EFTA02781079
Court Records
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EFTA02781079, U.S. Department of Justice, Epstein Files release (Court Records). Primary source: https://www.justice.gov/epstein/files/Court%20Records/v.%20Maxwell%2C%20No.%20115-cv-07433%20%28S.D.N.Y.%202015%29/EFTA02781079.pdf. Retrieved via Epstein Files Transparency Act Resources, https://tommycarstensen.com/epstein/data/documents/court/02781/EFTA02781079.html.
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Case 1:15-cv-07433-LAP Document 76-2 Filed 03/36-16 Page 1 of 21 EXHIBIT B EFTA02781079 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 2 of 21 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF, REVISED DISCLOSURE PURSUANT TO FED. R. CIV. P. 26 COMES NOW the Plaintiff, by and through her undersigned counsel, and serves this revised disclosure pursuant to Fed. R. Civ. P. 26 and states as follows: A. Witnesses: I. do Sigrid S. McCawley, Esq. Boles, Schiller & Flexner LLP 401 East Las Olas Boulevard, Suite 1200 Miami, Florida 33301 Tel: (954) 356-0011 Email: smccawley@bsfllp.com Plaintiff - information regarding Defendant, Ghislaine Maxwell's conduct that is the subject of this action 2. Ghislaine Maxwell do Laura A. Ise* nitir, Es . HADDON, & , P.C. 150 East 10' Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Email: ImennintterOhmflaw.com Defendant in this action. 1 EFTA02781080 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 3 of 21 3. Juan Alessi 6791 Fairway Lakes Drive, Boynton Beach, FL 33472 Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 4. Maria Alessi 6791 Fairway Lakes Drive, Boynton Beach, FL 33472 Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 5. Doug Band President of Teneo Holdings, 601 Lexington Avenue, 45th Floor, New York, NY 10022, Tel: (212) 886-1600 Was present on flights with Jeffrey Epstein and Ghislaine Maxwell and President Clinton and may have knowledge of Jeffrey Epstein and Ghislaine Maxwell's sexual trafficking conduct and interactions with minors. 6. P.O. Box 705, Arlington, VA 22216 (703) 656-6007 May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 7. 388 W. Carmel Valley Road, Cannel Valley, CA 93924 Tel: (310) 394-7048 May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 8. do Cris Armenta, Esq. 11900 Olympic Blvd., Suite 730, Los Angeles, CA 90064 Tel: (310) 826-2826 2 EFTA02781081 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 4 of 21 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. 9. 16694 Via La Costa, Pacific Palisades, CA 90272 Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 10. Jean Luc Brunel do Joe Titone, Esq. 621 South East 5th Street, Pompano Beach, FL 33060 Tel: (954) 729-6490 Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and Virginia Guiffre and has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 11. Ron Burkle Address unknown at this time Telephone number unknown at this time conduct. 12. Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking 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. 13. Alyson do 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 living and traveling with Jeffrey Epstein and Ghislaine Maxwell, and has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. was 3 EFTA02781082 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 5 of 21 14. Maximilia Address unknown at this time Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 15. Valdson Cotrin Address unknown at this time Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 16. 1017 N. Spaulding Avenue, #8, West Hollywood, CA 90056 Telephone number unknown at this time Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and may have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 17. 1212 N. Clark Street, Apt. #7, West Hollywood, CA 90069 Telephone number unknown at this time Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and may have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 18. Anouska DeGeorgieou 536 N. Edinburgh Avenue, Los Angeles, CA 90048 Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 19. Alan Dershowitz do Richard A. Simpson, Esq. WILEY REIN, LLP 1776 K Street NW Washington, D.C. 20006 Tel: (202) 719-7000 4 EFTA02781083 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 6 of 21 Has knowledge of Defendant's conduct that is the subject of this action. 20. Ryan Dionne Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 21. Eva 1090 N. Lake Way, Palm Beach, FL 33480 1040 56 Avenue, #15, New York, NY 10028 Telephone number unknown at this time Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 22. Glen 1090 N. Lake Way, Palm Beach, FL 33480 1040 5'h Avenue, #15, New York, NY 10028 Telephone number unknown at this time Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 23. Prince Andrew Albert Christian Edward, of York Buckingham Palace Rd, London SW IA IAA Tel: 020 7766 7300 Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors, including 24. Jeffrey Epstein do Tonja Haddad Coleman, Esq. 315 SE ath Street, Suite 301 Fort Lauderdale, FL 33301 Tel: (954) 467-1223 and do Marty Weinberg, Esq. 20 Park Plaza, Suite 1000, Boston,. 02116 Tel: (617) 227-3700 5 EFTA02781084 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 7 of 21 Has knowledge of Defendant's conduct that is the subject of this action and knowledge of his sexual trafficking operation and other co-conspirators. 25. Tatiana Espinoza Address unknown at this time Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 26. Frederic Fekkai Address unknown at this time Telephone number unknown at this time Has knowledge of Defendant's conduct that is the subject of this action. 27. Tony 104 Houston School Ct, Red Oak, TX 75154 Telephone number unknown at this time Has knowledge of Defendant's conduct that is the subject of this action. 28. Luciano "Jojo" Fontanilla 18 Teneyck Avenue, Valley Stream, NY 11580-4016 917-975-4500 Jeffrey Epstein's staff member in his various homes and may have knowledge of Defendant and Jeffrey Epstein's inappropriate conduct with underage girls. 29. Fontanilla 18 Teneyck Avenue, Valley Stream, NY 11580-4016 Telephone number unknown at this time May have knowledge of Defendant's conduct that is the subject of this action. 30. Michael 53320 Avenida Madero, La Quinta, CA 92253 Telephone number unknown at this time Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with minors. 6 EFTA02781085 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 8 of 21 31. 53320 Avenida Madero, La Quinta, CA 92253 Telephone number unknown at this time Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with minors. 32. 3927 Downey Ct, Simi Valley, CA 93063-2836 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. Eric Gany Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 34. Amanda Grant Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 35. Lesley Groff Address unknown at this time Telephone number unknown at this time conduct. 36. May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking 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 7 EFTA02781086 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 9 of 21 37. 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 38. Stephen 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 39. 50 S. Pointe Dr, Apt. 2304, Miami Beach, FL 33139 Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interactions with minors. 40. 1 Central Park South, #1306, New York, NY 10019-1732 Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors 41. 4712 Admiralty Way, # 383, Marina Del Rey, CA 90292 Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors 42. Adam 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. 8 EFTA02781087 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 10 of 21 43. 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 44. Michael Liffman 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. 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 46. 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 47. 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 48. 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. 9 EFTA02781088 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 11 of 21 49. 301 E. 66th Street, New York, NY 10065-6205 Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors 50. Todd Meister 101 Seminole Avenue, Palm Beach, FL 38480 Tel: (561) 650-0083 May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors 51. Brahakmana Address unknown at this time Telephone number unknown at this time House staff who may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 52. Jayarukshi Address unknown at this time Telephone number unknown at this time House staff who may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 53. Mitchell 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. 54. Bill Peadon 617 Piedmont Rd, West Palm Beach, FL 33405-1534 Telephone number unknown at this time House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 10 EFTA02781089 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 12 of 21 55. Francis Peadon 617 Piedmont Rd, West Palm Beach, FL 33405-1534 Telephone number unknown at this time House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 56. Tom Pritzker Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 57. 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. 58. Bill 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. 59. Rinaldo Rizzo 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. 60. 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. 11 EFTA02781090 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 13 of 21 61. David Rogers do Bruce E. Reinhart, Esq. Tel: (561) 202-6360 Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 62. do Alan S. Esq. Tel: (305) 858-9550 Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 63. do 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 was living and traveling with Jeffrey Epstein and Ghislaine Maxwell. Johanna Siolmersz was also present at an occasion with Prince Andrew, Ghislaine Maxwell, and was a minor. 64. 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. 65. 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. 66. Evelyn Valenzuela Address unknown at this time Telephone number unknown at this time 12 EFTA02781091 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 14 of 21 May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 67. Laity Visosky do 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. 68. Leslie Wexner do 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.. 69. 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. 70. All other then-minor girls, recruited by Ghislaine Maxwell, whose identities will attempt to determine, with whom Defendant, Ghislaine Maxwell and Jeffrey Epstein, have engaged in sexual activity. 71. All pilots, chauffeurs, chefs, and other employees of either Defendant Maxwell or Jeffrey Epstein with knowledge of Defendant and Jeffrey Epstein's inappropriate conduct with underage girls. 72. All staff and employees at the Mar-a-Lago Club during 1999-2002. 73. All other witnesses learned through discovery process. B. Exhibits• I. Palm Beach Police Department report and documents contained within Jeffrey Epstein's criminal files, attached hereto as Exhibit 1. 13 EFTA02781092 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 15 of 21 2. March 10, 2011 Statement on behalf of Ghislaine Maxwell by Media agent Gow, attached hereto as Exhibit 2. 3. September 3, 2008 Victim Notification Letter, attached hereto as Exhibit 3. 4. May I, 2009 Complaint in Jane Doe No. 102 v. Jeffrey Epstein, CIV-09-80656, in the Southern District of Florida, attached hereto as Exhibit 4. 5. FBI 302 Statement, attached hereto as Exhibit 5. 6. Flight Logs, attached hereto as Composite Exhibit 6. 7. Message Pads from Law Enforcement from trash pull of Jeffrey 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 attached hereto as Composite Exhibit 9. 10. Deposition Transcripts of Juan Alessi, attached hereto as Exhibit 10. II. 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 filed in the and Paul Cassell v. Alan Dershowitz matter, pending in the Seventeenth Judicial Circuit, Broward County, Florida, attached hereto as Exhibit 15. 16. passport, attached hereto as Exhibit 16. 17. Jude January 12, 2016 Confidentiality Order regarding deposition, attached hereto as Exhibit 17. 18. Documents produced and labelled Non-Party VR 000001 — Non-Party VR 000644, in the and Paul Cassell v. Alan Dershowitz matter, 14 EFTA02781093 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 16 of 21 pending in the Seventeenth Judicial Circuit, Broward County, Florida, attached hereto as Exhibit 18. 19. Victims Refuse Silence Articles of Incorporation and Amendment, attached hereto as Composite Exhibit 19. 20. Victims Refuse Silence By-laws, attached hereto as Exhibit 20. 21. Victims Refuse Silence 2016 Annual Report, attached hereto as Exhibit 21. 22. January 3, 2015 Daily Mail article: "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 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 \Inhit 28. C. Computation of tlainaues: attached hereto as 1. Physical, psychological and psychiatric injuries and resulting medical expenses — in an amount of approximately $ 102,200 present value. a. Computation Analysis: has had to receive treatment for the psychological harm as a result of Maxwell's conduct towards ii. The average annual expenditures for mental health services for adults 18-64 in the United States is $1,751. 15 EFTA02781094 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 17 of 21 iii. needs continuing care as a result of the harm she has suffered. was born August 9, 1983 and was 31.4 years old at the beginning of 2015 when the alleged harm occurred. The average remaining life expectancy for a 31 year old female is 51.1 years. iv. Based on a remaining life expectancy of 51.1 years, annual healthcare cost growth of 3.3% and a discount rate of 2.7%, the present value of expected treatment costs is $102,200 as of 1/1/2015. b. Supporting Evidence: is in the process of collecting records from her physicians ii. testimony is in the process of retaining an expert to calculate damages, and will provide further information through expert disclosure. 2. Past, present and future pain and suffering, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of standing in the community, loss of dignity and invasion of privacy in her public and private life not less than $30,000,000.00. a. Computation Analysis i. Under New York law, defamation per se as alleged in this case presumes damages and special damages do not need to be plead and proven. See Celle v. Filipino Reporter Enterprises Inc., 209 F.3d 163, 179 (2nd Cir. 2000) (Second Circuit holding that TV' 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). has been severely damaged by the defamation of the defendant, by calling her claims of sexual abuse "obvious lies". The defamation caused to re-live the sexual abuse she previously endured. 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 contends, including but not limited to, awards in other similar matters, that the 16 EFTA02781095 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 18 of 21 amount is not less than $30,000,000.00. is in the process of retaining an expert, and will provide further information through expert disclosure. b. Supporting Evidence testimony ii. Witness testimony iii. Awards in similar matters iv. is in the process of retaining an expert, and will provide further information through expert disclosure. 3. Estimated lost income of $180,000 annually. Present value of $3,461,000 to $5,407,000. a. Computation Analysis i. estimated compensation capacity is $180,000 annually. was born August 9, 1983 and was 31.4 years old at the beginning of 2015 when the alleged injury occurred. Her expected remaining work life based on mortality and probability of continued work was 20.2 years. Based on these factors, a 2% annual growth rate and a 2.4% discount rate, the present value of lost compensation is $3,461,000 as of 1/1/2015. ii. Alternatively, if is assumed to work until a normal retirement age of 65, or 33.6 years from her age at the beginning of 2015, and based on an annual growth rate of 2.0% and a discount rate of 2.7%, the present value of lost compensation is $5,407,000 as of 1/1/2015. b. Supporting Evidence i. Materials regarding compensation and work life expectancy 1) 2010 Life Table for Females, National Vita! Statistics Report, November 6, 2014, U.S. Department of Health & Human Services, Centers for Disease Control & Prevention, National Center for Health Statistics. 17 EFTA02781096 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 19 of 21 2) "Calculation of Work life Expectancy Using the Life, Participation, Employment Method," Vocational Econometrics, Inc. 3) Consumer Price Index for Urban Wage Earners and Clerical Workers, United States Department of Labor, Bureau of Labor Statistics. 4) Federal Reserve Statistical Release H.15, 1/5/2015. testimony is in the process of retaining a damages expert and will provide further information through expert disclosures. 4. niti% c Da niaues - 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. 18 EFTA02781097 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 20 of 21 Dated March 11, 2016 Respectfully Submitted, BOLES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Boles Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Ellen Brockman Boies Schiller & Flexner LLP 575 Lexington Ave New York, New York 10022 (212) 446-2300 19 EFTA02781098 Case 1:15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 21 of 21 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the above and foregoing Disclosure Pursuant to Fed. R. Civ. P. 26 has been provided by United States mail and electronic mail to all counsel of record identified below, on this 11th day of March, 2016. Laura A. Metutiolsq. HADDON, & 150 East 10 Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninzer(ahmflaw.com , P.C. By: /s/ Sigrid McCawley Sigrid McCawley 20 EFTA02781099