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DOJ Epstein Release Interview Victim Statements Evidence Maxwell
← Back to Giuffre v. Maxwell, No. 1;15-cv-07433 (S.D.N.Y. 2015)
Extracted Text

EXH I BIT Case Document Filed Page of Case Document Filed Page United States District Court Southern District of New York Virginia Giuffre Plaintiff Case No Ghislaine Maxwell Defendant I PLAINTIFF VIRGINIA GIUFFRES DISCLOSURE PURSUANT TO FED CIV COMES NOW the Plaintiff Virginia Giuffre by and through her undersigned counsel and files this disclosure pursuant to Fed Civ and states as follows A Witnesses Virginia Giuffre c/o Sigrid Mccawley Esq Boies Schiller Flexner LLP East Las Olas Boulevard Suite Miami Florida Tel Email smccawley bsfllp.com Plaintiff information regarding Defendant Ghislaine Maxwells conduct that is the subject of this action Ghislaine Maxwell c/o Laura A Menninger Esq HADDON MORGAN FOREMAN P.C East th A venue Denver Colorado Tel Email lmenninger hmflaw.com Defendant in this action Case Document Filed Page Juan Alessi Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Maria Alessi Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Janusz Banasiak Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Doug Band Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Gwendolyn Beck Address unknown at this time Telephone number unknown at this time Knowledge concerning Defendants conduct that is the subject of this action Sophie Biddle Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Nadia Bjorlin Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Case Document Filed Page I Evelyn Boulet Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Kelly Bovino Address unknown at this time Telephone number unknown at this time Knowledge concerning Defendants conduct that is the subject of this action Jean Luc Brunel Address unknown at this time Telephone number unknown at this time Knowledge concerning Defendants conduct that is the subject of this action Dana Burns Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Karen Casey Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Valdson Cotrin Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Chauntae Davies Address unknown at this time Telephone number unknown at this time Knowledge concerning Defendants conduct that is the subject of this action Case Document Filed Page Teala Davies Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Anouska DeGeorgieou Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Alan Dershowitz c/o Richard A Simpson Esq WILEY REIN LLP Street NW Washington D.C Tel Knowledge of Defendants conduct that is the subject of this action Ryan Dionne Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Celina Dubin Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Eva Anderson Dubin Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Glen Dubin Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Case Document Filed Page Jordan Dubin Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Maya Dubin Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Prince Andrew Albert Christian Edward Duke of York Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Jeffrey Epstein c/o Tonja Haddad Coleman Esq SE ih Street Suite Fort Lauderdale FL Tel Knowledge of Defendants conduct that is the subject of this action Tatiana Espinoza Address unknown at this time Telephone numbe unknown at this time Knowledge of Defendants conduct that is the subject of this action Annie Farmer Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Alexandra Fekkai Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action i Case Document Filed Page I Frederic Fekkai Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Tony Figueroa Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Luciano Jojo Fontanilla Address unknown at this time Jeffrey Epsteins staff member in his various homes with knowledge of Defendant and Jeffrey Epsteins inappropriate conduct with underage girls Lynn Fontanilla Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Lynn Forester Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Michael Friedman Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Rosalie Friedman Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Case Document Filed Page Sheridan Gibson-Butte Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Fred Graff Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Tiffany Kathryn Gramza Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Claire Hazel Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Victoria Hazel Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Shelly Harrison Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Shannon Harrison Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Eugenia lgnatieva Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Case Document Filed Page Sarah Kensington Vickers formerly Sarah Kellen Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Tatiana Kovylina Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Banu Kucukkoylu Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Adam Perry Lang Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Shelly Ann Lewis Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Michael Liffmann Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Cindy Lopez Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Melinda Lutz Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Case Document Filed Page of Cheri Lynch Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Nadia Marcinko formerly Nadia Marcinkova Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Bob Meister Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Todd Meister Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Brahakmana Mellawa Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Jayarukshi Mellawa Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Marvin Minsky Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Case Document Filed Page of Andrea Mitrovich Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Vanessa Modely Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action David Mullen Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Svetlana Oriaznove Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Fabriame Pacheco Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Joe Pagano Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Mary Paluga Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Case Document Filed Page of Joel Pashcow Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Bill Peadon Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Francis Peadon Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Dara Lynn Preece Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Tom Pritzker Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Louella Rabuyo Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Rinaldo Rizzo Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Case Document Filed Page of Haley Robson Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action David Rogers Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Adriana Ross formerly Adriana Mucinska Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Forest Sawyer Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Doug Schoetlle Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Joanna Sjoberg Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Kelly Spamm Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Case Document Filed Page of Ellen Spencer Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Melissa Stahl Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Mark Tafoya Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Emmy Taylor Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Brent Tindall Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Ed Tuttle Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Emma Vaghan Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Case Document Filed Page of Cresenda Valdes Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Evelyn Valenzuela Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Maritza Vazquez Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Larry Visosky Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Alexia Wallaert Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Igor Zinoview Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action All other then-minor girls whose identities Plaintiff will attempt to determine with whom Defendant Ghislaine Maxwell and Jeffrey Epstein have engaged in sexual activity All pilots chauffeurs chefs and other employees of either Defendant Maxwell or Jeffrey Epstein with knowledge of Defendant and Jeffrey Epsteins inappropriate conduct with underage girls All staff and employees at the Mar-a-Lago Club during Case Document Filed Page of All other witnesses learned through discovery process Exhibits Palm Beach Police Department report and documents contained within Jeffrey Epsteins criminal files attached hereto as Exhibit A March I Statement on behalf of Ghislaine Maxwell by Media agent Ross Gow attached hereto as Exhibit January 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 January Press Statement issued by Ross Gow to Express set forth Ghislaine Maxwell I was not a madam for paedophile attached as Exhibit January 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 Hes Seen Cutting Swiss Vacation Short to Face Queen attached hereto as Exhibit February Mirror article Prince Andrews Pal Ghislaine Maxwell May Sue Over Madam Allegations attached hereto as Exhibit May Complaint in Jane Doe No Jeffrey Epstein in the Southern District of Florida attached hereto as Exhibit Flight Logs attached hereto as Exhibit Computation of damages Physical psychological and psychiatric injuries and resulting medical expenses precise amount yet to be computed but not less than 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 precise amount yet to be computed but not less than Past and future lost wages and past and future loss of earning capacity and actual earnings precise amounts yet to be computed but not less than Punitive Damages to be based upon all relevant factors including the egregious nature of Defendant Ghislaine Maxwells conduct and the need for a large award Case Document Filed Page of to punish and deter conduct in view of the vast wealth of Defendant Maxwell in an amount not less than WE HEREBY CERTIFY that a true and correct copy of the above and foregoing Disclosure Pursuant to Fed Civ has been provided by United States mail and electronic mail to all counsel of record identified below on this 11th day of November Laura A Menninger Esq HADDON MORGAN FOREMAN P.C East I th Avenue Denver Colorado Tel Fax Email lmenninger hmflaw.com Case Document Filed Page of Respectfully Submitted BOIES SCHILLER FLEXNER LLP By Isl Sigrid Mccawley Sigrid Mccawley Pro Hae Vice Boies Schiller Flexner LLP Las Olas Blvd Suite Ft Lauderdale FL David Boies Boies Schiller Flexner LLP Main Street Armonk NY Ellen Brockman Boies Schiller Flexner LLP Lexington Ave New York New York
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