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 PLAINTIFF VIRGINIA GIUFFRES REVISED DISCLOSURE PURSUANT TO FED CIV COMES NOW the Plaintiff Virginia Giuffre by and through her undersigned counsel and serves this revised 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 I 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 I th A venue Denver Colorado Tel Email lmenninger cv,hmtlaw.com Defendant in this action Case Document Filed Page Juan Alessi Fairway Lakes Drive Boynton Beach FL Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Maria Alessi Fairway Lakes Drive Boynton Beach FL Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Doug Band President ofTeneo Holdings Lexington Avenue th Floor New York NY Tel Was present on flights with Jeffrey Epstein and Ghislaine Maxwell and President Clinton and may have knowledge of Jeffrey Epstein and Ghislaine Maxwells sexual trafficking conduct and interactions with minors Gwendolyn Beck P.O Box Arlington VA May have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Sophie Biddle Carmel Valley Road Carmel Valley CA Tel May have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Nadia Bjorlin c/o Cris Armenta Esq Olympic Blvd Suite Los Angeles CA Tel Case Document Filed Page Was present on flights with Jeffrey Epstein Ghislaine Maxwell and Virginia Guiffre and may have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Kelly Bovino Via La Costa Pacific Palisades CA Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors I Jean Luc Brunel c/o Joe Titone Esq South East 5th Street Pompano Beach FL Tel Was present on flights with Jeffrey Epstein Ghislaine Maxwell and Virginia Guiffre and has information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Ron Burkle Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct Dana Burns Address unknown at this time Telephone number unknown at this time Worked for Ghislaine Maxwell and has information about Ghislaine Maxwells recruiting of girls for Jeffrey Epstein Alyson Chambers c/o Marshall Dore Louis Esq Sinclair Louis Zavertnik P.A N.W rd Street Suite Miami FL Tel Worked for Jeffrey Epstein as a masseuse during the time that Virginia Giuffre was living and traveling with Jeffrey Epstein and Ghislaine Maxwell and has information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct Case Document Filed Page Maximilia Cordero Address unknown at this time Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct Valdson Cotrin Address unknown at this time Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct Chauntae Davies Spaulding A venue West Hollywood CA Telephone number unknown at this time Was present on flights with Jeffrey Epstein Ghislaine Maxwell and may have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Teala Davies Clark Street Apt West Hollywood CA Telephone number unknown at this time Was present on flights with Jeffrey Epstein Ghislaine Maxwell and may have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Anouska DeGeorgieou Edinburgh Avenue Los Angeles CA Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Alan Dershowitz c/o Richard A Simpson Esq WILEY REIN LLP Street NW Washington D.C Tel Case Document Filed Page Has knowledge of Defendants conduct that is the subject of this action Ryan Dionne Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct Eva Anderson Dubin Lake Way Palm Beach FL th Avenue New York NY Telephone number unknown at this time Was present on flights with Jeffrey Epstein Ghislaine Maxwell and has information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Glen Dubin Lake Way Palm Beach FL th Avenue New York NY Telephone number unknown at this time Was present on flights with Jeffrey Epstein Ghislaine Maxwell and has information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Prince Andrew Albert Christian Edward Duke of York Buckingham Palace Rd London SWIA lAA Tel Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors including Virginia Giuffre Jeffrey Epstein c/o Tonja Haddad Coleman Esq SE th Street Suite Fort Lauderdale FL I Tel and c/o Marty Weinberg Esq Park Plaza Suite I Boston MA Tel Case Document Filed Page Has knowledge of Defendants conduct that is the subject of this action and knowledge of his sexual trafficking operation and other co-conspirators Tatiana Espinoza Address unknown at this time Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Frederic Fekkai Address unknown at this time Telephone number unknown at this time Has knowledge of Defendants conduct that is the subject of this action Tony Figueroa Houston School Ct Red Oak TX Telephone number unknown at this time Has knowledge of Defendants conduct that is the subject of this action Luciano Jojo Fontanilla Teneyck A venue Valley Stream NY Jeffrey Epsteins staff member in his various homes and may have knowledge of Defendant and Jeffrey Epsteins inappropriate conduct with underage girls Lynn Fontanilla Teneyck Avenue Valley Stream NY Telephone number unknown at this time May have knowledge of Defendants conduct that is the subject of this action Michael Friedman A venida Madero La Quinta CA Telephone number unknown at this time Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with minors Case Document Filed Page Rosalie Friedman A venida Madero La Quinta CA Telephone number unknown at this time Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with minors Tiffany Kathryn Gramza Downey Ct Simi Valley CA Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Eric Gany Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct Amanda Grant Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct Lesley Groff Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct Claire Hazel Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Case Document Filed Page Shelly Harrison Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Stephen Kaufinan Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Sarah Kensington Vickers formerly Sarah Kellen Pointe Dr Apt Miami Beach FL Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interactions with minors Tatiana Kovylina Central Park South New York NY I Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Banu Kucukkoylu Admiralty Way Marina Del Rey CA Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Adam Perry Lang Address unknown at this time Telephone number unknown at this time Traveling chef for Jeffrey Epstein and Ghislaine Maxwell and may have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Case Document Filed Page of Shelly Ann Lewis Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Michael Liffman Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct Peter Listerman Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Cindy Lopez Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Melinda Lutz Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Cheri Lynch Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Case Document Filed Page of Nadia Marcinko formerly Nadia Marcinkova I 66th Street New York NY I Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Todd Meister Seminole Avenue Palm Beach FL Tel May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Brahakmana Mellawa Address unknown at this time Telephone number unknown at this time House staff who may have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Jayarukshi Mellawa Address unknown at this time Telephone number unknown at this time House staff who may have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors George Mitchell Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Bill Peadon Piedmont Rd West Palm Beach FL Telephone number unknown at this time House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Case Document Filed Page of Francis Peadon Piedmont Rd West Palm Beach FL Telephone number unknown at this time House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Tom Pritzker Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Louella Rabuyo Address unknown at this time Telephone unknown at this time House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Bill Richardson Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Rinaldo Rizzo Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Haley Robson Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Case Document Filed Page of David Rogers c/o Bruce Reinhart Esq Tel Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Adriana Ross formerly Adriana Mucinska c/o Alan Ross Esq Tel Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Johanna Sjoberg c/o Marshall Dore Louis Esq N.W rd Street Suite Miami FL Tel Worked for Jeffrey Epstein during the time when Virginia Giuffre was living and traveling with Jeffrey Epstein and Ghislaine Maxwell Johanna Sjobjerg was also present at an occasion with Prince Andrew Ghislaine Maxwell and Virginia Giuffre when Ms Giuffre was a minor Kelly Spamm Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Emmy Taylor Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Evelyn Valenzuela Address unknown at this time Telephone number unknown at this time Case Document Filed Page of May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct Larry Visosky c/o Bruce Reinhart Esq Tel Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Leslie Wexner c/o John Zeiger Esq Zeiger Tigges Little LLP South High Street Suite Columbus Ohio Tel Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Igor Zinoview Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors All other then-minor girls recruited by Ghislaine Maxwell whose identities Ms Giuffre will attempt to determine with whom Defendant Ghislaine Maxwell and Jeffrey Epstein have engaged in sexual activity 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 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 I Case Document Filed Page of March I Statement on behalf of Ghislaine Maxwell by Media agent Ross Gow attached hereto as Exhibit September Victim Notification Letter attached hereto as Exhibit May Complaint in Jane Doe No Jeffrey Epstein in the Southern District of Florida attached hereto as Exhibit FBI Statement attached hereto as Exhibit Flight Logs attached hereto as Composite Exhibit Message Pads from Law Enforcement from trash pull of Jeffrey Epsteins Palm Beach home attached hereto as Exhibit Jeffrey Epsteins Phone Book also referred to as his Black Book attached hereto as Exhibit Deposition of Sarah Kellen attached hereto as Composite Exhibit Deposition Transcripts of Juan Alessi attached hereto as Exhibit I Deposition Transcripts of Alfredo Rodriguez attached hereto as Exhibit January Corrected Joinder Motion DE filed in the CVRA action pending in the Southern District of Florida attached hereto as Exhibit All paragraphs between The Government then concealed from Jane Doe No the existence of the NP A pg and The Government was well aware of Jane Doe No when it was negotiating the NP A pg were stricken by Judge Marra January Declaration of Jane Doe No filed in the CVRA action pending in the Southern District of Florida attached hereto as Exhibit Paragraphs and were stricken by Judge Marra February Declaration of Jane Doe No filed in the CVRA action pending in the Southern District of Florida attached hereto as Exhibit Paragraphs and were stricken by Judge Marra November Affidavit of Virginia Giuffre filed in the Bradley Edwards and Paul Cassell Alan Dershowitz matter pending in the Seventeenth Judicial Circuit Broward County Florida attached hereto as Exhibit Virginia Roberts passport attached hereto as Exhibit Judge Thomas Lynchs January Confidentiality Order regarding Virginia Giuffres deposition attached hereto as Exhibit Documents produced and bates labelled Non-Party VR Non-Party VR in the Bradley Edwards and Paul Cassell Alan Dershowitz matter Case Document Filed Page of pending in the Seventeenth Judicial Circuit Broward County Florida attached hereto as Exhibit Victims Refuse Silence Articles of Incorporation and Amendment attached hereto as Composite Exhibit Victims Refuse Silence By-laws attached hereto as Exhibit Victims Refuse Silence Annual Report 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 September Red Ice Creations Article Prince Andrews Friend Ghislaine Maxwell Some Underage Girls and A Very Disturbing Story attached hereto as Exhibit Photographs attached hereto as Exhibit April Deposition Transcript of Nadia Marcinkova attached hereto as Exhibit Computation of damages Physical psychological and psychiatric injuries and resulting medical expenses in an amount of approximately I present value a Computation Analysis Giuffre has had to receive treatment for the psychological harm as a result of Maxwells conduct towards Giuffre The average annual expenditures for mental health services for adults in the United States is l:i Case Document Filed Page of i Giuffre needs continuing care as a result of the harm she has suffered Ms Giuffre was born August and was years old at the beginning of when the alleged harm occurred The average remaining life expectancy for a year old female is years iv Based on a remaining life expectancy of years annual healthcare cost growth of and a discount rate of the present value of expected treatment costs is as of Supporting Evidence i Ms Giuffre is in the process of collecting records from her physicians ii Ms Giuffres testimony i Ms Giuffre is in the process ofretaining an expert to calculate damages and will provide further information through expert disclosure 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 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 Filipino Reporter Enterprises Inc F.3d nd Cir Second Circuit holding that if a statement is defamatory per se injury is assumed In such a case even where the plaintiff can show no actual damages at all a plaintiff who has otherwise shown defamation may recover at least nominal damages and the Second Circuit also confirmed an award of punitive damages Ms Giuffre has been severely damaged by the defamation of the defendant by calling her claims of sexual abuse obvious lies The defamation caused Ms Giuffre to re-live the sexual abuse she previously endured Ms Giuffre has suffered and continues to suffer from the pain mental anguish humiliation embarrassment loss of self-esteem loss of standing in the community loss of dignity and invasion of privacy in her public and private life The computation of this amount is in the province of the jury but Ms Giuffre contends including but not limited to awards in other similar matters that the Case Document Filed Page of amount is not less than Ms Giuffre is in the process of retaining an expert and will provide further information through expert disclosure Supporting Evidence i Ms Giuffres testimony Witness testimony i Awards in similar matters iv Ms Giuffre is in the process ofretaining an expert and will provide further information through expert disclosure Estimated lost income of annually Present value of to a Computation Analysis Ms Giuffres estimated compensation capacity is annually Ms Giuffre was born August and was years old at the beginning of when the alleged injury occurred Her expected remaining work life based on mortality and probability of continued work was years Based on these factors a annual growth rate and a discount rate the present value of lost compensation is as of Alternatively if Ms Giuffre is assumed to work until a normal retirement age of or years from her age at the beginning of and based on an annual growth rate of and a discount rate of the present value of lost compensation is as of Supporting Evidence Materials regarding compensation and work life expectancy Life Table for Females National Vital Statistics Report November U.S Department of Health Human Services Centers for Disease Control Prevention National Center for Health Statistics Case Document Filed Page of Calculation of Work life Expectancy Using the Life Participation Employment Method Vocational Econometrics Inc Consumer Price Index for Urban Wage Earners and Clerical Workers United States Department of Labor Bureau of Labor Statistics Federal Reserve Statistical Release ii Ms Giuffres testimony Ms Giuffre is in the process of retaining a damages expert and will provide further information through expert disclosures 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 to punish and deter conduct in view of the vast wealth of Defendant Maxwell in an amount not less than a This calculation is in the province of the jury Case Document Filed Page of Dated March 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 Case Document Filed Page of CERTIFICATE OF SERVICE 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 ofrecord identified below on this 11th day of March Laura A Menninger Esq HADDON MORGAN FOREMAN P.C East th Avenue Denver Colorado Tel Fax Email lmenninger hmflaw.com By Sigrid Mccawley Sigrid Mccawley
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