Case Document Filed Page of EXHIBITD Case Document Filed Page of United States District Court Southern Di strict of New York Virginia Giuffre Plaintiff Case No Ghislaine Maxwell Defendant I PLAINTIFF VIRGINIA GIUFFRES OURTH 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 a-s follows A Witnesses Virginia Giuffre c/o Sigrid Mc cawley Esq Boies Schill er Flexner LLP East Las Olas Boulevard Suite Miami Florida Tel Email smccawley bsfllp com Plaintiff information regarding Defendant Ghislaine Max we lls conduct that is the subject of this action Ghis la ine Maxwell c/o Laura A Menninger Esq HADDON MORGAN OREMAN East th A venue Denver Colorado Tel Email lmenninger hmflaw com Defendant in this action CONFIDENT IAL as to victims identity pursuant to Courts Jun Order Case Document Filed Page of Juan Alessi Telephone number unknown at this time May have information about Ghis1aine Maxwell and Jeffrey Epsteins sex ua1 trafficking conduct and interaction with underage minors Maria Alessi Te1ephone number unknown at this time 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 Eps tein sex ual trafficking conduct and interaction ith 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 Epsteins sexua1 trafficking conduct and interaction with underage minors Doug Band President of Teneo Holdings Lexington A venue th Floor New York NY Tel Was present on flights with Jeffrey Epstein and Ghislaine Maxwell and President linton and may have knowledge of Jeffrey Epstein and Ghislaine Maxwells sexua trafficking conduct and interactions with minors Gwendolyn Beck CONFIDENTIAL as to victims identity pursuant to Courts June Order Case Document Filed Page of 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 interactio with underage minors Was present on flight with Jeffrey Epstein Ghislaine axwe ll and Virginia Guiffre and may have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and i nteraction with underage minors Fary Bjorlin Address Unknown Teephone Number Uknown May have information relating to Ghislaine Maxwell and Jeffrey Epsteins sexua trafficking conduct and interaction with underage minors Kelly Bovino Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Jean Luc Brune c/o Joe Titone Esq South East 5th Street Pompano Beach FL Tel CONFIDENTIAL as to victims identity pursuant to Courts June Order Case Document Filed Page of Was present on flights with Jeffrey Epstein Ghislaine Maxwell and Virginia Guiffre and has information about Ghislaine Maxwe ll and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Ron Burkle Address unknown at this time Te ephone number unknown at th i time Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct Address unknown at this time Telephone number unknown at this time Worked for Ghislaine Maxwell and has information about Ghis aine Maxwells recruiting of girls for Jeffrey Epstein Carolyn Casey 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 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 William Jefferson Clinton West Street New York NY Travelled with Jeffrey Epstein and Ghislaine Maxwell and may have information about Ghislaine Maxwell and Jeffrey Epsteins sexua trafficking conduct CONFIDENTIAL as to victims identity pursuant to Courts June Order Case Document Filed Page of Max:imilia Cordero Address unknown at this time Te ephone number unknown at hi time May have information about Ghislaine Maxwell an Jeffrey Epsteins sexual trafficking conduct Valdson Cotrin Ad dr ess unknown at this time Telephone number unknown at is time May bave info mation about Ghislaine Maxwe ll and Jeffrey Epsteins sex al trafficking conduct Chauntae Davies Telephone number unknown at th i time Was prese on flig ts with Jeffrey Epstein Gh i aine axwell and may have information about Ghislaine Maxwell and Jeffrey Epsteins sexua trafficking conduct an interaction with underage minors Teala Davies Telephone number unknown at this ti Was present on flights with Jeffrey Epstein Ghis aine Maxwell a may have information about Ghis aine Maxwell and Jeffrey Epstein sexua trafficking conduct and interaction wit underage minors Anouska DeGeorgieou Te ephone number unknown at th i time May ave information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage mi ors Alan Dersbowitz c/o Richard A Simpson Esq WILEY REIN LLP Street NW Washington CONFIDENTIAL as to victims identity pursuant to Courts June Order Case Document Filed Page of Tel Has knowledge of Defendants conduct that i the subject of this action Ryan Dionne Address unknown at th.is time Te ephone number unknown at th i time May have knowledge of Ghislaine Maxwe ll and Jeffrey Epsteins sexual trafficking conduct Eva Anderson Dubin Telephone number unknown at this time Was present on flights with Jeffrey Epstein Ghislaine Maxwe11 and has information about Ghislaine Maxwell and Jeffrey Epsteins sexua trafficking conduct and interaction with underage minors Glen Dubin Telephone number unknown at this time Was present on flights with Jeffrey Epstein Ghis aine Maxwe ll and has information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors 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 Prince Andrew Albert Christian Edward Duke York Buckingham Palace Rd London SWlA lAA Has knowledge of Ghislaine Maxwe and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors including Virginia Giuffre CONFIDENTIAL as to victims identity pursuant to Courts June Order Case Document Filed Page of Records Custodian for Travel for Prince Andrew Albert Christian Edward Duke of York Buckingham Palace Rd London SWIA lAA Has knowledge of Ghislaine Maxwell and Jeffrey Eps eins sexua trafficking conduct and interaction with underage minors including Virginia Giuffre Jeffrey Epstein c/o Marty Weinberg Esq Park Plaza Suite Boston MA Has knowledge of Defendants conduct that is the subject ohhis action and know edge 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 Annie Farmer Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexua trafficking conduct and interaction with underage minors including Virginia Giuffre Marie Farmer 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 including Virginia Giuffre Vicky Ward Address unknown at this time Telephone unknown at this time CONFIDENTIAL as to victims identity pursuant to Courts June Order Case Document Filed Page of Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors including Virginia Giuffre Frederic Fekkai Address unknown at th.is time Telephone number unknown at this time Has knowledge of Defendant conduct that is the subject of this action TonyFigueroa Telephone number unknown at this time Has knowledge of Defendants conduct that is the subject ohb.is action Luciano Jojo Fontanilla Jeffrey Epsteins staff member in his various homes and may have knowledge of Defendant and Jeffrey Epsteins inappropriate conduct with underage girls Telephone number unknown at this time May have knowledge of Defendants conduct that is tbe subject of this action Michael Friedman Telephone number unknown at this time Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey Epstein sexual trafficking conduct and interaction with minors Rosalie Friedman Telephone number unknown at this time ONFIDENTIAL as to vic ti ms i dentity pursuant to Courts June Order Case Document Filed Page of Fonner house staff and may have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with minors case Ross Gow Acuity Representation Berk ley Square London 6HE Defendant press agent who bas knowledge of the defamatory statements in this Tiffany Kathryn Gramza Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epsteins sex ual trafficking conduct and interaction with underage minors Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Eps tein sexual trafficking conduct Amanda Grant Address unknown at this time Telephone number unknown at this time May bave know ledge of Ghislaine MaxweJl and Jeffrey Eps teins sexual trafficking conduct Lesley Groff Address unknown at this time Telephone number unknown at thi time May have knowledge of Ghislaine Maxwell and Jeffrey Epstei ns sexual trafficking conduct CONFIDENTIAL as to victims identity pursuantto Courts June Order Case Document Filed Page of Has information about Ghis aine Maxwell and Jeffrey Epstein 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 Ghis1aine Maxwell and Jeffrey Epsteins sexua trafficking conduct and interaction with underage minors 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 Gina lgnat ie va Address Unknown Telephone number unknown at this time Maybave knowledge ofGbislaine Maxwell and Jeffrey Eps eins sexua1 trafficking conduct and interaction with underage minors Brett Jaffe Address noted on Defendants Rule disc osures Defendant attorney Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Eps tein sexua trafficking conduct and interaction with underage minors CONFIDENTIAL as to victims identity pursuant to Courts June Order Case Document Filed Page of Sarab Kensington Vickers formerly Sarah Ke11en c/o Bruce Reinhart Esq McDonald Hopkins LLC Flagler Dr Ste West Palm Beach FL Tel Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexua trafficking conduct and interactions with minors Tatiana Kovylina Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexua trafficking conduct and interaction with underage minors Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage mfoors Adam Perry Lang Address unknown at this time Telephone number unknown at this time Traveling chef for Jeffrey Epstein and Ghislaine Maxwell and may hav knowledge of Gbjslaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Address unknown at this time Telephone number unknown at this time May have knowledge of Gbislaine Maxwell and Jeffr ey Epsteins sexual trafficking conduct and interaction with underage minors Michael Liffman CONFIDENTIAL as to victims i dentity pursuant to Courts June Order Case Document Filed Page of 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 MaxweJI 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 Epstein sexua trafficking conduct and interaction with underage minors Nadia Marcinko formerly Nadia Marcink.ova Jack Goldberger Esq Atterbury Goldberger Weiss P.A Australian Ave South Ste West Palm Beach FL Tel ONFIDENTIAL as to victi identity pursuant to Court June Order Case Document Filed Page of Has knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Bob Meister May have information about Ghislaine Maxwell and Jeffr ey Epsteins sex ual trafficking conduct and interaction with underage minors Todd Meister May have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual traffickin conduct and interaction with underage minors Brahakmana Mellawa Address unknown at thi time Telephone number unknown at this time House staff who may ave 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 Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Eps tein sexua trafficking conduct and interaction with underage minors Andrea Mitrovich Address Unknown Telephone number unknown at this time CONFIDENTIAL as to victims identity pursuant to Courts June Order h?h:??ɆȖX??G M?V nS O?j u0?H չP_ Vitg?G ᠩ?J??P?d I 3V bj UJ cF W?k0 vg A?B BF:?z p?sRj P?oT3 Oc?7?ڑ A?-?v?VՀ?Ì L??M R5?wE;?PN?P bڊ a u8 p?lO Jx U_ NT u??W?D ʂ?k/e rˀ A h?c L?av f3 Q??P Frz r?ت H:?J ft?G,?Ľ g?V eBV??_bL N??i DW?Ͳ u0?F?f XDU??H??J Sx qRQ3 F?ܢ zAf d?Q?H?r CC r)?P?f Qə_ 9lE i?Ňy LA B?H?pg eNXo;6?W Dw1 Ic?HJ?b?B?BFclB m?zK6V?r Y5 P?M x?E?c I uc??C5 n9w gCawI M?ϴl Ǩߨc WU dZ??ᘐ Gq??n FC?R zd Ѐ??Tq lJh v?P t3?Hɀ iX h??L w?VE p?a 쀀??h v?q I 0V ڸ岩Z??W fZll?K?gX7?NY4 e2 T?w kVe 3F eףo?9 hi f?n W?Z 6y?A B0H kEc?Zz?F Tl?䄿 E?ND?Px?r?R8 Od?(?u?G 4s a?ͼ R??ϲ?P Ӱ7kCD Qb?3 H,U q?b_ʊ BfW Qd lj?h?v kZ7 i?w E??r Ri 3e?r ƨ?S NE x?j e?b Z2G Qĕ?f r639?eNa o??Vw ώ?p??u Mr ó:Dd Z?B??i 6?w?ry I?D U0 VƂ y2 v?FT 9X Љ?K S??g J?Z??Dmq7 nr a:?Bn 8Ĺ?H ĆM H?i ݠ8 k?D V?A?W 7I G8H zչĽ??2 WɁ??r c?IK gJ?ꘫ X?ʀ 3?uI Eρ n?n?e kQj RZ??X rh C1 J??V Md૯:Ɍ?MmZ r5Y?NG ȫ?Q tB hj2ſ?f Cߠ r?R VӶ?g?l?o 9s?t y?5Z?ra;y qO 4?Cr t,i H?g Ub I?GkY?0 dX BƳ a??u?O 2I dW p??V W?T sG WT Q?U?d?P I bA C?Ko?r G?z GLF Wp nVSEdU G??h vPc?"t Bc5?qH SL m?R u?K X?A O?r 9v??I?ZN UAČ vlH a F?I?b lޗ 6?r?f?ր?8?zOUҋ?m Øi v5 OH Sj bD ӈj4 D?Ѐ ɶQ Bm?PŻ Tu Ā??Nf?mX wh 7gm?ɳ??H N?9n p?z vs y!?X Rk??q kY?0 si Lj W?Tl G?D?_S?eS Ŕr 욵cI a bL?c WƇ?i SS?A u?CX?Pc 5C?x WDL?u s7j Yp??ۃ ۂ?d?Q?k??t?"tG a 0U p?Vq??QPl a kT?Р?"ؾ Case Document Filed Page of Knowledge of Defendants conduct that is the ubject of this action Bill Peadon Telephone number unknown at this time House staff that may have know edge of Ghis aine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Francis Peadon Telephone number unknown at this time House staff that may have know edge 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 sexua trafficking conduct and interaction with underage minors Dara Preece Address Unknown Telephone Unknown at this time May have knowledge of Defendants conduct i this action Louella Rabuyo Address unknown at this time Telephone unknown at this time House staff that may have know edge of Ghis aine Maxwe and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Joseph Recarey Telephone number unknown at this time CONFIDENTIAL as to victims identity pursuant to Courts June Order Case Document Filed Page of Detective Recarey was the chief investigator of the crimes committed at Jeffrey Epsteins Palm Beach mansion and has information about Ghis aine Maxwe ll and Jeffrey Epsteins sexua trafficking conduct and interaction with underage minors Chief Michael Reiter Telephone number unknown at this time Police Chief Reiter oversaw he investigation of the crimes committed at Jeffrey Epstejns Palm Beach mansion and has information abou Ghis aine Maxwe ll and Jeffrey Epsteins sexual trafficking conduct and abuse of underage minors Bill Richardson Address unknown at this time Te ephone number unknown at this time Has knowledge of Ghlslaine Maxwell and Jeffrey Eps teins sexual trafficking conduct and interaction with underage minors Rina ld Rizzo c/o Robert Lewis Esq Freeman Lewis LLP th Street th Floor New York NY Te Has knowledge of Ghislaine Maxwell and Jeffrey Eps tein sexual trafficking conduct and interaction with underage minors Haley Robson Ad dr ess unknown at this time Te ep hone number unknown at thi time Has knowledge of Ghislaine Maxwel1 and Jeffrey Eps te i sexua trafficking conduct and interaction with underage mi ors Sky Roberts CONFIDENTIAL as to victims identity pursuant to Courts June Order Case Document Filed Page of Family member who may have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors David Rodgers c/o Bruce Reinhart Esq McDonald Hopkins LLC Flagler Dr Ste West Palm Beach FL Tel Has knowledge of Ghis1aine Maxwell and Jeffrey Epsteins sexua1 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 Marshall Dore Louis Esq N.W rd Street uite 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 rince 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 knowledg-e of Ghislaine Maxwell and Jeffrey Epsteins exual trafficking conduct and interaction with underage minors Cecilia Stein Address unknown at this time Telephone number unknown at this time CONF IDENTIAL as to victims identity pursuant to Courts June Order Case Document Filed Page of May have knowledge of Gbislaine 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 May have know ledge 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 Courtney Wild c/o Bradley Edwards Esq FARMER JAFFE WEIS SING EDWARDS FISTOS LEHRMAN North Andrews Avenue Suite Fort Lauderdale Florida Tel ONFIDENTIAL as to victims identity pursuant to Court June Order Case Document Filed Page of Has information about Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Doug Wilson Family member who may have knowledge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking cond uct and interaction wi th underage minors Igor Zinoview Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Eps tein sexua trafficking conduct and interaction with underage minors AU females identified in the police reports or identifi ed through the United State Attorneys office during or through the criminal investigation of Jeffrey Epste in and his co-conspirators AU other then-minor girls recruited by Ghislaine Maxw ell whose identities Ms Giuffre will attempt to determine with whom Defendant Ghislaine Maxwell and Jeffrey tein have engaged in sexual activity All pilots chauffeurs chefs aud other employees of either Defendant Maxwell or Jeffrey Epstein with knowledge of Defendant and Jeffrey Epstei inappropriate conduct with underage girls All staff and employees at the Mar-a-Lago Clu during All other witnesses learned through discovery process Relevant Documents All files held by the Palm Beach Police Department or the Palm Beach State Attorneys office which are publically available All press releases of Ghislaine Maxwell or on her behalf t8 CONFIDENTIAL as to victims identity pursuant to Courts June Order Case Document Filed Page of The video of Ghislaine Maxwell adopting the January press statement All newspaper or other media where Ghislaine Maxwells press release appears All evidence obtained by the Federal Bureau of Investigations which elate 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 Attorneys office by or through the criminal investigation of Alfredo Rodriguez All document relating to the previous subpoenas served on Defendant for her deposition and all documents related in any way to that deposition All documents evidencing visitors or passengers at any of Jeffrey Epstein owned or controlled property or aircraft All docum nts demonstrating the relationship between Bi11 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 All documents and information from Shoppers Travel evidencing travel flight records or passenger manifests during the relevant period All documents and information from David Rigg Aviation Insurance Agent evidencing travel flight records or passenger manifests during the relevant period Exhibits Palm Beach Police Department report and documents contained wi thin Jeffrey Epsteins criminal files attached hereto as Exhibit March Statement on behalf of Ghislaine Maxwe11 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 ONFIDENTIAL as to victi ms identity pursuant to Court June Order Case Document Filed Page of FBI Statement attached hereto as Exhibit Flight Logs attached hereto as Composite Exhibit Message Pads from Law Enforcement from trash pull of Jeffrey Epstein 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 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 oftbe NPA pg and The Government was well aware of Jane Doe No when it was negotiating the NPA 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 Vrrginia 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 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 ONFIDENTIAL as to victims identity pursuant to Courts June Order yQ r?r?-H φ?;d a Hм4 is??K lA N??G A-I?qhmݵ箫 c?耀?e??dO E??h i ȯxN?f GEA Nx f?a F?јW?R aG kƤ?x ZpI i ꄺQ v?x r?Y c?t Bh?eA a A R??Џ o?b?ʭX I6 Hj i Ba gF ʀS N!H By s?h j?Ř7?u 6oj PX ŻQ??zHΛNdJ QY T?h dQ1 И?g?3N N3H o?f?à a A??YS Z?u gj mʏܓ?OT?y PҺ 2c?j?IeI k?z WӕK d??Ol?p oZQT A?yH i kt C?4d sf kg?v uށ s0?wW U:p тl n5 ʺ?Y i a JB p?瀬?o Kd MZl?X W?X K??UZƽ x1GЀ 뿸?gt jff??s a Fi _s A kT?j2 b?H R?G ZD I iRq fF hM ax?ڄ c?P l?P R?!р wr3?N I sw sz??ɱ nD xb w?ڳ?h?ځ US?i?N?A?0S qߌ gVoE x??ڄ rNw P?F I?ݗ V?n vZ ھꖀ φ?;t h?b Z?E 2oкa?G??K X??ժP??X?ˊm4 Ku n?I?F uqB?ax b?Ak ų6 Ǿ??diz䀀 5?o?I4vL i??F e0 Ux?e Qi g?Z Bs?a οL FAy??g?P q?u?akO aW?p IS?p E?zϲ9z T8 a qYB A??K I Xd??Ԁ XP6 Ƶ?dJ?5 BId?T iT Du 2o s?,ek Zu m?Uက?b K?g Y_ Ç?H qA B?E 7s?d?fr?i L?Ȝ p?Q j??ϝ tࢦ md j?2et ӗ??w 3M i?J?kYε?DK U?"Ԑ?ԕ Q??N Y?N8 I dW?O s?f LG rt Rh?M lu Ag??C I KLݠL?bl ӘT C?P K?0qӑ 4E?y?sm)X?p Ic q?uz?f?F?D vt?x J?k J"H I?v?m 9PB 5퀀Ϋ?ct?t?3 hɣ?r wy?n g?I 8V E?o?yI4 t1 T?W?u??x 6p 1C 9!S?IZj u?T?qF SX?P a?RJ k?N Tg h_ W??M A çD!tx u?S k?k ϔ?a NJ C?z 3V?ߧht?g J?z o_?ڴa??m cG??G Z?P p??DŽ dj Case Document Filed Page of 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 Dai 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 amoW1t of approximately present value a Computation Analysis Giuffre has had to receive trea1ment for the psychological harm as a result of Maxwells conduct towards Giuffre ii The average annual expenditures for mental health services for adults in the United States is 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 disooW1t rate the present value of expected treatment costs is as of ONFIDENTIAL as to victims identity pursuant to Court June Order Case Document Filed Page of Supporting Evidence Ms Giuffre is in the process of collecting records from her physicians Ms Giuffres testimony ru Ms Giuffre is in the process of retaining 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 steem 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 3d nd Cir Second Circuit holding that i a statement i defamatory per se injury is assumed In such a case even where the plaintiff can show no actual damages at all a plaintiff ho has otherwise shown defamation may recover at least nominal damages and the Second Circuit also confirmed an award of punitive dam.ages Ms Giuffre has been severely damaged by the defamation of the defendant by calling her claims of sexual abuse obvio lies The defamation caused Ms Giuffre to re-Jive the sexual abuse she previously endured Ms Giuffre has suffered and continues to suffer from the pain mental anguish humiliation embarrassment lo ss of self-esteem oss of standing in the community lo ss of dignity and invasion of privacy in her public and private life The computation of this amount is in th province of the jury but Ms Giuffre contends including but not limited to awards in other simi lar matters that the 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 Ms Giuffres testimony ONFIDENTIAL as to victims identity pursuant to Court June Order Case Document Filed Page of Witness testimony Awards in similar matters iv Ms Giuffre is in the process of retaining an expert and will provide further information through expert disclosure 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 MaxweU in an amount not less than a This calculation is in the province of the jury ONFIDENTIAL as to victi identity pursuantto Courts June Order Case Document Filed Page of Dated June Respectfully Submitted BOIES SCIITLLER FLEXNER LLP By Isl Sigrid McCaw1ey Sigrid Mccawley Pro Hae Vice Meredith Schultz Pro Hae Vice Boies Schiller Flexner LLP Las Olas vd Suite Ft Lauderda le FL David Boies Boies Schiller Flexner LLP Main Street Armonk NY I Bradley Edwards Pro Rae Vice FARMER JAFFE WEISSING EDWARDS FISTOS LEHRMAN North Andrews A venue Suite Fort Lauderdale Florida Paul Cassell Pro Hae Vice S.J Quinney College of Law University of Utah University St Salt Lake City UT I This daytime business address is provided for identification and correspondence purposes onJy and is not intended to imp institutional endorsement by the University of Utah for this private representation CONFIDENTIAL as to victims identity pursuant to Courts June Order 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 Ci has been provided by United States mail and electronic mail to all counsel of record identified below on this 24th day of June Laura A Menninger Esq Jeffrey Pagliuca Esq HADDON MORGAN FOREMAN East th A venue Den er Colorado Tel Fax Email lrnenninger bmflaw.com Email jpagliuca hmflaw.com By I Sigrid Mccawley Sigrid Mccawley CONFIDENTIAL as vi ctims i tity pursuant to Court June Order
