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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)
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Case Document Filed Page of EXHIBIT Filed Under Seal Case Document Filed Page of United States District Court Southern District of New York Virginia Giuffre Plafatiff Case No Ghislaine Maxwell Defendant __ PLAINTIFF VIRGINIA GIUFFRES THIRD REVISED DISCLOSURE URSUANT 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 Bou levard Suite Miami Florida Tel Emai I smccawley bsfllp.com Plaintiff Information regarding Defendant Ghislaine Maxwells conduct that is the subject of this action Ghislai.ne Maxwell c/o Laura A Menninger Esq HADDON MORGAN FOREMAN East Avenue Denver Co orado Tel Emai 1men.ningcr hmflaw.com Defendant in his action ONFIDENTIA Case Document Filed Page of Juan Alessi Telephone number w1known at this time May have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors May have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors 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 sexual trafficking conduct and interaction with underage minors 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 sexual traf6cking 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 exual trafficking conduct and interactions 267with minors Gwendolyn Beck May have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Sophie Biddle CONFIDENTIAL Case Document Filed Page of IO May have information about Ghislaine Maxwell and Jeffrey Epstein sexual trafficking conduct and interaction with underage minors Was present on flights with Jef frey Epstein Ghi laine Maxwell and Virginia Guiffre and may have information about Ghislaine Maxwell and Jeffrey Epstein sexual trafficking conduct and interaction with underage minors Fary Bjorlin Address Unknovv11 Telephone Number Uknown May have infom1ation relating to Ghislaine Maxwell and Jeffrey Epstein sexual tlafficking conduct and interaction with underage minors May have information about Ghislaine Maxwell and Jeffrey Epstein sexual trafficking conduct and interaction with underage minors 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 Epstein 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 Epstein sexual trafficking conduct CONFIDENTIAL Case Document Filed Page of Worked for Ghislaine Maxwell and has information about Ghislaine Maxwell recruiting of girls for Jeffrey Epstein Caro yn Casey Address unknown at this time Telephone number unknown at this time fay have information about Ghislaine Maxwell and Jeffrey Epstein sexual trafficking conduct and interaction with underage minors I Alyson Chambers c/o Marshall Dore Louis Esq Sinclai Louis Zavertnik P.A N,W rd Street Suite Miami FL Tel Worked for Jeffrey Epstein as a masseuse dur i ng the time that Virginia Giuffre was living and traveling with Jeffrey Epstein and Ghislaine Maxwell and has information about Ghislaine Maxwell and Jeffrey Epstein sexual trafficking conduct William Jefferson lin ton West Street New York NY Travelled with Jeffrey Epstein and Ghislaine Maxwell and may have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct Maxim i lia Cordero Address unknown at this time Telephone number unknown at this time May have information about Ghislaine Ma well and Jeffrey Epsteins sexual trafficking conduct Valdson Cotrin Address unknown at this time Telephone number unknown at this time May have informatioh a out Ghislaine Maxwell and Jeffrey Epsteins sex al trafficking conduct Chauntae Davies Telephone number unknown at this time CO FIDENTTAL Case Document Filed Page of Was present on flights with Jeffrey Epstein Ghislaine Maxwell and may have information about Ghislaine Maxwell and Jeffrey Epstein sexual trafficking conduct and interaction with underage minors TeaJa Davies Telephone number unknown a this time Was present on flights with Jeffrey Epstein Ghislaine Maxwell and may have information about Ghis aine Maxwell and Jeffrey Epstein sexual trafficking conduct and interaction i th underage minors Anouska DeGeorgieou elephone number unknown a this time May have infonua1ion about Ghislrune Maxwell and Jeffrey Epstein sexual trafficking conduct and interaction with underage minors Alan Dershowitz i chard A Simpson Esq WILEY REIN LLP Street NW Washington Tel Has knowledge of Defendants conduct that is the subject of this action Ryan Dionne Address unkno rn at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstejn sexual trafficking conduct Eva Anderson Dubin Telephone number unknown at this time Was present on flights with Je frey Epstein Ghislaine Maxwell and has information about Ghis aine Maxwell and Jeffrey Epstein sexual trafficking onduct and interaction with underage minors Glen Dubin Ill Telephone number unknown at this time FIDE TIAL Case Document Filed Page of 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 May have informalion about Ghislaine Maxwell and Jeffrey Epstein sexual trafficking conduct and interaction with underage minors Prince Andrew Albert Christian Edward Duke of York Buckingham Palace Rd London SWlA IAA Tel Has knowledge of Ghislaine Maxwel1 and Jeffrey Epstein sexual trafficking conduct and int eraction with underage minors inclucling Virginia Giuffre Records Custodian for Travel for Prince Andrew Albeit Christian Edward Duke of York Buckingbam Palace Rd London SWlA 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 Marty Weinberg Esq Park Plaza Suite Boston MA Tel Has knowledge of Defendants conduct that is the subject of this action and knowledge of his se ual afficking 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 Annie Farmer Address unknown at this time Telephone number unknown at this time Has knowledge of Ghis1aine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors including Virginia Giuffre CONFIDENTIAL Case Document Filed Page of Made Farmer Address unknown at this time Telephone number unknown at this time TTas knowledge of Ghislaine Maxwell and Jeffrey Epstein sexual trafficking conduct and interaction with underage minors including Virginia Giuffre Vicky Ward Address unknown at this time Telephone unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein sexual trafficking conduct and interaction with underage minors including Virginia Giufile Frederic Fekkai Address unknown a this ti me Telephone number unknown at this time Has knowledge Defendant conduct that i the subject of this action Tony Figueroa Telephone number unknown at this time Has knowledge of Defendant conduct that is the subject of this action Luciano Jojo Fontanilla Jeffrey Epstein staff member in his various homes and may have knowledge Defendant and Jeffrey Epstein inappropriate conduct with underage girls Lynn ontanilla Telephone number unknm vn at this time May have knowledge of Defendants condu that is the subject of this action Michael Friedman Telephone number unknown a this time Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with minors Rosalie Friedman ONFlDENT I AL Jane Doe Jane Doe Case Document Filed Page of elephonc number unknown at this time Former house st a ff and may have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with minors Ross Gow Acuity Representation Berkeley Square London WlJ 6HE Defendants press agent who has knowledge of the defamatory statements in this ca Tiffany Kathryn Gramza Telephone numbe1 unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epstein sexual lmfficking conduct and interaction with underage minors May have knowledge of Ghislaine Maxwell and Jeffrey Epstein 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 Epstein sexual traffickjng conduct ONFIDENTIAL Case Document Filed Page of Has information about Ghislaine Maxwell and Je11i-ey Epsteins sexual trafficking conduct and abuse and interaction with underage minors Claire Haze Address unknown at this time Telephone number unknown at this time Has knowledge of Ghis aine Maxwell and Jeffrey Epstein sexual trafficking conduct and interac ion with underage minors Shelly Harrison Address unknown at this time Telephone nwnb unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey pstein sexual trafficking conduct and interaction with underage minors Gina Ignatieva Address Unknown Telephone number unknown at this time May have knowledge of Ghisla i ne Maxwell and Jeffrey Epstein sexual trafficking conduct and interac ion with underage minors Brett Jaffe Address noted on Defendant RuJe disclosure Defendants attorney Has knowledge of Ghisla i ne Maxwell and Jeffrey Epstein sexual trafficking conduct and interaction with underage minors Sarah Kensington Vickers formerly Sarah Kellen c/o Bruce Reinhart Esq McDonald Hopkins LLC Flagler Dr Ste West Palm Beach FL Tel CONFIDENTIAL Case Document Filed Page of Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual traffickjng conduct and interactions witJ1 minors Tatiana Kovylina Telephone number unknown at this ti.me May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Has knowledge of Ghislaine Maxwell and Jeffrey Eps teins sexual trafficking conduct and in teraction with underage minors Adam Perry La11g Address unknown at thi time Telephone number unknown at this time Traveling chef for Jeffrey Epstein and Ghislaine Max.well and may have knowledge of Ghislaine Maxwell and Jefli-cy Epsteins sexual trafficking conduct and interaction with underage minors May have knowledge of Ghislaine Maxwell and Jeffrey Epstein sexual trafficking conduct and interaction with underage minors Michael Liffman Address unknown at this time Telephone number unknown at this time May ha knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct Peter Listerrnan Address unknown at this time Te1ephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein se ual trafficking conduct and interaction with underage minors Cindy Lopez Address unknown at this time CONFTDENTlAL Case Document Filed Page of Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epste i ns sexual trafficking nduct and interact i on with underage minors Mel i nda Lutz Address unknown at th.is time TeJephone number unknovm at thjs time May have lrnowledge of Ghis aine Maxwell and Jeffrey Epstein sexual trafficking conduct and interaction with w1derage minors Cheri Lynch Address unknown at this time Te ephone number unknmvn at this time May have know edge of Ghislaine Maxweil and Jeffrey Epstein sexual trafficking conduct and interaction with underage minors adiaMarcinko formerly adiaMarcinkova Jack Goldberger Esq Atterbury Goldberger Weiss P.A Australian Ave South Ste West Palm Beach FL Tel Has knowledge of Ghislaine Maxwell and effrcy Epstein sexual trafficking conduct and interaction with underage minors Bob Meister May have information about Ghislaine Maxwell and Jeffrey Epstein sexua trafficking conduct and interaction with underage minors Todd Meister May have knowledge of Ghis aine Maxwe ll and Jeffrey Eps eins sexual trafficking conduct and interaction with widerage minors Brahakmana Mellawa Address unknown at this time Telephone number unlrnown at this time CONFIDENTIAL Case Document Filed Page of House staff who may have knowledge of Ghi aine Maxwell and Jeffrey Epste in sexua trafficking conduct and interaction with underage minors Jayarukshi Mellawa Address unknown at this time Telephone number unknown at th i time House staff who may have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Andrea Mitrovich Address Unknown Telephone number unknown at this time Knowledge of Defendant conduct that is the subject of this action Bill Peadon House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underag minors Francis Peadon Telephone number unknown at this time House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epstcin sexual trafficking conduct and interaction with underage minors Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Dara Preece Address Unknown Telephon Unknown at this time ONFIDE TIAL Case Document Filed Page of May have know edge of Defendants conduct jn this action Louella Rabuyo Address unknown at this time Telephone unknown at his time House staff that may have know edge of Ghislaine Maxwell and Jeffrey Epstein se Ual trafficking conduct and interaction with underage minors Joseph Recarey Detective Re arcy was the chief investigator of the crimes committed at Jeffrey Epsteins Palm Beach mansion and bas information about Ghisla i ne Ma-xwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Chief Michae Reiter Police Chief iter ersaw the investigation of the crimes comm i tted at ffrey Epsteins Palm Beach mansion and has information about Ghislaine Maxwell and Jeffrey Epstein se ual trafficking conduct and abuse of underage minors Bill Richardson Address unknown at this time Te ephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey psteins sexual trafficking conduct and interaction with underage minors Rinaldo Rizzo c/o Ro ert Lewis Esq reeman Lewis LLP th Street Floor New York NY Tel Has know edge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors II aJey Robson Address unknown at this time Telephone number unknown at this time ONFIDENTIAL Case Document Filed Page of Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with w1derage minors David Rodgers Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins se."ual trafficking conduct and interaction with underage minors Adr i ana Ross formerly Adriana Mucinska Has knowledge of Ghislaine Maxwell and Jeffrey Epstein sexual trafficking conduct and interaction with underage minors Johanna Sjoberg Worked for Jeffrey Epstein during the time when Virginia Giuffre was living and traveling with Jeffrey Epste i and Ghisla i ne Maxwell Johanna Sjo jerg was also present at an occasion with Prince Andrew Ghjsla i ne 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 Jetliey Epstein sexual trafficking conduct and interaction with underage minors Cecilia Stein Address unknown at this time Te ephone number unknown at this time May have l01ow cdge of Gh i slaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and internction with underage minors Emmy Taylor Address unknown at this time Telephone number unknown at this time CONFIDENTIAL Case Document Filed Page of Has knowledge of Ghislaine Maxwell and Jeffrey Epstein sexual trafficking conduct and in eraction with underage minors Evelyn Valenzuela Address unknown at this time Telephone number unknown at this time ay have knowledge of Ghislaine Maxwell and Jeffrey pstein sexual trafficking conduct Larry Visosky Has knowledge of Ghislaine Maxwell and Jeffrey Epstein sexual trafficking conduct and interaction with underage minors Leslie Vexner Has knowledge of Ghislaine Maxwell and Jeffrey Epstein sexual trafficking conduct and interaction with underage minors Courtney Wild Has information about Gh i slaine Maxwell and Jeffrey Epstein se ual 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 Epstein sexual trafficking conduct a nd interaction with underage minors All females identified in the police reports or identified through the United State Attorney office dming or through the criminal in estigation Jeffrey Epstein and his co-conspirators CONFIDE TIAL Case Document Filed Page of All other then-minor girls recn1ited by Ghisla in Maxwell whose identities Ms Giuffre will attempt to determine with whom Defendant Ghislaine Maxwell and Jeffrey pstein have engaged in sexual activity All pilots chauffew chefs and other employees of either Defendant Maxwell or Jeffrey Epstein with knowledge of Defendant and Jeffrey Epsteins inappropriate conduct with underage girls AU staff and employees at the Mar-a-Lago Club during All other witnesses learned through discovery process Relevant Documents All files held by the Palm Beach Police Department or the alm Beach State Attorneys office which are publicaJly available All press releases of Ghislaine Maxwell or on her behalf The video of Ghislaine Ma.--.:well adopting the January press statement All newspaper or othe media where Ghislaine Maxwe ll press release appears All evidence obtained by the Federal Bureau of Investigations which telate in any way to Jeffrey Epstein or Ghislaine Maxwell All statements that relate in any way to Jeffrey Epstein or Ghislaine Maxwell All evidence obtained by the FBI or United States Attorney office by or through the criminal investigation of Alfredo Rodriguez All documents relating to the previous subpoenas served on Defendant for her deposition and all documents rc1atecl in any way to that deposition All documents evidencing visitors or passengers at any of Jeffrey Epstein owned or controlled property or aircraft All documents demonstrating lhe relationship between Bill Clinton and Jeffrey Epstein or Ghislaine Maxwell All photos of Ghislaine Maxwell at Chelsea Clintons wedding All documents or information refuting statements made by Ghislaine Maxwell All documents and information relating to Prince Andrews travel including travel to New York City and the Caribbean in to CONFIDENT I AL Case Document Filed Page of Exhibits Palm Beach Police Department report and documents contained within Jeffre Epsteins criminal files attached hereto as Exhibit March Statement on behalf of Ghislaine Maxwell by Media agent Ross Gow attached hereto as Exhibit September Victim Notification Letter attached her eto as Exhibit May Complaint in Jane Doe No Jeffrey Epstein ClV-09 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 ash pull of Jeffrey Epsteins Palm Beach home attached hereto as Exhibit Jeffrey Epstein Phone Book also referred to as his Black Book attached hereto as Exhibit Deposition of Sarah Kellen attached her eto as Composite Exhibit Deposition Transcripts of uan Alessi attached hereto as Exhibit 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 AU paragraphs between The Government then concealed from Jane Doc No the existence of the NP A pg and he Government was well aware of Jane Doc No when it was negotiating the NPA pg were stricken by Judge Marra Januar Declaration of ane Doe No filed in the CVRA action pending in the Southern Di stric of Florida attached hereto as Exhibit Paragraphs and were stricken by Judge Marra February Declaration of Jane oe 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 A an Dershowitz matter pending in the Seventeenth Jud icial Circuit Broward County Florida attached hereto as Exhibit Virginia Roberts passport attached hereto as Exhibit CONFIDENTIAL Case Document Filed Page of Judge Thomas Lynchs January Confiden6ality Order regarding Virginia Giuffres deposition attached hereto as Exhibit Documents produced and bates labelled Non-Party VR Non-Patty VR in the Bradley Edwards and Paul Cassell Alan Dershowilz matter pending in the Seventeenth Judicial Circuit Broward County Florida attached hereto as Exhibit Victims Refuse Silence A1ticles of Incorporation and Amendment attached hereto as Composite Exhibit Victims Refuse Silence By-laws attached hereto as Exhibit Vjctims Refuse Silence Annual Report attached hereto as Exhibit January Daily Mail article Harvard Law Professor Named AJongside 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 Jee Creations Article Prince Andrews Friend Ghislaine Maxwell Some Underage Girls and A Very Disturbing Story attached hereto as Exhibit Photographs attached hereto as Exhibit Apri 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 present value a Computation Analysis Giuffre has had to receive treatment for the psychological harm as a result of Maxwells conduct towards Giuffre CONFIDENTIAL Case Document Filed Page of The average annual expenditures for mental health services for adults in the United States is Giuffre o.eeds continuing care as a result of the harm she has suffered Ms Giuffre was bom August and was years old at the beginning of when the alleged harm occurred The average remaining li fe expectancy for a year old female is years iv Based on a remaining life expectancy of years annual healthcare cost growth and a discount rate the present value of expected tTeatment costs is as of Supporting Evidence Ms Giuffre is in the process of collecting records from her p11ysicians ii Ms Giuffres testimony Ms Giuffre is in the process of retaining an expert to ca cu ate damages and will provide further information through expert disclosure Past present an future pain and suffering mental anguish humiliation cmban-assmcnt loss of self-esteem loss of standing in the community loss of dignity and invasion of privacy in her public and private Jjfe not less than a Computation Analysis Under New York law defamation per seas alleged in this case presumes damages and special damages do not need to be plead and proven See Celle Filipino Reporter Ente1prises Inc FJd nd Cir Second Circuit holding that if a statement is defamatory per sc i njuly is assumed ln such a case ev en ere 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 confim1ed an award of punitive damages Ms Giuffre has been severely damaged by the defamation of the defendant by calhng her aims of sexual abuse bvious lies The defamation caused Ms Giuffre to re-live the sexual abuse she previously endured Ms Giuffre has ffered and continues to suffer from the pain mental anguish humiliation emban 267assment loss of self-esteem los of standing in the community oss of dignity and invasion of privacy in her pub ic and private life The computation of this amount is in the province of the jury but Ms Giuffre contends CONFIDENTIAL Case Document Filed Page of including but not limited to awards in other similar matters that the amt is not less than Ms Giuffre is in the process of retaining an expert and will provide further information through expert disclosure Supporting Evidence Ms Giuffres testimony Witness testimony i Awards in similar matters 1v Ms Giuffre is in the process of retaining an expert and will provide further information through expe1i 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 Altematively 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 grov.,ih rate and a discount rate of the pre ent value of lost compensation is as of Supporting Evidence Materials reg a rding 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 CONFIDE TIAL Case Document Filed Page of Calc ul ation of Work hfe Expectancy Using the Life Partic ipation Employment Method Vocational Ec onometrics Inc Consumer Price Inde for Urban Wage Earners and Clerical Workers United States Department of Labor Bureau of Labor Statistics Federal Reserve Statistical Release Ms Giuffres testimony Ms Giuffre is in the process ofretaining a damages expert and will prov i de further information through expert disclosures Punitive Damages to be based upon all relevant factors including the egrngious nature of Defendant Ghislaine Ma Vvell conduct and the need for a large award to puni sh 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 CONFIDENAL Case Document Filed Page of Dated June Respectfully Submitted BOIES SCHILLER FLEXNBR LLP By I Sigrid McCawley Sigr i Mccawley Pro Hae Vice Meredith Schultz Pro Hae Vice Boies Schiller Flexner LLP Las Olas Blvd Suite Ft Lauderdale FL Dav i Boies Boies Schiller Flexner LLP Main Street Armonk NY Bradley Edwards Pro Hae Vice ARMER JAFFE WEISSING EDWARDS FISTOS LEH I Uv1AN P.L North Andrews A venue Sui Fort Lauderdale orida Pau Cassell Pro Ilac Vice S.J Quinney College of Law University of Utah University St Salt Lake City UT This daytime business address is provided for iden ificat i on and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this pr i vate representation CONFIDENTIAL 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 counsel of record identified below on this 1st day of June Laura A Menninger Esq Jeffrey Pag iuca Esq HADDON MORGAN FOREMAN P.C East th Avenue Denver Colorado Tel Fax Email lmennlngcr hmflaw.com Email jpag iuca hmflaw com By Sigrid McCawley Sigrid McCawlcy CONFIDENTIAL
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