United States District Court

United States District Court Southern District of New York Plaintiff, Case No.: v. Ghislaine Maxwell, Defendant. PLAINTIFF, DISCLOSURE PURSUANT TO FED. R. CIV. P. 26 COMES NOW the Plaintiff, by and through her undersigned counsel, and files this disclosure pursuant to Fed. R. Civ. P. 26 and states as follows: A. Witnesses: I. do Sigrid S. McCawley, Esq. Boies, Schiller & Flexner LLP 401 East Las Olas Boulevard, Suite 1200 Miami. Florida 33301 Tel: Email: Plaintiff - information regarding Defendant, Ghislaine Maxwell's conduct that is the subject of this action 2. Ghislaine Maxwell do Laura A. Menninger, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East le Avenue Denver olorado 0203 Tel: Email: Defendant in this action. 1 EFTA01079085 3. Juan Alessi Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action 4. Maria Alessi Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 5. Janusz Banasiak Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 6. Doug Band Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 7. Address unknown at this time Telephone number unknown at this time Knowledge concerning Defendant's conduct that is the subject of this action. 8. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 9. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 2 EFTA01079086 10. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 1 I. Address unknown at this time Telephone number unknown at this time Knowledge concerning Defendant's conduct that is the subject of this action. 12. Jean Luc Brunel Address unknown at this time Telephone number unknown at this time Knowledge concerning Defendant's conduct that is the subject of this action. 13. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 14. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 15. Valdson Cotrin Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 16. Address unknown at this time Telephone number unknown at this time Knowledge concerning Defendant's conduct that is the subject of this action. 3 EFTA01079087 17. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 18. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 19. Alan Dershowitz do Richard A. Simpson, Esq. WILEY REIN, LLP 1776 K Street NW Washin ton D.C. 20006 Tel: Knowledge of Defendant's conduct that is the subject of this action. 20. Ryan Dionne Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 21. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 22. Eva Anderson Dubin Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 23. Glen Dubin Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 4 EFTA01079088 24. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 25. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 26. Prince Andrew Albert Christian Edward, Duke of York Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 27. Jeffrey Epstein do Tonja Haddad Coleman, Esq. 315 SE 7th Street, Suite 301 Fort Lauderdale FL 33301 Tel: Knowledge of Defendant's conduct that is the subject of this action. 28. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 29. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 30. Alexandra Fekkai Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 5 EFTA01079089 31. Frederic Fekkai Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 32. Tony Figueroa Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 33. Luciano "Jojo" Fontanilla Address unknown at this time Jeffrey Epstein's staff member in his various homes with knowledge of Defendant and Jeffrey Epstein's inappropriate conduct with underage girls. 34. Lynn Fontanilla Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 35. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 36. Michael Friedman Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 37. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 6 EFTA01079090 38. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 39. Fred Graff Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 40. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 41. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 42. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 43. Shelly Harrison Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 44. Shannon Harrison Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 45. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 7 EFTA01079091 46. formerly ■ Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 47. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 48. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 49. Adam Perry Lang Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 50. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 51. Michael Liffmann Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 52. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 53. • Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 8 EFTA01079092 54. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 55. formerly Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 56. Bob Meister Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 57. Todd Meister Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 58. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 59. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 60. Marvin Minsky Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 9 EFTA01079093 61. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 62. Vanessa Modely Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 63. David Mullen Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 64. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 65. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 66. Joe Pagano Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 67. Mary Paluga Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. I0 EFTA01079094 68. Joel Pashcow Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 69. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action 70. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 71. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 72. Tom Pritzker Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 73. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 74. Rinaldo Rizzo Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 11 EFTA01079095 75. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 76. David Rogers Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 77. formerly Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 78. Forest Sawyer Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 79. Doug Schoetlle Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 80. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 81. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 12 EFTA01079096 82. Ellen Spencer Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 83. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 84. Mark Tafoya Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 85. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 86. Brent Tindall Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 87. Ed Tuttle Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 88. Emma Vaghan Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 13 EFTA01079097 89. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 90. Evelyn Valenzuela Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 91. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 92. Larry Visosky Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 93. Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 94. Igor Zinoview Address unknown at this time Telephone number unknown at this time Knowledge of Defendant's conduct that is the subject of this action. 95. All other then-minor girls, whose identities Plaintiff will attempt to determine, with whom Defendant, Ghislaine Maxwell and Jeffrey Epstein, have engaged in sexual activity. 96. All pilots, chauffeurs, chefs, and other employees of either Defendant Maxwell or Jeffrey Epstein with knowledge of Defendant and Jeffrey Epstein's inappropriate conduct with underage girls. 97. All staff and employees at the Mar-a-Lago Club during 1999. 14 EFTA01079098 98. All other witnesses learned through discovery process. B. Exhibits: I. Palm Beach Police Department report and documents contained within Jeffrey Epstein's criminal files, attached hereto as Exhibit A. 2. March 10, 2011 Statement on behalf of Ghislaine Maxwell by Media agent Ross Gow, attached hereto as Exhibit B. 3. January 3, 2015 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 C. 4. January 3, 2015 Press Statement issued by Ross Gow to Express set forth in "Ghislaine Maxwell: I was not a madam for paedophile," attached as Exhibit D. 5. January 4, 2015 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 He's Seen Cutting Swiss Vacation Short to Face Queen," attached hereto as Exhibit E. 6. February I, 2015 Mirror article: "Prince Andrew's Pal Ghislaine Maxwell May Sue Over Madam Allegations," attached hereto as Exhibit F. 7. May 1, 2009 Complaint in Jane Doe No. 102 v. Jeffrey Epstein, CIV-09-80656, in the Southern District of Florida, attached hereto as Exhibit G. 8. Right Logs, attached hereto as Exhibit H. C. Computation of damages: Physical, psychological and psychiatric injuries and resulting medical expenses — precise amount yet to be computed, but not less than $100,000.00. 2. Past, present and future pain and suffering, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of standing in the community, loss of dignity and invasion of privacy in her public and private life — precise amount yet to be computed, but not less than $30,000,000.00. 3. Past and future lost wages and past and future loss of earning capacity and actual earnings — precise amounts yet to be computed, but not less than $5,000,000.00. 4. Punitive Damages - to be based upon all relevant factors, including the egregious nature of Defendant, Ghislaine Maxwell's conduct and the need for a large award 15 EFTA01079099 to punish and deter conduct in view of the vast wealth of Defendant Maxwell, in an amount not less than $50,000,000.00 WE HEREBY CERTIFY that a true and correct copy of the above and foregoing Disclosure Pursuant to Fed. R. Civ. P. 26 has been provided by United States mail and electronic mail to all counsel of record identified below, on this 11th day of November, 2015. Laura A. Menninger, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver Colorado 80203 Tel: Fax: Email: 16 EFTA01079100 Respectfully Submitted, BOLES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Boles Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale. FL 33301 David Boles Boles Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Ellen Brockman Boles Schiller & Flexner LLP 575 Lexington Ave New York. New York 10022 17 EFTA01079101