Gov - Uscourts.nysd.447706.1322.1 4
Gov - Uscourts.nysd.447706.1322.1 4
Gov - Uscourts.nysd.447706.1322.1 4
EXHIBIT N
Case 1:15-cv-07433-LAP Document 1322-1 Filed 01/04/24 Page 2 of 19
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VIRGINIA L. GIUFFRE,
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
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disclosures:
1. Ghislaine Maxwell
c/o Laura A. Menninger, Esq.
Haddon, Morgan & Foreman, P.C.
150 E. 10th Ave.
Denver, CO 80203
303-831-7364
[email protected]
Ms. Maxwell is the Defendant and may have knowledge concerning matters at
issue, including the events of 1999-2002 and the publication of statements in the
press in 2011-2015.
8. David Boies
Boies, Schiller, Flexner LLP
575 Lexington Ave.
New York, NY 10022
(212) 446-2300
Mr. Boies has knowledge concerning matters at issue in the Complaint and in
Plaintiff’s pleadings and sworn statements in other litigations, including in
particular her publicly filed allegations concerning Defendant and Alan
Dershowitz.
9. Laura Boothe
The Mar-a-Lago Club, LC.
1100 South Ocean Boulevard,
Palm Beach, FL 33480
Ms. Boothe has knowledge concerning matters at issue, including the date that
Sky Roberts began working at the Mar-a-Lago Club, and the human resources
department at Mar-A-Lago.
Ms. Boulet may have knowledge concerning Plaintiff’s false claims against
Defendant.
Ms. Boylan has knowledge concerning Plaintiff during the relevant time period
including claims for damages, motive and bias.
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Mr. Schoettle may have knowledge concerning Plaintiff’s false claims against
Defendant.
Ms. Stein may have knowledge concerning Plaintiff’s false claims against
Defendant.
Mr. Tafoya may have knowledge concerning Plaintiff’s false claims against
Defendant.
67. Ed Tuttle
Address unknown at this time
Telephone number unknown at this time
Mr. Tuttle may have knowledge concerning Plaintiff’s false claims against
Defendant.
Ms. Vaghan may have knowledge concerning Plaintiff’s false claims against
Defendant.
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Ms. Valdes may have knowledge concerning Plaintiff’s false claims against
Defendant.
Ms. Vazquez may have knowledge concerning Plaintiff’s false claims against
Defendant.
Ms. Ward may have knowledge concerning Plaintiff’s false claims against
Defendant.
Ms. Wild may have knowledge concerning Plaintiff’s false claims against
Defendant.
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Mr. Wilson may have knowledge concerning matters at issue, including Plaintiff’s
activities during 1996 – 2002.
The Duke has knowledge concerning Plaintiff’s false statements to the press, in
court pleadings, and in sworn testimony as well as the events of 1999-2002.
78. Witnessed identified by Plaintiff in any of the various versions of her Rule 26
disclosures.
79. Witnesses whose identities and contact information can be identified in law
enforcement reports disclosed herein.
a. “Sordid friends and why he isn't fit for the job: Duke of York risks
losing ambassador role,” Daily Mail Online (Feb. 28, 2011).
b. “Prince Andrew and the 17-year-old girl his sex offender friend flew
to Britain to meet him,” Daily Mail Online (corrected Mar. 2, 2011).
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g. “Prince Andrew story runs and runs - but editors should beware,” The
Guardian (Jan. 5, 2015).
h. “US lawyer sues in Prince Andrew sex claims case,” Time (Jan 6,
2015).
l. “Jeffrey Epstein accuser was not a sex slave, but a money-hungry sex
kitten, her former friends say,” NY Daily News (Mar. 1, 2015).
m. “Twat Claims She Was Underage Sex Slave Bedding Prince Andrew,”
http://www.mgtowhq.com/viewtopic.php?f=2&t=6676 (Jan. 5, 2015).
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6. Jane Doe #1 and #2 v. United States, U.S. District Court for the Southern
District of Florida, 08-cv-80736-KAM pleadings to include:
7. Epstein v. Scott Rothstein and Bradley J. Edwards, In the Circuit Court of the
Fifteenth Judicial Circuit in and for Palm Beach County, Florida, 09-ca-
040800, pleadings to include:
8. Law enforcement records obtained from the Palm Beach County (Florida)
Sheriff’s Office, the Royal Palm Beach (Florida) Police Department, the
County Court in and for Palm Beach County (Florida), the Greenacres
(Florida) Department of Public Safety, and the Fremont County (Colorado)
Sheriff’s Office.
10. Education records obtained from Royal Palm Beach Community High School
and Forest Hills High School.
12. Documents received from any other party through disclosures and/or in
discovery, including any deposition exhibits, will not be identified or
produced, though they technically may fall within this category “II”, and
Defendant reserves the right to utilize such documents at any hearing or trial
on this matter.
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Not applicable at this time Ms. Maxwell reserves her right to supplement these
disclosures as necessary.
s/ Laura A. Menninger
Laura A. Menninger
Jeffrey S. Pagliuca
HADDON, MORGAN AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
[email protected]
[email protected]
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CERTIFICATE OF SERVICE
I certify that on June 17, 2016, I electronically served this DEFENDANT GHISLAINE
MAXWELL’S THIRD SUPPLEMENTAL F.R.C.P. 26(A)(1) DISCLOSURES via e-mail on the
following:
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