Maxwell Exhibit 38 Pre Redaction

Case Document 1090-38 Filed 07/30/20 Page 1 of 19 EXHIBIT Case 1:15-cv-07433-LAP Document 1090-38 Filed 07/30/20 Page 2 of 19 United States District Court Southern District Of New York --------------------------------------------------X Plaintiff, v. GHISLAINE MAXWELL, Defendant. .......................................... VIRGINIA L. GIUFFRE, 15-cv-07433-RWS --------------------------------------------------X DEFENDANT GHISLAINE MAXWELL’S THIRD SUPPLEMENTAL F.R.C.P. 26(A)(1)(A) DISCLOSURES Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following disclosures: I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH PARTICULARITY IN THE PLEADINGS 1. Ghislaine Maxwell c/o Laura A. Menninger, Esq. Haddon, Morgan & Foreman, P.C. 150 E. 10th Ave. Denver, CO 80203 303-831-7364 LMenninger@HMFLaw.com 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. 2. Virginia Lee Roberts Giuffre c/o Sigrid S. McCawley, Esq. Boies, Schiller & Flexner LLP 401 East Las Olas Boulevard, Suite 1200 Case Document 1090-38 Filed 07/30/20 Page 3 of 19 Miami Florida 33301 (954) 356-0011 Ms. Giuffre is the Plaintiff and has knowledge concerning the matters at issue in her Complaint. including the events of 1996-2015 and the publication of statements in the press in 2011-2015. Address unknown at this time Telephone number unknown at this time has knowledge about matters at issue, including Plaintiffs 1erea outs 1u'ing 2000-2002 and her false claims concerning Defendant and others. Address unknown at this time Telephone number unknown at this time has knowledge about matters at issue, including Plaintiffs whereabouts dlu'ing 2000-2002 and her false claims concerning Defendant and others. _has knowledge concerning matters at issue in the Complaint i_ncluding events of 1996- 2002. has knowledge conceining press statements by Plaintiff and Defendant in 2011-2015 at issue in this matter. Address unknown at this time Telephone number unknown at this time Case 1:15-cv-07433-LAP Document 1090-38 Filed 07/30/20 Page 4 of 19 has knowledge concerning matters at issue in the Complaint, including her own whereabouts and activities during the period 2000-2002. 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 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 began working at the Mar-a-Lago Club, and the human resources department at Mar-A-Lago. 10. Evelyn Boulet Address unknown at this time Telephone number unknown at this time Ms. Boulet may have knowledge concerning Plaintiff’s false claims against Defendant. 11. Address unknown at this time Telephone number unknown at this time has knowledge concerning Plaintiff during the relevant time period including claims for damages, motive and bias. 12. Address unknown at this time has knowledge concerning Plaintiff’s credibility, including false claims of sexual assault. 13. Address unknown at this time Telephone number unknown at this time 3 Case Document 1090-38 Filed 07/30/20 Page 5 of 19 14. 15. 16. may have knowledge concerning Plaintiffs false claims against Defendant. Paul Cassell 383 South University Street Salt Lake City. UT 84112 801-585-5202 paul.cassell@law.utah.edu Mr. assell has knowledge concerning press statements by Plaintiff. Plaintiffs court pleadings, and Plaintiffs sworn testimony. Sharon hru'cher 3 Deveau Road N. Salem. NY 10560 Ms. hurcher has knowledge concerning matters at issue. including Plaintiffs statements regarding Defendant and others. Alexandra Cousteau Address unknown at this time Telephone number rurknown at this time Ms. Cousteau may have knowledge conceming Plaintiffs false claims against Defendant and others. 18. has knowledge concerning Plaintiffs false statements to the press, in corut pleadings, and in sworn testimony. at issue in this matter. has knowledge about matters at issue. including Plaintiffs whereabouts dining 2001 and her claimed damages. Case Document 1090-38 Filed 07/30/20 Page 6 of 19 Address rurkrrown at this time Telephone number rmknown at this time may have knowledge concerning Plaintiff? 3 false claims against Defendant. 20. Bradley Edwards Farmer, affe, Weissing, Edwards, Fistos Lehrnran, PL. 425 N. Andrews Ave., Suite 2 Ft. Lauderdale, FL 33301 (954) 524-2820 Mr. Edwards has knowledge concerning Plaintiff 8 false statements to the press, in corut pleadings, and in sworn testimony at issue in this matter. Mr. Edwards also has knowledge concerning ?Victim?s Refuse Silence, Inc.? 21. Amanda Ellison Address rurknown at this time 561-628-4338 Ms. Ellison has knowledge concerning Plaintiff 5 false allegations concerning Defendant. has knowledge concerning Plaintiffs false allegations concerning Defendant. 23. Jeffrey Epstein c/o Tonja Haddad Coleman, Esq. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 (954) 467-1223 Mr. Epstein has knowledge concerning Plaintiff 5 false statements to the press and in coru't pleadings, as well as the events of 1999-2002 concerning Plaintiff and Defendant. A 'ess ur rown at this time Telephone number unknown at this time Case Document 1090-38 Filed 07/30/20 Page 7 of 19 may have knowledge concerning Plaintiffs false claims against Defendant. Address unknown at this time Telephone number rurknown at this time may have knowledge concerning Plaintiffs false claims against De err ant. 26. Address unknown at this time Telephone number unknown at this time may have knowledge concerning Plaintiffs false claims against Defendant and others. A e35 111 rown at this time may have knowledge concerning matters at issue. including Plaintiffs activities dru?ing 1996 2002 28-- has knowledge concerning matters at issue. including Plaintiffs act1v1t1es ru?ing 1996 2002. 29. - may have knowledge concerning travel of A ?ess unknown at this time Telephone number unknown at this time may have knowledge concerning Plaintiff whereabouts during 2000- 2002 and her false claims against Defendant. 31. Meg Garvin Lewis Clark Law School Case Document 1090-38 Filed 07/30/20 Page 8 of 19 10015 S.W. Terwilliger Boulevard MSC 51 Portland, Oregon 97219 Ms. Garvin has knowledge concerning matters at issue including Victims Refuse Silence and Plaintiff damages. 32. Sheridan Gibson-Butte Address unknown at this time Telephone number unknown at this time Ms. Gibson-Butte may have knowledge concerning Plaintiffs false claims against Defendant. is may have knowledge concerning matters at issue. including Plaintiffs activities dining 2002-2016 and her damages allegations. may have knowledge concerning matters at issue, including the publication of statements in the press in 2011-2015 concerning Plaintiff and Defendant. DJ LII . Fred Graff Address unknown at this time Telephone number unknown at this time Mr. Gr'aff may have knowledge concerning Plaintiffs false claims against Defendant. Address unknown at this time Telephone number unknown at this tinre may have knowledge concerning matters at issue. including Plaintiffs activities during 1996 2002. Case Document 1090-38 Filed 07/30/20 Page 9 of 19 - may have knowledge concerning matters at issue. 38. Address unknown at this time Telephone number unknown at this time may have knowledge concerning Plaintiffs false claims against Defendant. 39. Address unknown at this time Telephone number unknown at this time may have knowledge concerning Plaintiffs false claims against Defendant. 40. Brittany Henderson Farmer, affe, Weissing, Edwards. Fistos Lehrman, PL. 425 N. Andrews Ave, Suite 2 Ft. Lauderdale, FL 33301 Ms. Henderson has knowledge concerning matters at issue including Victims Refuse Silence and Plaintiffs damages. 41. Brett Jaffe Address unknown at this time Telephone number unknown at this time Mr. affe has knowledge concerning Plaintiffs false claims concerning Ms. Maxwell including her compliance with any deposition subpoena in the VRA matter. 42. Address unknown at this time Telephone number unknown at this time may have knowledge concerning matters at issue. including Plaintiffs activities diu'ing 1996 2002. 43. Dr. Karen Kutikoff 12957 Palms Drive #101 Case Document 1090-38 Filed 07/30/20 Page 10 of 19 Loxahatchee, FL 33470 Dr. Kuti?coff may have knowledge concerning matters at issue, including Plaintiffs whereabouts dining 1998-2002 and Plaintiffs damages. 44. Address unknown at this time Telephone number rurknown at this time may have knowledge concerning Plaintiff?s false claims against Defendant. 45. Tony Lyons Skyhorse Publishing, Inc. 307 West 36th Street, 1 1th Floor New York, NY 10018 Mr. Lyons may have knowledge concerning matters at issue, including Plaintiffs false allegations concerning Defendant and others. may have knowledge concerning Plaintiff?s false claims against Defendant. has knowledge concerning Plaintiff?s honesty and truthfuhless. 48. may have knowledge concerning matters at issue, including Plaintiffs activities dining 1996 2002. 49. Address unknown at this time Telephone number unknown at this time Case 1:15-cv-07433-LAP Document 1090-38 Filed 07/30/20 Page 11 of 19 may have knowledge concerning Plaintiff’s false claims against Defendant and others. 50. Address unknown at this time Telephone number unknown at this time may have knowledge concerning Plaintiff’s false claims against Defendant. 51. David Mullen Address unknown at this time Telephone number unknown at this time Mr. Mullen may have knowledge concerning Plaintiff’s false claims against Defendant. 52. Joe Pagano Address unknown at this time Telephone number unknown at this time Mr. Pagano may have knowledge concerning Plaintiff’s false claims against Defendant. 53. Mary Paluga Address unknown at this time Telephone number unknown at this time Ms. Paluga may have knowledge concerning Plaintiff’s false claims against Defendant. 54. J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 914-763-8333 Mr. Pottinger may have knowledge concerning matters at issue, including Plaintiff’s attempts to sell her story to the media and her contacts with the media. 55. Joseph Recarey 2753 Misty Oaks Circle Royal Palm Beach, FL 33441 Telephone number unknown at this time Mr. Recarey may have knowledge concerning Plaintiff’s false claims against Defendant. 10 Case Document 1090-38 Filed 07/30/20 Page 12 of 19 56. Michael Reiter 2335 So. Ocean Blvd. Apt. 15 Palm Beach. FL 33480 Telephone number unknown at this time Mr. Reiter may have knowledge concerning Plaintiffs false claims against Defendant. 57. Jason Richards Federal Bureau of Investigations Address unknown at this time Mr. Richards has knowledge concernin matters at issue. including Plaintiffs statements concerning Defendant. and other individuals. Address unknown at this time Telephone number unknown at this time may have knowledge concerning Plaintiffs false claims against Defendant and others. may have knowledge concerning matters at issue. including Plaintiffs activities during 1996 2002. has knowledge concerning Plaintiff's civil claims against Jeffrey Epstein. 61. Forest Sawyer Address unknown at this time Telephone number unknown at this time Mr. Sawyer may have knowledge concerning Plaintiffs false claims against Defendant. 62. Doug Schoetlle Address unknown at this time Telephone number rurknown at this time 11 Case 1:15-cv-07433-LAP Document 1090-38 Filed 07/30/20 Page 13 of 19 Mr. Schoettle may have knowledge concerning Plaintiff’s false claims against Defendant. 63. Address unknown at this time Telephone number unknown at this time may have knowledge concerning Plaintiff’s false claims against Defendant. 64. Mark Tafoya Address unknown at this time Telephone number unknown at this time Mr. Tafoya may have knowledge concerning Plaintiff’s false claims against Defendant. 65. Brent Tindall Address unknown at this time Telephone number unknown at this time 66. Address unknown at this time has knowledge concerning Plaintiff’s credibility, including false claims of sexual assault. 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. 68. Emma Vaghan Address unknown at this time Telephone number unknown at this time Ms. Vaghan may have knowledge concerning Plaintiff’s false claims against Defendant. 69. Kimberly Vaughan-Edwards Address unknown at this time Telephone number unknown at this time Believed to be in the UK 12 Case Document 1090-38 Filed 07/30/20 Page 14 of 19 70. 71. 72. 73. 74. 75. 76. Ms. Vaughan-Edwards has knowledge concerning facts relevant to this dispute and Ms. Maxwell?s character. resenda Valdes Address unknown at this time Telephone nrunber unknown at this time Ms. Valdes may have knowledge concerning Plaintiffs false claims against Defendant. Address rurknown at this time Telephone nrunber rurknown at this time may have knowledge concerning matters at issue, including Plaintist activities dining 1996 2002. Maritza Vazquez Address unknown at this time Telephone number turknown at this time Ms. Vazquez may have knowledge concerning Plaintiffs false claims against Defendant. Vicky Ward Address rurknown at this time Telephone number unknown at this time Ms. Ward may have knowledge concerning Plaintiff?s false claims against Defendant. Jarred Weisfeld Address unknown at this time Mr. Weisfeld may have knowledge concerning matters at issue, including Plaintiff attempted publication of false allegations concerning Defendant and others. may have knowledge concerning Plaintiffs false claims against Defendant. Address unknown at this time 13 Case 1:15-cv-07433-LAP Document 1090-38 Filed 07/30/20 Page 15 of 19 Telephone number unknown at this time may have knowledge concerning matters at issue, including Plaintiff’s activities during 1996 – 2002. 77. Address unknown at this time Telephone number unknown at this time 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. 80. Any other witness learned through the discovery process. Defendant Ghislaine Maxwell reserves her right to supplement these disclosures as additional witnesses are learned through the discovery process, or endorsed by Plaintiff. II. DOCUMENTS, DATA, COMPILATIONS AND TANGIBLE THINGS IN POSSESSION, CUSTODY OR CONTROL OF DEFENDANT THAT MAY BE USED TO SUPPORT DEFENDANT’S CLAIM OR DEFENSES 1. 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. 2. News articles from the internet: 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). c. “Unsavoury association: How Robert Maxwell's daughter 'procured young girls' for Prince Andrew's billionaire friend,” Daily Mail Online (Mar. 5, 2011). 14 Case 1:15-cv-07433-LAP Document 1090-38 Filed 07/30/20 Page 16 of 19 d. “Virginia Roberts' account of the explosive Prince Andrew 'sex slave' drama,” Daily Mail Online (Jan. 3, 2015). e. “Court papers put daughter of Robert Maxwell at centre of ‘sex slave’ scandal,” The Guardian (Jan. 4, 2015). f. “Prince Andrew denies sexual abuse allegations in unprecedented Buckingham Palace statement: The Duke of York denies having relations with alleged ‘sex slave,’” The Independent (Jan. 4, 2015). 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). i. “Harvard professor Alan Dershowitz denies charges of sex with underage girl,” Boston Globe (Jan. 22, 2015). j. “Virginia Roberts’s Aunt Reveals Jeffrey Epstein Girl Says I Am In Fear for My Life,” Daily Mail Online, (Jan. 10, 2015). k. “EXCLUSIVE: Alleged ‘sex slave’ of Jeffrey Epstein, Prince Andrew accused two men of rape in 1998, but was found not credible,” NY Daily News (Feb. 23, 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). n. “Exclusive: Prince Andrew at Heidi Klum’s ‘Hookers and Pimps’ party with the New York socialite accused of procuring underage girls for his billionaire pedophile friend” Daily Mail Online (May 10, 2016). 3. Email from to various news organizations, Subject: “Ghislaine Maxwell,” (Jan. 2, 2015). 4. “Lawyers Acknowledge Mistake In Filing Sexual Misconduct Charges Against Professor Dershowitz,” Joint Statement of Brad Edwards, Paul Cassell and Alan Dershowitz (Apr. 8, 2016). 5. Edwards and Cassell v. Dershowitz, In the Circuit Court of the Seventeenth Judicial District In and For Broward County Florida to include: 15 Case 1:15-cv-07433-LAP Document 1090-38 Filed 07/30/20 Page 17 of 19 a. Deposition testimony of Paul G. Cassell, dated October 16, 2015 and October 17, 2015. 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: a. Motion for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filing (July 28, 2008) (Doc. # 16) b. Notice of Change of Address and Firm Affiliation (Apr. 9, 2009) (Doc. # 37) c. Order Denying Petitioners’ Motion to Join Under Rule 21 and Motion to Amend Under Rule 15 (Apr. 7, 2015) (Doc. #324) d. Order Scheduling Settlement Conference Before the Magistrate Judge, U.S. District Court (Mar. 31, 2016) (Doc. #378) 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-ca040800, pleadings to include: a. Complaint (Dec. 7, 2009). 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. 9. Employment records obtained from ET Employment Training and Recruiting Australia. 10. Education records obtained from Royal Palm Beach Community High School and Forest Hills High School. 11. Documents received from Palm Beach County Library System. 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. 16 Case 1:15-cv-07433-LAP Document 1090-38 Filed 07/30/20 Page 18 of 19 Defendant reserves the right to identify additional documents, data, compilations and tangible things as discovery continues and to supplement this list accordingly. III. DESCRIPTION OF CATEGORIES OF DAMAGES SOUGHT AND COMPUTATION OF ECONOMIC DAMAGES CLAIMED BY THE DISCLOSING PARTY Not applicable at this time Ms. Maxwell reserves her right to supplement these disclosures as necessary. IV. INSURANCE AGREEMENT UNDER WHICH ANY PERSON CARRYING ON AN INSURANCE BUSINESS MAY BE LIABLE TO SATISFY A PART OR ALL OF A JUDGMENT Ms. Maxwell’s AIG Homeowners and Excess Liability insurance policies. Coverage has been denied by AIG, as their letter of April 18, 2016 to Ms. Maxwell, copied to Ms. McCawley, attests. Dated: June 17, 2016. Respectfully submitted, 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 lmenninger@hmflaw.com jpagliuca@hmflaw.com Attorneys for Ghislaine Maxwell 17 Case 1:15-cv-07433-LAP Document 1090-38 Filed 07/30/20 Page 19 of 19 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: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@aol.com s/ 18