISCLOSING PARTY

Not applicable at this time Ms. Maxwell reserves her right to supplement these
disclosures as necessary.

IV. INSURANCE AGREEMENT UNDER WHICH ANY PERSON CARRYING

ON AN INSURANCE BUSINESS MAY BE LIABLE TO SATISFY A PART
OR ALL OF A JUDGMENT

Ms. Maxwell’s AIG Homeowners and Excess Liability insurance policies.

Coverage has been denied by AIG, as their letter of April 18, 2016 to Ms.
Maxwell, copied to Ms. McCawley, attests.

Dated: June 17, 2016.

Respectfully submitted,

s/ Laura A. Menninger
Laura A. Menninger
Jeffrey S. Pagliuca
HADDON, MORGAN AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
lmenninger@hmflaw.com
jpagliuca@hmflaw.com

Attorneys for Ghislaine Maxwell

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CERTIFICATE OF SERVICE

I certify that on June 17, 2016, I electronically served this DEFENDANT GHISLAINE
MAXWELL’S THIRD SUPPLEMENTAL F.R.C.P. 26(A)(1) DISCLOSURES via e-mail on the
following:

Sigrid S. McCawley Paul G. Cassell

Meredith Schultz 383 S. University Street
BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112
401 East Las Olas Boulevard, Ste. 1200 cassellp@law.utah.edu
Ft. Lauderdale, FL 33301
smccawley@bsfllp.com
mschultz@bsfllp.com
J. Stanley Pottinger
Bradley J. Edwards 49 Twin Lakes Rd.
FARMER, JAFFE, WEISSING, EDWARDS, South Salem, NY 10590
FISTOS & LEHRMAN, P.L. StanPottinger@aol.com
425 North Andrews Ave., Ste. 2
Ft. Lauderdale, FL 33301
brad@pathtojustice.com
s/

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