Case Document Filed Page of EXHIBIT Case Document Filed Page of United States District Court Southern District Of New York Virginia Giuffre Plaintiff Ghislaine Maxwell Defendant DEFENDANT GHISLAINE MAXWELLS INITIAL F.R.C.P a A DISCLOSURES Pursuant to F.R.C.P a A Defendant Ghislaine Maxwell makes the following disclosures I IDENTITIES OF INDIVIDUALS LIKELY TO HA VE DISCOVERABLE INFORMAT I ON RELE ANT TO DISP TED FACTS ALLEG ED WI TH PARTICULARITY IN THE PLEADINGS Ghislaine Maxwell c/o Laura A Menninger Esq Haddon Morgan Foreman P.C th Ave Denver CO LMenninger HMFLaw.com Ms Maxwell is the Defendant and a have kn wledge conc rning matters at issue including the events of and the publication of statements in the press in Virginia Lee Roberts Giuffre c/o Sigrid Mccawley Esq Boies Schiller Flexner LLP ast as Olas Boulevard Sui Case Document Filed Page of Mr Edwards has knowledge concerning Plaintiffs false statements to the press in court pleadings and in sworn testimony at issue in this matter Mr Edwards also has knowledge concerning Victims Refuse Silence Inc Jeffrey Epstein c/o Tonja Haddad Coleman Esq SE 7th Street Suite Fort Lauderdale FL Mr Epstein has knowledge concerning Plaintiffs false statements to the press and in court pleadings as well as the events of concerning Plaintiff and Defendant Anthony Figueroa Address unknown at this time Telephone number unknown at this time Mr Figueroa may have knowledge concerning matters at issue including Plaintiffs activities during Louis Freeh Address unknown at this time Mr Freeh may have knowledge concerning travel of Bill Clinton I Robert Giuffre Address unknown at this time Telephone number unknown at this time Mr Giuffre is may have knowledge concerning matters at issue including Plaintiffs activities during and her damages allegations Ross Gow Acuity Representation Berkeley Square London WIJ 6HE Mr Gow may have knowledge concerning matters at issue including the publication of statements in the press in concerning Plaintiff and Defendant Case Document Filed Page of Dated February Respectfully submitted Laura A Menninger Laura A Menninger HADDON MORGAN AND FOREMAN P.C East th Avenue Denver CO Phone Fax lmenninger hmflaw.com Attorney for Ghislaine Maxwell CERTIFICATE OF SERVICE I certify that on February I electronically served this DEFENDANT GHISLAINE MAXWELLS INITIAL F.R.C.P A DISCLOSURES via e-mail on the following Sigrid Mccawley BOIES SCHILLER FLEXNER LLP East Las Olas Boulevard Ste Ft Lauderdale FL smccawley bsfllp.com Laura A Menninger Laura A Menninger
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