EFTA02792927
Court Records
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EFTA02792927, 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/EFTA02792927.pdf. Retrieved via Epstein Files Transparency Act Resources, https://tommycarstensen.com/epstein/data/documents/court/02792/EFTA02792927.html.
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Case 1:15-cis-07433-LAP Document 1325-5 Filed 01/0424 Page 1 224 EXHIBIT 13 (Filed Under Seal) EFTA02792927 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 2 of 24 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF, THIRD 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: 1. c/o Sigrid S. McCawley, Esq. Boles, Schiller & Flexner LLP 401 East Las Olas Boulevard, Suite 1200 Miami, Florida 33301 Tel: (954) 356-0011 Email: smccawley@bsfilp.com Plaintiff- Information regarding Defendant, Ghislaine Maxwell's conduct that is the subject of this action. 2. Ghislaine Maxwell c/o Laura A. Met~nin er, Ea HADDON, & ~, P.C. 150 East 10' Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Email: Imenniruzer@hmflaw.com Defendant in this action. CONFIDENTIAL EFTA02792928 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 3 of 24 3. Juan Alessi Boynton Beach, PL 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 leicpnone numoer unknown at tnis 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 Tonto 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 ofJeffrey Epstein and Ghislaine Maxwell's sexual trafficking conduct and interactions with minors. 8. 9. May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 2 CONFIDENTIAL EFTA02792929 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 4 of 24 May have information about Ghislainc Maxwell and Jeffrey Epstein's sexual trtflicking conduct and interaction with underage minors. 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. Address Unknown Telephone Number Uknown May have information relating to Ghislaine Maxwell and Jeffrey Epstcin's sexual trafficking conduct and interaction with underage minors. 12. May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 13. 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, Ghislainc 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 15. Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 3 CONFIDENTIAL EFTA02792930 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 5 of 24 Worked for Ghislaine Maxwell and has information about Ghislaine Maxwell's recruiting of girls for Jeffrey Epstein. 16. 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 c/o Marshall Dore Louis, Esq. Sinclair, Louis & Zavennilc, 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 Ghislainc Maxwell, and has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 18. William Jefferson Clinton 55 West 125 Street Ncw York, NY 10027 was Travelled with Jeffrey Epstein and Ghislaine Maxwell and may have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 19. Maximilia Cordero Address unknown at this time Telephone number unknown at this time May have information about Ghislainc 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 Telephone number unknown at this time 4 CONFIDENTIAL EFTA02792931 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 6 of 24 Was present on flights with Jeffrey Epstein, Ghislainc Maxwell and may have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 22. 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 do Richard A. Simpson, Esq. WILEY REIN, LLP 1776 K Street NW Washington, D.C. 20006 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 Ghislainc Maxwell and Jeffrey Epstein's sexual trafficking conduct. 26. Eva Telephone number unknown at this time Was present on flights with Jeffrey Epstein, Ghislainc Maxwell and has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 27. Glen Telephone number unknown at this time CONFIDENTIAL EFTA02792932 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 7 of 24 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. May have information about Ghislaine Maxwell and Jeffrey Epstcin's sexual trafficking conduct and interaction with underage minors. 29. Prince Andrew Albert Christian Edward, of York Buckingham Palace Rd, London SWIA IAA Tel: 020 7766 7300 Has knowledge of Ghislaine Maxwell and Jeffrey Epstcin's sexual trafficking conduct and interaction with underage minors, including I 30. Records Custodian for Travel for 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 31. Jeffrey Epstein do Marty Weinberg, Esq. 20 Park Plaza, Suite 1000, Boston,. 02116 Tel: (617) 227-3700 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 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 6 CONFIDENTIAL EFTA02792933 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 8 of 24 34. 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 35. Vicky Address unknown at this time Telephone unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey F,pstein's sexual trafficking conduct and interaction with underage minors. including 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 Telephone number unknown at this time Has knowledge of Defendant's conduct that is the subject of this action. 38. Luciano "Jo o" Fontanilla Jeffrey F.pstein's staff member in his various homes and may have knowledge of Defendant and Jeffrey Epstein's inappropriate conduct with underage girls. 39. Fontanilla Telephone number unknown at this time May have knowledge of Defendant's conduct that is the subject of this action. 40. Michael 41. 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. 7 CONFIDENTIAL EFTA02792934 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 9 of 24 elephone 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. 42. Gow Acuity Representation 23 Berkeley Square London W I J 6HE Defendant's press agent who has knowledge of the defamatory statements in this case. 43 44. Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors 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 47. May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. CONFIDENTIAL EFTA02792935 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 10 of 24 Has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and abuse and interaction with underage minors. 48. Address unknown at this time Telephone number unknown at this time I las knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 49 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 Epstcin's sexual trafficking conduct and interaction with underage minors. 51. Brett Jaffe Address noted on Defendant's Rule 26 disclosures Defendant's attorney. 52. 53. Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. c/o Bruce Reinhart Esq. McDonald LLC 505 S Flagler Dr Ste 300 West Palm Beach, FL 33401-5942 Tel: 561- 472-2121 9 CONFIDENTIAL EFTA02792936 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 11 of 24 Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interactions with minors. 54. Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. has kiam ledge of Ciiiislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 56. 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 Jeflicy Epstein's sexual trafficking conduct and interaction with underage minors. 57. May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 58. Michael Li ffman 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 Listermun Address unknown at this time Telephone number unknown at this time 60. May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. Address unknown at this time 10 CONFIDENTIAL EFTA02792937 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 12 of 24 Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 6l. 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. 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. c/o Jack Goldberger, F.sq. Atterbury, Goldberger, & Weiss, Y.A. 250 Australian Ave South, Ste 1400 West Palm Beach, FL 33401-5012 Tel: (561) 659-8300 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 Address unknown at this time Telephone number unknown at this time II CONFIDENTIAL EFTA02792938 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 13 of 24 House staff who may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 67. 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. 68. 69. Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. Address Unknown Telephone number unknown at this time. Knowledge of Defendant's conduct that is the subject of this action. 70. 1311) Pcadon House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 71. Francis Pcadon 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. 73. Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. Address Unknown Telephone Unknown at this time 12 CONFIDENTIAL EFTA02792939 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 14 of 24 May have knowledge of Defendant's conduct in this action. 74. Address unknown at this time Telephone unknown at this time !louse staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 75. Recarey Detective Recarcy 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. 73. Chief Michael Reiter 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. 74. 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. 75. Rinaldo Rizzo do Robert Esq. Freeman LLP 228 E. 45 ' Street, 17th Floor Ncw York, NY 10017 Tel: 212-980-4084 Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 76. I Ialey Address unknown at this time Telephone number unknown at this time 13 CONFIDENTIAL EFTA02792940 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 15 of 24 Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 77. David Rodgers Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 78. 79. 80. Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. Worked for Jeffrey Epstein during the time when was living and traveling with Jeffrey Epstein and Ghislaine Maxwell. Johanna Sjoblfis also resent at an occasion with Prince Andrew, Ghislaine Maxwell, and was a minor. 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. 81 Cecilia Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstcin's sexual trafficking conduct and interaction with underage minors. 82. Emmy Taylor Address unknown at this time Telephone number unknown at this time 14 CONFIDENTIAL EFTA02792941 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 16 of 24 Has knowledge of Ghislainc Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 83. Evelyn Valenzuela Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislainc Maxwell and Jeffrey Epstein's sexual trafficking conduct. 84. Larry Visosk Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 85. Leslie Wexner Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 86. Has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 87. 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. 88. 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. 15 CONFIDENTIAL EFTA02792942 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 17 of 24 89. Alger then-minor girls, recruited by Ghislaine Maxwell, whose identities ■ will attempt to determine, with whom Defendant. Ghislainc Maxwell and Jeffrey Epstein, have engaged in sexual activity. 90. 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. 91. All staff and employees at the Mar-a-Lago Club during 1999-2002. 92. 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. 3. The video(s) of Ghislaine Maxwell adopting the January, 2015 press statement. 4. All newspaper or other media where Ghislainc 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. 16 CONFIDENTIAL EFTA02792943 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 18 of 24 C. Exhibits 1. Palm Beach Police Department report and documents contained within Jeffrey Epstein's criminal files, attached hereto as Exhibit I. 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 1, 2009 Complaint in Jane Doe No. 102 v. Jeffrey Epstein, CIV-09-80656, in the Southern District of Florida, attached hereto as Exhibit 4. 5. FBI 302 Statement, attached hereto as Exhibit 5. 6. Flight Logs, attached hereto as Composite Exhibit 6. 7. Message Pads from Law Enforcement from trash pull of Jeffrey 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 Doc 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 Dershowirz matter, pending in the Seventeenth Judicial Circuit, Broward County, Florida, attached hereto as Exhibit 15. 16. passport, attached hereto as Exhibit 16. 17 CONFIDENTIAL EFTA02792944 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 19 of 24 17. Jude deposition, attached hereto as Exhibit 17. January 12, 2016 Confidentiality Order regarding 18. Documents produced and labelled Non-Party VR 000001 — Non-Party VR 000644, in the 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. 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 Ghislainc 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 Ghislainc Maxwell May Sue Over Madam Allegations," attached hereto as Exhibit 25. 26. September 23, 2007 Red Ice Creations Article "Prince Andrew's Friend, Ghislainc 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 attached hereto as Exhibit 28. D. Computation of Damages: 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 =. 18 CONFIDENTIAL EFTA02792945 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 20 of 24 ii. The average annual expenditures for mental health services for adults 18-64 in the United States is $1,751. 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. l'he 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. h. Supporting Evidence: is in the process of collecting records from her physicians 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 (2id 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). 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, 19 CONFIDENTIAL EFTA02792946 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 21 of 24 including but not limited to, awards in other similar matters, that the 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 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 Vital Statistics Report, November 6, 2014, U.S. Department of Health & Human Services, Centers for Disease Control & Prevention, National Center for Health Statistics. 20 CONFIDENTIAL EFTA02792947 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 22 of 24 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. Punitive Damages - to be based upon all relevant factors, including the egregious nature of Defendant, Ghislainc 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. 21 CONFIDENTIAL EFTA02792948 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 23 of 24 I 1..k. I w:.• Respectfully Submitted, 13O1ES, SC1IILLER & FLEXNER LLP By: /s/ Skald McCawley Sigrid McCasS (Pro Hac Vice) Meredith (Pro Rae 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 IL.1. (Pro Hac Vice) JAFFE, WEISSING, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-5202 i ' 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. 22 CONFIDENTIAL EFTA02792949 Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 24 of 24 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 Ist day of June, 2016. Laura A. Menninger, Esq. Jeffrey S. Pa litisisq. HADDON, & , Y.C. 150 East 10` Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: ImenningcrEamflaw.com Email: joualiucaQhmtlaw.com By: Is/ Sigrid McCawlev Sigrid McCawlcy 23 CONFIDENTIAL EFTA02792950