Case 1:15-cv-07433-RWS Document 76 Filed 03/31/16 Page 1 of 2

Case 1:15-cv-07433-RWS Document 76 Filed 03/31/16 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS Declaration Of Laura A. Menninger In Support Of Motion To Compel Responses to Defendant's First Set of Discovery Requests to Plaintiff I, Laura A. Menninger, declare as follows: 1. I am an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell ("Maxwell") in this action. I respectfully submit this declaration in support of Ms. Maxwell's Motions to Compel Responses to Defendant's First Set of Discovery Requests to Plaintiff. 2. Attached as Exhibit A is a true and correct copy of Plaintiff's Amended Supplemental Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff, served on March 22, 2016. 3. Attached as Exhibit B is a true and correct copy of Plaintiff, [REDACTED]'s Revised Disclosure Pursuant to Fed. R. Civ. P. 26, served on March 11, 2016. EFTA01182998 Case 1:15-cv-07433-RWS Document 76 Filed 03/31/16 Page 2 of 2 4. Attached as Exhibit C is a true and correct copy of the Confidentiality Order issued in Edwards and Cassell v. Dershowitz, 15-000072, (17th Judicial District, Broward County, Florida). 5. I further certify that document bates numbered GIUFFRE003714 produced by Plaintiff in this matter is an email from Plaintiff to Sharon Churcher, a member of the media. The email shows that it includes an attachment. No attachment has been produced. The email is not being included herewith because Plaintiff marked it as "confidential." By: Is/Laura A. Menninger Laura A. Menninger CERTIFICATE OF SERVICE I certify that on March 31, 2016, I electronically served this DECLARATION OF LAURA A. MENNINGER IN SUPPORT OF MOTION TO COMPEL RESPONSES TO DEFENDANT'S FIRST SET OF DISCOVERY REQUESTS TO PLAINTIFF via ECF on the following: Sigrid S. McCawley BOIES, $CHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com /s/ Nicole Simmons Nicole Simmons 2 EFTA01182999 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/11 Page 1 of 45 EXHIBIT A EFTA01183000 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 2 of 45 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S AMENDED SUPPLEMENTAL RESPONSE AND OBJECTIONS TO DEFENDANT'S FIRST SET OF DISCOVERY REOUESTS TO PLAINTIFF Plaintiff hereby serves her amended supplemental responses and objections to Defendant's First Set of Discovery Requests. GENERAL OBJECTIONS Defendant's First Set of Discovery Requests violates Local Civil Rule 33.3. Defendant has served interrogatories that are in direct violation of that Rule because the interrogatories are not "restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation of each category of damage alleged, and the existence, custodian, location and general description of relevant documents, including pertinent insurance agreements, and other physical evidence, or information of a similar nature." Local Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil Rule 33.3, and therefore, they should not be served because they are not "a more practical method of obtaining the information sought than a request for production or a deposition," and because they were served in advance of the period "30 days prior to the discovery cut-off date." Local Civil Rule 33.3(b), (c). The interrogatories you served violate Local Rule 33.3 and we ask 1 EFTA01183001 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 3 of 45 that you immediately withdraw those interrogatories. See Rule 33.3, Local Rules for the Southern District of New York; see also Shannon v. New York City Transit Auth., No. 00 CIV. 5079 (Sweet, J.), 2001 WL 286727, at *3 (S.D.N.Y. Mar. 22, 2001); accord Gary Friedrich Enterprises, LLC v. Marvel Enterprises, Inc., No. 08 CIV. 1533 BSJ JCF, 2011 WL 1642381, at *4 (S.D.N.Y. Apr. 26, 2011). Specifically, Rule 33.3 provides: (a) (b) Unless otherwise ordered by the Court, at the commencement of discovery, interrogatories will be restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation of each category of damage alleged, and the existence, custodian, location and general description of relevant documents, including pertinent insurance agreements, and other physical evidence, or information of a similar nature. During discovery, interrogatories other than those seeking information described in paragraph (a) above may only be served (1) if they are a more practical method of obtaining the information sought than a request for production or a deposition, or (2) if ordered by the Court. (c) At the conclusion of other discovery, and at least 30 days prior to the discovery cut-off date, interrogatories seeking the claims and contentions of the opposing party may be served unless the Court has ordered otherwise. Similarly, Requests for Production numbers 1, 2, 4, 6(i), 9, 12, 30, 35 and 37 also violate Local Rule 33.3 in that they rely on the offending interrogatory requests. The Rule provides that a party must first try to obtain discovery through document production and testimony. Discovery does not close in this case until July 1, 2016, and Defendant has not yet noticed a deposition. As such, these interrogatories violate Local Rule 33.3 and are premature. Defendant's First Set of Discovery Requests also violates Rule 33, Fed. R. Civ. P., which provides "a party may serve on any other party no more than 25 interrogatories, including all discrete subparts" — in that Defendant has served a total of 59 interrogatories, including subparts, in violation of Rule 33. We ask that you immediately withdraw those interrogatories that exceed the 25 interrogatory limit set by Rule 33. 2 EFTA01183002 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 4 of 45 Ms. Giuffre objects to Defendant's First Set of Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege, work product privilege, joint defense/common interest privilege, public interest privilege, and any other applicable privilege. Ms. Giuffre objects to the requests to the extent Defendant's First Set of Discovery Requests call for the production of documents or information that is already in the possession, custody, or control of the Defendant. Ms. Giuffre further objects to the requests to the extent that Defendant's First Set of Discovery Requests is duplicative of documents and information that can equally or more readily be obtained by the Defendant. Ms. Giuffre objects to the requests to the extent that they seek documents that are not relevant, material, or necessary to this action and, thus, are not reasonably calculated to lead to the discovery of admissible evidence. Many of the requests in the Defendant's First Set of Discovery seek documents that are in no way limited to their relation to this case. Indeed, they seek documents that are not important to resolving the issues; documents that are not relevant to any party's claim or defense; and documents that are not proportional to the needs of the case. Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery is prohibited by the Federal Rules of Civil Procedure, particularly under the 2015 amendments to Rule 26(b)(1), Fed. R. Civ. P., and is wholly inappropriate. Ms. Giuffre objects to the requests to the extent that they are overly broad and unduly burdensome, as individually logging all privileged responsive documents would be overly burdensome. Plaintiff contends that requests targeting such privileged information are overly broad under Rule 26(b)(I), Fed. R. Civ. P. Specifically, Ms. Giuffre objects to the requests as overly burdensome to the extent that they would require logging voluminous and ever-increasing 3 EFTA01183003 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 5 of 45 privileged communications between Ms. Giuffre and her counsel after the date litigation commenced on September 21, 2015. Ms. Giuffre objects to the requests as overly burdensome to the extent that they would require logging voluminous privileged documents between Ms. Giuffre and her counsel related to Jane Doe #1 and Jane Doe #2 v. United States, Case no. 08- 80736-CIV-Marra, pending in the Southern District of Florida; Bradley Edwards and Paul Cassell v. Alan Dershowitz, Case no. CACE 15-000072, pending in the Seventeenth Judicial Circuit, Broward County, Florida; and Jane Doe No. 102 v. Jeffrey Epstein, Case No. 09-80656- CIV-Marra/Johnson (Southern District of Florida). Accordingly, due the undue burden of individually logging responsive privileged documents related to Defendant's overly broad requests, Plaintiff has employed categorical logging of such privileged responsive documents pursuant to Local Civil Rule 26.2(c). Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking. Ms. Giuffre objects to the requests to the extent they are overly broad and unduly burdensome. Ms. Giuffre objects to Defendant's definition of "your attorneys" because it includes names of attorneys that do not represent her, including Spencer Kuvin and Jack Scarola. Ms. Giuffre's responses to Defendant's First Set of Discovery Requests are being made after reasonable inquiry into the relevant facts, and are based only upon the information and documentation that is presently known to her. Ms. Giuffre reserves the right to modify and/or supplement her responses. Ms. Giuffre is producing documents and information herewith, and she will continue to review and produce relevant documents until completion. Ms. Giuffre incorporates her above-listed general objections in the responses herein. 4 EFTA01183004 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 6 of 45 INTERROGATORIES 1. State: a. Your present residential address; b. Each residential address You have had since 1998, including any residential treatment facilities; c. the dates You lived at each address; d. the other Persons who lived with You at each address and for what period of time they lived at such address. Response to Interrogatory One: Ms. Giuffre objects to this interrogatory in part because it violates Rule 33.3. Ms. Giuffre objects to this interrogatory in that it seeks information that is sought by Defendant only to harass and intimidate Ms. Giuffre who was a victim of sexual trafficking. Per the Plaintiff's First Responses and Objections, and per our representations during the March 21, 2016 meet and confer phone call, we are working diligently to find information to supplement the below information with regard to address and dates, and once that information is obtained, Plaintiff will serve supplemental responses. Additionally, per the March 21, 2016 meet and confer phone call, we are addressing with the Plaintiff whether she will reveal here address to Defendant's counsel confidentially and we will update you with her response. a. Due to safety concerns with respect to Ms. Giuffre and her minor children, she is not at liberty to reveal her present residential location. To ensure that Defendant is not prejudiced by the failure to provide information about Ms. Giuffre's specific residential location, Ms. Giuffre agrees to have her attorney's accept service on her behalf of any necessary communication or 5 EFTA01183005 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 7 of 45 filings in this matter to be addressed to: Sigrid McCawley, Esq. Boies Schiller & Flexner LLP, 401 East Las Olas Blvd., Suite 1200, Fort Lauderdale, FL 33316. b. Ms. Giuffre can recall living at the following addresses during the period of 1998 to the present. Ms. Giuffre may have lived at other locations for which she does not presently have the address. Ms. Giuffre is providing the information she has presently to the best of her recollection and review of documents and will supplement to the extent she obtains additional information responsive to this interrogatory. c. Ms. Giuffre believes she has lived at the following residences: • In January 1998, Ms. Giuffre was 14 years old. Ms. Giuffre recalls one facility named "Growing Together" that was located in or around Palm Beach, but she does not recall the dates when she resided at the facility. • From 1999-2002, Ms. Giuffre lived and travelled with Jeffrey Epstein and stayed at his various mansions in New York (9 E. 71st Street, New York, NY 10021-4102), Palm Beach (358 El Brillo Way, Palm Beach, Florida 33480, New Mexico (Zorro Ranch, 49 Zorro Ranch Rd., Stanley, New Mexico 87056), U.S.V.I. (Little St. James, 6100 Red Hook Quarters, Suite B3, St. Thomas, Virgin Islands 00802), and Paris (22 Avenue Foch Apt 2DD, Paris, France 75116). 6 EFTA01183006 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 8 of 45 • Jeffrey Epstein also rented a residence for Ms. Giuffre in Royal Palm Beach, the exact address and dates of rental are in the possession, custody and control of Jeffrey Epstein. Tony Figueroa, James Michael Austrich and a few other individuals for whom Ms. Giuffre cannot recall the names of, stayed with her from time to time at the residence that Jeffrey Epstein rented. • Ms. Giuffre's parents' address was 12959 Rackley Road, Loxahatchee, Florida 33470, and she lived there from time to time with her mother, her father, and her brothers. • 2C Quentin St. Basshill NSW in approximately 2003, but she is not certain of that date. At this location, Ms. Giuffre lived with Robert Giuffre. • N. Paramentata, NSW from approximately 2003 - 2005, but she is not certain of those dates. At this location, Ms. Giuffre lived with Robert Giuffre. • Blue Bay, NSW from approximately 2005 - 2008 but is not certain of those dates. At this location, Ms. Giuffre lived with Robert Giuffre. • 3 Elk St., NSW from approximately 2008 - 2009 but is not certain of those dates. At this location, Ms. Giuffre lived with Robert Giuffre. • 50 Robertson Road, Basshill, NSW, but is not certain of the date. At this location, Ms. Giuffre lived with Robert Giuffre. 7 EFTA01183007 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 9 of 45 • 50 Bundeena Rd., Glenning Valley, NSW from approximately 2009 - 2013 but is not certain of those dates. At this location, Ms. Giuffre lived with Robert Giuffre. • 5035 Winchester Drive, Titusville, FL from approximately November 6, 2013 to 2014 but is not certain of those dates. At this location, Ms. Giuffre lived with Robert Giuffre. • 1270 J. Street, Penrose, CO 81240, from approximately 2014 — 2015. At this location Ms. Giuffre lived with Robert Giuffre. 2. Identify any email address, email account, cellphone number and cellphone provider, social media account and login or screen name, text or instant messaging account name and number, that You have used, applied for or been supplied between 1998 and the present. Response to Interrogatory No. 2 Ms. Giuffre objects to this request in that it violates Rule 33.3. Ms. Giuffre objects to this request in that it is overly broad and seeks information solely to harass and intimidate Ms. Giuffre. For the period of 1998 to the present Ms. Giuffre provides the following information. During the time period that she was sexually trafficked by Jeffrey Epstein and the defendant, the defendant provided Ms. Giuffre with a cellphone so that she could be reached by the Defendant and Jeffrey Epstein at any time. Defendant is in possession of the information relating to this cellphone that she provided to Ms. Giuffre. Ms. Giuffre is responding with the information she can presently recall, but to the extent she obtains additional information she will supplement this response. Ms. Giuffit's e-mail address is robieiennagQv7mail.com. She can recall having the following cell numbers (321) 2714948, +61414651273, 0407.433.252. Ms. Giuffre had a Facebook account for a short time but it is no longer active. Per our representations during the 8 EFTA01183008 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 10 of 45 March 21, 2015 meet and confer phone call, we are working diligently to find information to supplement the above information, and once that information is obtained, Plaintiff will serve supplemental responses. 3. Identify each attorney who has represented you from 1998 to the present, the dates of any such representation, and the nature of the representation. Response to Interrogatory No. 3 Ms. Giuffre objects to this interrogatory as it seeks privileged information relating to her representation by attorneys. Ms. Giuffre responds that she has been represented by the following attorneys: Bob Josefsberg and members of his firm; Stan Pottinger, Brad Edwards from Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.; Paul Cassell, a Professor of Criminal Law at the S.J. Quinney College of Law at the University of Utah; David Boies, Sigrid McCawley, and other attorneys and staff at Boies Schiller & Flexner LLP. 4. Identify each Communication, including the transmission of any Document, that You or Your Attorneys have had with any local, state or federal law enforcement agent or agency, whether in the United States or any other country, whether in Your capacity as a purported victim, witness, or perpetrator of any criminal activity, and whether as a juvenile or as an adult, including without limitation: a. the date of any such Communication; b. the form of any such Communication, whether oral or written and if written, the format of any such Communication; c. the identities of all persons involved in the Communication, including the identity of the law enforcement agency with whom the agent is or was affiliated; 9 EFTA01183009 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 11 of 45 d. the case number associated with any such Communication; e. the subject matter of any such Communication; f. the disposition of any case associated with any such Communication, irrespective of whether the matter was sealed, expunged or later dismissed. Response to Interrogatory No. 4 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre objects to this interrogatory in that it seeks protected information regarding confidential investigations. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. Ms. Giuffre objects to the extent this seeks information regarding sexual assaults that occurred prior to her involvement with the Defendant and Jeffrey Epstein. Ms. Giuffre responds as follows: Ms. Giuffre met with the FBI on or about March 17, 2011. Ms. Giuffre also corresponded with Maria Villafano from the U.S. Attorney's office and that correspondence has been produced. As to other investigations by law enforcement, Ms. Giuffre objects as this seeks information covered by the public interest privilege. 5. Identify each Communication that You or Your Attorneys have had with any author, reporter, correspondent, columnist, writer, commentator, investigative journalist, photojournalist, newspaper person, freelance reporter, stringer, or any other employee of any media organization or independent consultant to the same, including: a. the date of any such Communication; b. the form of any such Communication, whether oral or written and if written, the format of any such Communication; 10 EFTA01183010 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 12 of 45 c. the identities of all persons involved in such Communication, including the identity of the media organization with whom the agent is or was affiliated; d. the article title, date of publication, and means of publication of any article, report, or re-printing of any such Communication made by You or Your Attorneys; e. the amount of Income that You and/or Your Attorneys received in exchange for any such Communication; f. the dates on which You and/or Your Attorneys received any such Income for any such Communication. Response to Interroeatory No. 5 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. Ms. Giuffre objects in that this request is overly broad and unduly burdensome. 6. Identify any "false statements" attributed to Ghislaine Maxwell which were "published globally, including within the Southern District of New York" as You contend in paragraph 9 of Count 1 of Your Complaint, including: a. the exact false statement; b. the date of its publication; c. the publishing entity and title of any publication containing the purportedly false statement; 11 EFTA01183011 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 13 of 45 d. the URL or Internet address for any internet version of such publication; and e. the nature of the publication, whether in print, internet, broadcast or some other form of media. Response to Interrogatory No. 6 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. Ms. Giuffre further objects because the information requested above is in the possession of Defendant who has failed to comply with her production obligations in this matter. 7. State whether You believe that You have ever been defamed by anyone other than Ghislaine Maxwell. If so, as to each alleged act of Defamation, state a. the exact false statement; b. the date of its publication; c. the publishing entity and title of any publication containing the purportedly false statement; d. the URL or Internet address for any internet version of such publication; and e. the nature of the publication, whether in print, internet, broadcast or some other form of media. Response to Interrogatory No. 7 Ms. Giuffre objects to this request in that it violates Local Rule 33.3. Ms. Giuffre objects to this request in that it seeks information protected by the attorney client and work product 12 EFTA01183012 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 14 of 45 privileges. Ms. Giuffre objects to this interrogatory in that it is not limited in time or to the subject nature of this litigation. 8. Identify the individuals referenced in Your pleadings filed in the U.S. District Court for the Southern District of Florida, Jane Doe 1 and Jane Doe 2 v. United States of America, 08-cv-80736-ICAM, as the "high-profile non-party individuals" to whom Mr. Jeffrey Epstein sexually trafficked You, "including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders," including as to each episode of alleged sexual trafficking: a. the date of any such sexual trafficking; b. the location of any such sexual trafficking; c. any witnesses to any such sexual trafficking; d. any Income You received in exchange for such sexual trafficking; and e. any Documents You have to support or corroborate Your claim of such sexual trafficking. Response to Interrogatory No. 8 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. Additionally, Ms. Giuffre objects to this interrogatory because naming some such individuals would jeopardize her physical safety based on credible threats to the same. Ms. Giuffre refers to the list of witnesses identified in her Revised Rule 26 Disclosures. 9. Identify any Employment You have had from 1996 until the present, including 13 EFTA01183013 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 15 of 45 without limitation, the name of Your employer or the name of any Person who engaged You for such Employment, the address and telephone number for any such Employment, the beginning and ending dates of any such Employment, Your job title in such Employment, and Your Income from such Employment. Response to Interrogatory No. 9 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. Ms. Giuffre objects to this request in that it is overly broad and unduly burdensome, and seeks information that is not relevant to this case. 10. Identify any Income from any source other than Your Employment that You have received from January I, 1996 until the present, including the Person or entity providing such Income, the amount of the Income, the dates on which any such Income was received, and the nature of the Income, whether a loan, investment proceeds, legal settlement, asset sale, gift, or other source. Response to Interrogatory No. 10 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre objects to this request in that it is overly broad and seeks confidential financial information. Ms. Giuffre objects to this interrogatory in that it seeks information covered by confidentiality provisions. Ms. Giuffre objects to this information in that any payment information for the sexual trafficking she endured at the hands of Jeffrey Epstein and Ghislaine Maxwell is in the possession, custody and control of the Defendant and Jeffrey Epstein. 14 EFTA01183014 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 16 of 45 Ms. Giuffre is in possession of a responsive document that contains a confidentiality provision. If Defendant obtains, and produces to Ms. Giuffre, a written waiver from her co- conspirator, Mr. Epstein, of the confidentiality provision, freeing Ms. Giuffre from any liability whatsoever under the confidentiality provision, she will produce the document. 11. Identify any facts upon which You base Your contention that You have suffered as a result of the Alleged Defamation by Ghislaine Maxwell "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." Response to Interrogatory No. 11 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre objects to this interrogatory in that it prematurely seeks expert witness disclosures. Ms. Giuffre incorporates by reference herein her Revised Rule 26 disclosures, which includes her computation of damages. 12. Identify any Health Care Provider from whom You received any treatment for any physical, mental or emotional condition, that You suffered from subsequent to any Alleged Defamation by Ghislaine Maxwell, including: a. the Health Care Provider's name, address, and telephone number; b. the type of consultation, examination, or treatment provided; c. the dates You received consultation, examination, or treatment; d. whether such treatment was on an in-patient or out-patient basis; e. the medical expenses to date; f. whether health insurance or some other person or organization or entity has paid for the medical expenses; and 15 EFTA01183015 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 17 of 45 g. for each such Health Care Provider, please execute the medical and mental health records release attached hereto as Exhibit A. Response to Interrogatory No. 12 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre objects to this request in that it is overbroad and seeks confidential medical information of a sex abuse victim and is not limited in scope to the issues in this case Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. 13. Identify any Health Care Provider from whom You received any treatment for any physical, mental or emotional condition, including addiction to alcohol, prescription or illegal drugs, that You suffered from prior to the Alleged Defamation by Ghislaine Maxwell, including: a. the Health Care Provider's name, address, and telephone number; b. the type of consultation, examination, or treatment provided; c. the dates You received consultation, examination, or treatment; d. whether such treatment was on an in-patient or out-patient basis; e. the medical expenses to date; f. whether health insurance or some other person or organization or entity has paid for the medical expenses; and g. For each such Health Care Provider, please execute the medical and mental health records release attached hereto as Exhibit A. Response to Interrogatory No. 13 16 EFTA01183016 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 18 of 45 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre objects to this request in that it is overbroad and seeks confidential medical information of a sex abuse victim and is not limited in scope to the issues in this case. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, and any other applicable privilege. Ms. Giuffre objects to this request in that it is not limited in scope to the medical information relating to the abuse she suffered from Defendant and Jeffrey Epstein. 14. Identify any Person who You believe subjected You to, or with whom You engaged in, any illegal or inappropriate sexual contact, conduct or assault prior to June 1999, including the names of the individuals involved, the dates of any such illegal or inappropriate sexual contact, conduct or assault, whether Income was received by You or anyone else concerning such event, whether a police report was ever filed concerning such event and the outcome of any such case, as well as the address and location of any such event. Response to Interrogatory No. 14 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre objects to this request in that it is overbroad and seeks confidential medical information of a sex abuse victim. Ms. Giuffre objects to this request in that it seeks sexual assault information for a period prior to the sexual abuse at issue in this matter for a period when she was a minor child from the time Ms. Giuffre was born until she was 15. Ms. Giuffre objects to this request in that it is sought solely to harass, and intimidate Ms. Giuffre who is a victim of sexual abuse by the defendant. 17 EFTA01183017 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 19 of 45 REOUESTS FOR PRODUCTION 1. All Communications and Documents identified in Interrogatories 1-14, above. Response to Request No. 1 Ms. Giuffre objects to this request in that Defendant's interrogatories violate Local Rule 33.3. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. Ms. Giuffre objects to this request on the grounds that it is overly broad and unduly burdensome, incorporating the interrogatories that total 59 subparts, and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Giuffre objects to this request in that it seeks to invade the privacy rights of a sex abuse victims, and is meant for the improper purpose of harassing and intimidating this victim. Subject to and without waving the above objections, Ms. Giuffre is withholding production of documents that are privileged pursuant to the attorney-client privilege, the work product privilege, and the public interest privilege. Ms. Giuffre is also withholding electronic renditions of photographs that depict the faces of her minor children, including school portraits and other photographs taken that reveal the faces of her minor children. Subjection to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE00000I to GIUFFRE003190, and will produce non-privileged documents responsive to this Request limited to documents that do not depict images of her minor children as described supra and will continue to supplement her production. 18 EFTA01183018 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 20 of 45 2. All Documents reviewed or relied upon in answering Interrogatory Nos. 1-14 above. Response to Request No. 2 Ms. Giuffre objects to this request in that defendant's interrogatories violate Local Rule 33.3. Ms. Giuffre objects to this request in that it seeks information that is protected by the attorney client, work product, and public interest, and other applicable privileges. Ms. Giuffre objects to this request in that it is overly broad incorporating the interrogatories that total 59 subparts. Ms. Giuffre objects to this request in that it seeks to invade the privacy rights of a sex abuse victims and is meant for the improper purpose of harassing and intimidating this victim. Subject to and without waving the above objections, Ms. Giuffre is withholding production of documents that are privileged pursuant to the attorney-client privilege, the work product privilege, and the public interest privilege. Ms. Giuffre is also withholding electronic renditions of photographs that depict the faces of her minor children, including school portraits and other photographs taken that reveal the faces of her minor children. Subjection to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non-privileged documents responsive to this Request limited to documents that do not depict images of her minor children as described supra and will continue to supplement her production. 3. All Documents from any law enforcement agency, whether local, state or federal, whether in the United States or elsewhere, which concern or relate to You in any way. These Documents should include, without limitation, any witness statements, including statements made by You. Response to Request No. 3 19 EFTA01183019 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 21 of 45 Ms. Giuffre objects to this request in that it seeks information that is protected by the attorney client, work product, public interest privilege and other applicable privileges. Ms. Giuffre objects to this request in that it is not limited in time period. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non-privileged documents responsive to this Request and will continue to supplement her production. Ms. Giuffre is withholding documents that concern or relate to any currently ongoing investigation by any law enforcement agency under the public interest privilege and other applicable privileges. 4. All Documents reflecting any letter of engagement, any fee agreement, or any other type of writing reflecting an engagement of any attorney identified in response to Interrogatory No. 3. Response to Request No. 4 Ms. Giuffre objects to this request in that it seeks information that is protected by the attorney client, work product, joint defense and other applicable privileges. Ms. Giuffre is withholding documents based on this objection. Specifically, Ms. Giuffre is withholding documents reflecting the engagements between herself and her attorneys she has engaged in relation to the above-captioned action and other actions as those documents involve privileged communications. 5. All Documents relating to any Communications occurring from 1998 to the present with any of the following individuals or with their attorneys, agents or representatives: a. Jeffrey Epstein; 20 EFTA01183020 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 22 of 45 b. Ghislaine Maxwell c. Any witness disclosed in Plaintiff's Rule 26(a) disclosures; d. Any witness identified by You in response to Interrogatory No. 8 and No. 14; e. Sky Roberts; f. Lynn Roberts; g. Kimberley Roberts; h. Daniel LNU, half-brother of Plaintiff; i. Carol Roberts Kess; j. Philip Guderyon; k. Anthony Valladares; I. Anthony Figueroa; m. Ron Eppinger Response to Request No. 5 Ms. Giuffre objection to this request on the grounds that it is overly broad and unduly burdensome, particularly as it seeks documents relating to over 60 individuals, and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Giuffre objects because compliance with this request is unduly burdensome. Ms. Giuffre objects to this request in that documents responsive to this request are within the possession, custody and control of the defendant and Jeffrey Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms. Giuffre's request seeking communications between the Defendant and Ms. Giuffre and between Jeffrey Epstein and Ms. Giuffre. Ms. Giuffre objects to this request to the 21 EFTA01183021 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 23 of 45 extent is seeks documents protected by the attorney client, work product, joint defense, public interest or any other applicable privilege. Ms. Giuffre objects to this request in that it is sought solely to harass and intimidate Ms. Giuffre, and invade her privacy, by seeking her private communications with her various family members, including aunts, uncles and parents and siblings. Subject to and without waving the above objections, Ms. Giuffre is withholding production of documents that are privileged pursuant to the attorney-client privilege, the work product privilege, and the public interest privilege. Ms. Giuffre is also withholding electronic renditions of photographs that depict the faces of her minor children, including school portraits and other photographs taken that reveal the faces of her minor children. Subjection to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non-privileged documents responsive to this Request limited to documents that do not depict images of her minor children as described supra and will continue to supplement this production. 6. All photographs or video containing any image of You and the following indk iduals. To the extent You have such photographs and video in their original, native format, please produce them in that format (not a paper copy). a. Ghislaine Maxwell b. Alan Dershowitz c. Jeffrey Epstein d. Andrew Albert Christian Edward, the Duke of York (aka Prince Andrew) e. Ron Eppinger 22 EFTA01183022 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 24 of 45 f. Bill Clinton g. Stephen Hawking h. Al Gore i. Any of the individuals identified by You in response to Interrogatory No. 8 and \o. 14. Response to Request No. 6 Ms. Giuffre objects to this request in that documents responsive to this request are within the possession, custody and control of the defendant and Jeffrey Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms. Giuffre's request seeking communications between the Defendant and Ms. Giuffre and between Jeffrey Epstein and Ms. Giuffre. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non-privileged documents responsive to this Request and will continue to supplement her production. Ms. Giuffre does not have "original, native format," as requested so she is producing the paper copies she has in her possession, custody and control. 7. All photographs and v ideo of You in any of Jeffrey Epstein's properties, including, but not limited to: his home in Palm Beach, Florida; his home in New York City, New York; his ranch in Santa Fe, New Mexico; and Little Saint James Island in the U.S. Virgin Islands. To the extent You have such photographs and video in their original, native format, please produce them in that format (not a paper copy). Response to Request No. 7 23 EFTA01183023 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 25 of 45 Ms. Giuffre objects to this request in that documents responsive to this request are within the possession, custody and control of the defendant and Jeffrey Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms. Giuffre's request seeking communications between the Defendant and Ms. Giuffre and between Jeffrey Epstein and Ms. Giuffre. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GRJFFRE003190, and will produce documents responsive to this Request and will continue to supplement her production. Ms. Giuffre does not have "original, native format," as requested so she is producing the paper copies she has in her possession, custody and control. The Defendant has documents responsive to this request that she should produce. 8. All photographs or video of You in any of Ms. Maxwell's properties, including her home in London, England and her home in New York City, New York. To the extent You have such photographs or video in their original, native format, please produce them in that format (not a paper copy). Response to Request No. 8 Ms. Giuffre objects to this request in that documents responsive to this request are within the possession, custody and control of the defendant and Jeffrey Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms. Giuffre's request seeking communications between the Defendant and Ms. Giuffre and between Jeffrey Epstein and Ms. Giuffre. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce 24 EFTA01183024 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 26 of 45 non-privileged documents responsive to this Request and will continue to supplement her production. Ms. Giuffre does not have "original, native format," as requested so she is producing the paper copies she has in her possession, custody and control. The Defendant has documents responsive to this request that she should produce. 9. Any Documents reflecting rental agreements or purchase agreements for the residential addresses identified by You in response to Interrogatory No. 1. Response to Request No. 9 Ms. Giuffre objections to this Request on the grounds that it is overly broad and unduly burdensome and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Giuffre objects to this request in that it seeks confidential financial information that is irrelevant to this action. Ms. Giuffre objects to this request to the extent is seeks documents protected by the attorney client, work product, joint defense, public interest or any other applicable privilege. Ms. Giuffre objects to this request in that the information regarding rental agreements for the apartments that Defendant and Jeffrey Epstein rented for her are in the Defendant's possession, control and custody. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non- privileged documents responsive to this Request, and will continue to supplement this production. 10. All Documents relating to Your Employment and/or association with the Mar-a-Lago Club located in Palm Beach, Florida, including any application for Employment. 25 EFTA01183025 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 27 of 45 Response to Request No. 10 Ms. Giuffre objects to this request to the extent is seeks documents protected by the attorney client, work product, joint defense, public interest or any other applicable privilege. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non- privileged documents responsive to this Request, and will continue to supplement this production. 11. Any Document reflecting any confidentiality agreement by and between, or concerning, You and the Mar-a-Lago Club. Response to Request No. 10 Ms. Giuffre objects to this request to the extent is seeks documents protected by the attorney client, work product, joint defense, public interest or any other applicable privilege. Ms. Giuffre has been unable to locate any such documents. 12. All Documents concerning any Employment by You from 1998 to the present or identified by You in response to Interrogatory No. 9, including any records of Your Employment at the Roadhouse Grill in Palm Beach, Florida. Response to Request No. 12 Ms. Giuffre objections to this Request on the grounds that it is overly broad and unduly burdensome and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Giuffre objects to this request to the extent is seeks documents protected by the attorney client, work product, joint defense, public interest or any other applicable privilege. 26 EFTA01183026 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 28 of 45 Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non- privileged documents responsive to this Request, and will continue to supplement this production. 13. All Documents concerning allegations of theft by You from the Roadhouse Grill in Palm Beach, Florida from 1999 — 2002. Response to Request No. 13 Ms. Giuffre objects to this request in that it seeks information solely to harass, embarrass, and intimidate Ms. Giuffre. Ms. Giuffre objects to this request to the extent is seeks documents protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, public interest privilege, and any other applicable privilege. Ms. Giuffre objects to this request in that it wrongfully characterizes a "theft by You". Ms. Giuffre objects to this request as it seeks documents of sealed juvenile records, and the only means of obtaining such records are either through court order or illegal means. Ms. Giuffre has been unable to locate any such documents. 14. A copy of Your federal, state or local tax returns for the years 1998 to the present, whether from the United States or any other country. Response to Request No. 14 Ms. Giuffre objections to this Request on the grounds that it is overly broad and unduly burdensome and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Giuffre objects to this request in that it seeks confidential financial information that is irrelevant to this action. Ms. Giuffre objects to this request in that it seeks financial information from her when she was a 27 EFTA01183027 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 29 of 45 minor child starting at age 14. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the accountant client privilege, and any other applicable privilege. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non- privileged documents responsive to this Request, and will continue to supplement this production. 15. All Documents concerning Your attendance at or enrollment in any school or educational program of whatever type, from 1998 to the present. Response to Request No. 15 Ms. Giuffre objections to this Request on the grounds that it is overly broad and unduly burdensome and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Giuffre objects to this request to the extent is seeks documents protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. Ms. Giuffre objects to this request in that her school records from when she was a minor child are an invasion of privacy, and sought only to harass and embarrass her. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non- privileged documents responsive to this Request, and will continue to supplement this production. 28 EFTA01183028 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 30 of 45 16. Any diary, journal or calendar concerning Your activities between 1996 — 2002. Response to Request No. 16 Ms. Giuffre objections to this Request on the grounds that the time period is overly broad and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Giuffre objects to this request to the extent it seeks proprietary and copyright protected materials. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, and any other applicable privilege. Ms. Giuffre objects to this request in that it seeks highly personal and sensitive material from a time when she was being sexually trafficked. Ms. Giuffre has been unable to locate any such documents. 17. All Documents relating to Your travel from the period of 1998 to the present, including, but not limited to a copy of Your passport that was valid for any part of that time period, any visa issued to You for travel, any visa application that You prepared or which was prepared on Your behalf, and travel itinerary, receipt, log, or Document (including any photograph) substantiating Your travel during that time period. Response to Request No. 17 Ms. Giuffre objections to this Request on the grounds that it is overly broad and unduly burdensome and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product 29 EFTA01183029 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 31 of 45 privilege, joint defense/common interest privilege, and any other applicable privilege. Ms. Giuffre objects to this request in that it is overly broad and not limited to travel records relevant to the abuse she suffered. Ms. Giuffre objects to this request in that it seeks information that is wholly irrelevant to this lawsuit. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non- privileged documents responsive to this Request, and will continue to supplement this production. Per the agreements made in the March 21, 2016 meet and confer, we will attempt to locate and make copies of Plaintiff's current passport book. 18. All Documents showing any payments or remuneration of any kind made by Jeffrey Epstein or any of his agents or associates to You from 1999 until the present. Response to Request No. 18 Ms. Giuffre objects to this request in that documents responsive to this request are within the possession, custody and control of the defendant and Jeffrey Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. At this point in time, Ms. Giuffre has been unable to locate any such documents, but continues to search for responsive documents. 30 EFTA01183030 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 32 of 45 19. Any Document reflecting a confidentiality agreement, settlement agreement, or any contractual agreement of any kind, between You and Jeffrey Epstein, or any attorneys for You and/or Mr. Epstein. Response to Request No. 19 Ms. Giuffre objects to this request in that the documents responsive to this request are within the possession, custody and control of the defendant and Jeffrey Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. Ms. Giuffre is in possession of a responsive document that contains a confidentiality provision. As discussed during the March 21, 2016 meet and confer, If Defendant obtains, and produces to Ms. Giuffre, a written waiver from her co-conspirator, Mr. Epstein, of the confidentiality provision, releasing Ms. Giuffre from any liability whatsoever under the confidentiality provision, she will produce the document. 20. Any Document reflecting Your intent, plan or consideration of, asserting or threatening a claim or filing a lawsuit against another Person, any Document reflecting such a claim or lawsuit, including any complaint or draft complaint, or any demand for consideration with respect to any such claim or lawsuit against any Person. Response to Request No. 20 Ms. Giuffre objections to this Request on the grounds that it is overly broad and unduly burdensome and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. 31 EFTA01183031 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 33 of 45 Giuffre objects to this request to the extent is seeks documents protected by the attorney client, work product, joint defense or any other applicable privilege. Ms. Giuffre objects because this request is overly broad and unduly burdensome in that it seeks wholly privileged communications from other cases the logging of which on a privilege log would be unduly burdensome. As such, Ms. Giuffre is providing categorical privilege entries relating to those matters. At this point in time, Ms. Giuffre has not found any non-privileged documents responsive to this request, but continues to search for responsive documents. 21. All Documents relating to Your driver's license from 1998 — 2002. Response to Request No. 21 Ms. Giuffre objections to this Request on the grounds that it is overly broad and unduly burdensome and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Giuffre objects to this request in that documents responsive to this request are within the possession, custody and control of the defendant and Jeffrey Epstein for whom she claims a joint defense privilege and defendant has refused to produce responsive documents. At this point in time, Ms. Giuffre has not found any documents responsive to this request, but continues to search for responsive documents. 22. A copy of Your marriage license(s) from 1999 to the present. Response to Request No. 22 Ms. Giuffre objections to this Request on the grounds that it is irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Giuffre 32 EFTA01183032 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 34 of 45 objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, and any other applicable privilege. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non- privileged documents responsive to this request, and will continue to supplement this production. 23. All documents concerning Your naturalintion application to Australia from 1999 to the present. Response to Request No. 23 Ms. Giuffre objections to this Request on the grounds that it is irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, and any other applicable privilege. Ms. Giuffre has been unable to locate any such documents. 24. All Documents concerning Your Employment in Australia, including, but not limited to employment applications, pay stubs, Documents reflecting Your Income including any tax Documents. Response to Request No. 24 Ms. Giuffre objections to this Request on the grounds that it is overly broad and unduly burdensome and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Giuffre objects to this request in that it seeks confidential financial information Ms. Giuffre objects to this request to the extent is seeks documents protected by the attorney client, work product, joint defense, or 33 EFTA01183033 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 35 of 45 any other applicable privilege. Ms. Giuffre objects to this request in that it seeks overly broad financial information not tailored to the sexual abuse and defamation issues in this case. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non- privileged documents responsive to this request, and will continue to supplement this production. 25. All Documents concerning any massage therapist license obtained by You, including any massage therapy license issued in the United States, Thailand and/or Australia. Response to Request No. 25 Ms. Giuffre objects to this request in that documents responsive to this request are within the possession, custody and control of the defendant and Jeffrey Epstein for whom she claims a joint defense privilege and defendant has refused to produce responsive documents. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, and any other applicable privilege. At this point in time, Ms. Giuffre has not found any non-privileged documents responsive to this request, but continues to search for responsive documents. 26. All Documents concerning any prescription drugs taken by You, including the prescribing doctor, the dates of said prescription, and the dates of any fulfillment of any such prescription. Response to Request No. 26 Ms. Giuffre objections to this Request on the grounds that it is overly broad and unduly burdensome and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. 34 EFTA01183034 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 36 of 45 Giuffre objects to this request in that it is not limited in date range in any way; therefore if she was on a prescription drug when she was 2 years old, she would have to produce that document. Ms. Giuffre also objects to this request in that it is not limited to prescription drugs she has taken as a result of the abuse she endured. Ms. Giuffre objects to this request to the extent it seeks confidential medical records that are not relevant to this action. Ms. Giuffre objects to this request to the extent is seeks documents protected by the attorney client, work product, or any other applicable privilege. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and is producing non-privileged documents responsive to the Request limited to documents relating to prescription drugs relating to her treatment for sexual abuse she suffered at the hands of the Defendant and Jeffrey Epstein, and relating to conditions or symptoms arising after Defendant's defamatory statement, and will continue to supplement this production. 27. All Documents, written or recorded, which reference by name, or other description, Ghislaine Maxwell. Response to Request No. 27 Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. Ms. Giuffre objects to this request to the extent it seeks proprietary or copyright protected materials. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non- 35 EFTA01183035 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 37 of 45 privileged documents responsive to this Request, and will continue to supplement her production. 28. All Documents reflecting notes of, or notes prepared for, any statements or interviews in which You referenced by name or other description, Chislaine Maxwell. Response to Request No. 28 Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. Ms. Giuffre objects to this request to the extent it seeks proprietary or copyright protected materials. At this point in time, Ms. Giuffre has not found any non-privileged documents responsive to this request, but continues to search for responsive documents. 29. All Documents concerning any Communications by You or on Your behalf with any media outlet, including but not limited to the Daily Mail, Daily Express, the Mirror, National Enquirer, New York Daily News, Radar Online, and the New York Post, whether or not such communications were "on the record" or "off the record." Response to Request No. 29 Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, and any other applicable privilege. Ms. Giuffre objects to this request to the extent it seeks proprietary or copyright protected materials. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will 36 EFTA01183036 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 38 of 45 produce non-privileged documents responsive to this Request, and will continue to supplement her production. 30. All Documents concerning any Income received by You from any media outlet in exchange for Your statements (whether "on the record" or "off the record") regarding Jeffery Epstein. Alan M. Dershowitz, Prince Andrew, Bill Clinton or Ghislaine Maxwell or any of the individuals identified by You in response to Interrogatory Nos. 8 and 14. Response to Request No. 30 Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, and any other applicable privilege. Ms. Giuffre objects to this request to the extent it seeks proprietary or copyright protected materials. Ms. Giuffre objects to this request in that it seeks confidential financial information. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non-privileged documents responsive to this Request, and will continue to supplement her production. 31. All Documents concerning any actual or potential book, television or movie deals concerning Your allegations about being a sex slave, including but not limited to a potential book by former New York Police Department detective John Connolly and writer James Patterson. Response to Request No. 31 37 EFTA01183037 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 39 of 45 Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, and any other applicable privilege. Ms. Giuffre objects to this request to the extent it seeks proprietary or copyright protected materials. Ms. Giuffre objects to this request in that it seeks confidential financial information. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non-privileged documents responsive to this Request, and will continue to supplement her production. 32. All manuscripts and/or other writings, whether published or unpublished, created in whole or in part b, or in consultation with You, concerning, relating or referring to Jeffrey Epstein, C hislaine Maxwell or any of their agents or associates. Response to Request No. 32 Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, and any other applicable privilege. Ms. Giuffre objects to this request to the extent it seeks proprietary or copyright protected materials. Ms. Giuffre objects to this request in that it seeks confidential financial information. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non-privileged documents responsive to this Request, and will continue to supplement her production. 38 EFTA01183038 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 40 of 45 33. All Documents concerning or relating to Victims Refuse Silence, the organization referred to in the Complaint, including articles of incorporation, any financial records for the organization, any Income You have received from the organization, and any Documents reflecting Your role within the organization or any acts taken on behalf of the Organization. Response to Request No. 33 Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, and any other applicable privilege. Ms. Giuffre objects to this request to the extent it seeks proprietary or copyright protected materials. Ms. Giuffre objects to this request in that it seeks confidential financial information. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non- privileged documents responsive to this Request, and will continue to supplement her production. 34. To the extent not produced in response to the above list of requested Documents, all notes, writings, photographs, and/or audio or video recordings made or recorded by You or of You at any time that refer or relate in any way to Ghislaine Maxwell. Response to Request No. 34 Ms. Giuffre objects to this request in that documents responsive to this request are within the possession, custody and control of the defendant and Jeffrey Epstein for whom she claims a joint defense privilege and defendant has refused to produce responsive documents. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work 39 EFTA01183039 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 41 of 45 product privilege, and any other applicable privilege. Ms. Giuffre objects to this request to the extent is seeks proprietary and copyright protected material. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non- privileged documents responsive to this Request, and will continue to supplement her production. 35. All phone records, including text messages, emails, social media Communications, letters or any other form of Communication, from or to You or associated with You in any way from 1998 to the present, which concern, relate to, identify, mention or reflect Ghislaine Maxwell, Jeffrey Epstein, Alan Dershowitz, Prince Andrew, Bill Clinton, or any of the individuals identified in response to Interrogatory Nos. 8 and 14. Response to Request No. 35 Ms. Giuffre objections to this Request on the grounds that it is overly broad and unduly burdensome and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Giuffre objects to this request to the extent it seeks documents from "anyone associated with you" as that is vague and ambiguous. Ms. Giuffre objects to this request in that documents responsive to this request are within the possession, custody and control of the defendant and Jeffrey Epstein for whom she claims a joint defense privilege and defendant has refused to produce responsive documents. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, the public interest privilege, and any other applicable privilege. 40 EFTA01183040 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 42 of 45 Ms. Giuffre objects to this request to the extent is seeks proprietary and copyright protected material. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non- privileged documents responsive to this Request, and will continue to supplement her production. While Ms. Giuffre has produced her documents, Ms. Giuffre's response does not include documents "from anyone associated with you" based on the above referenced objection. 36. All Documents relating to massages, including but not limited to any Documents reflecting the recruiting or hiring of masseuses, advertising for masseuses, flyers created for distribution at high schools or colleges, and records reflecting e-mails or calls to Persons relating to massages. Response to Request No. 36 Ms. Giuffre objections to this Request on the grounds that it is overly broad and unduly burdensome and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Giuffre objects to this request in that it is not time limited in any way. Ms. Giuffre objects to this request in that documents responsive to this request are within the possession, custody and control of the defendant and Jeffrey Epstein for whom she claims a joint defense privilege and defendant has refused to produce responsive documents. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, public interest privilege, and any other applicable privilege. Ms. Giuffre has been unable to locate any such documents. 41 EFTA01183041 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 43 of 45 37. Statements or records from any bank into which You deposited money received from Jeffrey Epstein, any Person identified in Interrogatory No. 8 or 14, any witness disclosed in Your Rule 26(a) disclosures, any media organization or any employee or affiliate of any media organization. Response to Request No. 37 Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. Ms. Giuffre objects to this request in that it seeks personal financial information. Ms. Giuffre objects to this request in that it is overly broad as it has no time limitation. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non- privileged documents responsive to this Request, and will continue to supplement her production. Dated: March 22, 2016 Respectfully Submitted, BOLES, SCHILLER & FLEXNER LLP By: Is/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 42 EFTA01183042 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 44 of 45 Ellen Brockman Boles Schiller & Flexner LLP 575 Lexington Ave New York, New York 10022 (212) 446-2300 43 EFTA01183043 Case 1:15-cv-07433-RWS Document 76-1 Filed 03/31/16 Page 45 of 45 CERTIFICATE OF SERVICE I certify that on March 22, 2016, I electronically served Plaintiff [REDACTED]'s Amended Supplemental Responses and Objections to Defendant's First Set ofDiscovery Requests on the following: Laura A. Menninger, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmflaw.com Jeffrey S. Pagliuca„ Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: jpagliuca@hmflaw.com By: hi Sigrid McCawley Sigrid McCawley 44 EFTA01183044 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 1 of 21 EXHIBIT B EFTA01183045 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 2 of 21 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF, [REDACTED]'S REVISED DISCLOSURE PURSUANT TO FED. R. CIV. P. 26 COMES NOW the Plaintiff, Virginia L. Giuffre, by and through her undersigned counsel, and serves this revised disclosure pursuant to Fed. R. Civ. P. 26 and states as follows: A. Witnesses: I. Virginia L. Giuffre do Sigrid S. McCawley, Esq. Boies, Schiller & Flexner LLP 401 East Las Olas Boulevard, Suite 1200 Miami, Florida 33301 Tel: (954) 356-0011 Email: smccawley@bsfllp.com 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 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Email: Imenninger@hmflaw.com Defendant in this action. 1 EFTA01183046 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 3 of 21 3. Juan Alessi 6791 Fairway Lakes Drive, Boynton Beach, FL 33472 Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 4. Maria Alessi 6791 Fairway Lakes Drive, Boynton Beach, FL 33472 Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 5. Doug Band President of Teneo Holdings, 601 Lexington Avenue, 45'h Floor, New York, NY 10022, Tel: (212) 886-1600 Was present on flights with Jeffrey Epstein and Ghislaine Maxwell and President Clinton and may have knowledge of Jeffrey Epstein and Ghislaine Maxwell's sexual trafficking conduct and interactions with minors. 6. Gwendolyn Beck P.O. Box 705, Arlington, VA 22216 (703) 656-6007 May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 7. Sophie Biddle 388 W. Cannel Valley Road, Carmel Valley, CA 93924 Tel: (310) 394-7048 May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 8. [REDACTED] do Cris Armenta, Esq. 11900 Olympic Blvd., Suite 730, Los Angeles, CA 90064 Tel: (310) 826-2826 2 EFTA01183047 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 4 of 21 Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and Virginia Guiffre and may have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 9. Kelly Bovino 16694 Via La Costa, Pacific Palisades, CA 90272 Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 10. Jean Luc Brunel do Joe Titone, Esq. 621 South East 5th Street, Pompano Beach, FL 33060 Tel: (954) 729-6490 Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and Virginia Guiffre and has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. II. Ron Burkle Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 12. Dana Bums Address unknown at this time. Telephone number unknown at this time Worked for Ghislaine Maxwell and has information about Ghislaine Maxwell's recruiting of girls for Jeffrey Epstein. 13. Alyson Chambers do Marshall Dore Louis, Esq. Sinclair, Louis & Zavertnik, P.A. 40 N.W. 3rd Street, Suite 200, Miami, FL 33128 Tel: (305) 374-0544 Worked for Jeffrey Epstein as a masseuse during the time that [REDACTED] was living and traveling with Jeffrey Epstein and Ghislaine Maxwell, and has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 3 EFTA01183048 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 5 of 21 14. Maximilia Cordero Address unknown at this time Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 15. Valdson Cotrin Address unknown at this time Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 16. [REDACTED] 1017 N. Spaulding Avenue, #8, West Hollywood, CA 90056 Telephone number unknown at this time Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and may have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 17. [REDACTED] 1212 N. Clark Street, Apt. #7, West Hollywood, CA 90069 Telephone number unknown at this time Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and may have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 18. Anouska DeGeorgieou 536 N. Edinburgh Avenue, Los Angeles, CA 90048 Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 19. Alan Dershowitz c/o Richard A. Simpson, Esq. WILEY REIN, LLP 1776 K Street NW Washington, D.C. 20006 Tel: (202) 719-7000 4 EFTA01183049 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 6 of 21 Has 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 May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 21. Eva Anderson Dubin 1090 N. Lake Way, Palm Beach, FL 33480 1040 5'h Avenue, #15, New York, NY 10028 Telephone number unknown at this time Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 22. Glen Dubin 1090 N. Lake Way, Palm Beach, FL 33480 1040 5'h Avenue, #15, New York, NY 10028 Telephone number unknown at this time Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 23. Prince Andrew Albert Christian Edward, Duke of York Buckingham Palace Rd, London SW1A IAA Tel: 020 7766 7300 Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors, including [REDACTED]. 24. Jeffrey Epstein do Tonja Haddad Coleman, Esq. 315 SE t h Street, Suite 301 Fort Lauderdale, FL 33301 Tel: (954) 467-1223 and do Marty Weinberg, Esq. 20 Park Plaza, Suite 1000, Boston, MA 02116 Tel: (617) 227-3700 5 EFTA01183050 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 7 of 21 Has knowledge of Defendant's conduct that is the subject of this action and knowledge of his sexual trafficking operation and other co-conspirators. 25. Tatiana Espinoza Address unknown at this time Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 26. Frederic Fekkai Address unknown at this time Telephone number unknown at this time Has knowledge of Defendant's conduct that is the subject of this action. 27. Tony Figueroa 104 Houston School Ct, Red Oak, TX 75154 Telephone number unknown at this time Has knowledge of Defendant's conduct that is the subject of this action. 28. Luciano "Jojo" Fontanilla 18 Teneyck Avenue, Valley Stream, NY 11580-4016 917-9754500 Jeffrey Epstein's staff member in his various homes and may have knowledge of Defendant and Jeffrey Epstein's inappropriate conduct with underage girls. 29. Lynn Fontanilla 18 Teneyck Avenue, Valley Stream, NY 11580-4016 Telephone number unknown at this time May have knowledge of Defendant's conduct that is the subject of this action. 30. Michael Friedman 53320 Avenida Madero, La Quinta, CA 92253 Telephone number unknown at this time Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with minors. 6 EFTA01183051 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 8 of 21 31. Rosalie Friedman 53320 Avenida Madero, La Quinta, CA 92253 Telephone number unknown at this time Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with minors. 32. Tiffany Kathryn Gramza 3927 Downey Ct, Simi Valley, CA 93063-2836 Telephone number unknown at this time May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors 33. Eric Gany Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 34. Amanda Grant Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 35. Lesley Groff Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 36. Claire Hazel Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors 7 EFTA01183052 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 9 of 21 37. Shelly Harrison Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors 38. Stephen Kaufman Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors 39. Sarah Kensington Vickers formerly Sarah Kellen 50 S. Pointe Dr, Apt. 2304, Miami Beach, FL 33139 Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interactions with minors. 40. Tatiana Kovylina 1 Central Park South, #1306, New York, NY 10019-1732 Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors 41. Banu Kucukkoylu 4712 Admiralty Way, # 383, Marina Del Rey, CA 90292 Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors 42. Adam Perry Lang Address unknown at this time Telephone number unknown at this time Traveling chef for Jeffrey Epstein and Ghislaine Maxwell and may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 8 EFTA01183053 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 10 of 21 43. Shelly Ann Lewis Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors 44. Michael Liffman Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 45. Peter Listerman Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors 46. Cindy Lopez Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors 47. Melinda Lutz Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors 48. Cheri Lynch Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 9 EFTA01183054 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 11 of 21 49. Nadia Marcinko formerly Nadia Marcinkova 301 E. 66th Street, New York, NY 10065-6205 Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors 50. Todd Meister 101 Seminole Avenue, Palm Beach, FL 38480 Tel: (561) 650-0083 May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors 51. Brahakmana Mellawa Address unknown at this time Telephone number unknown at this time House staff who may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 52. Jayarukshi Mellawa Address unknown at this time Telephone number unknown at this time House staff who may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 53. George Mitchell Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 54. Bill Peadon 617 Piedmont Rd, West Palm Beach, FL 33405-1534 Telephone number unknown at this time House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 10 EFTA01183055 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 12 of 21 55. Francis Peadon 617 Piedmont Rd, West Palm Beach, FL 33405-1534 Telephone number unknown at this time House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 56. Tom Pritzker Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 57. Louella Rabuyo Address unknown at this time Telephone unknown at this time House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 58. Bill Richardson Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 59. Rinaldo Rizzo Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 60. [REDACTED] Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 11 EFTA01183056 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 13 of 21 61. David Rogers do Bruce E. Reinhart, Esq. Tel: (561) 202-6360 Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 62. Adriana Ross formerly Adriana Mucinska do Alan S. Ross, Esq. Tel: (305) 858-9550 Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 63. [REDACTED] do Marshall Dore Louis, Esq. 40 N.W. 3th Street, Suite 200, Miami, FL 33128 Tel: (305) 374-0544 Worked for Jeffrey Epstein during the time when [REDACTED] was living and traveling with Jeffrey Epstein and Ghislaine Maxwell. Johanna Sjobjerg was also present at an occasion with Prince Andrew, Ghislaine Maxwell, and [REDACTED] when Ms. Giuffre was a minor. 64. Kelly Spamm Address unknown at this time Telephone number unknown at this time May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 65. Emmy Taylor Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 66. Evelyn Valenzuela Address unknown at this time Telephone number unknown at this time 12 EFTA01183057 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 14 of 21 May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct. 67. Lany Visosky do Bruce E. Reinhart, Esq. Tel: (561) 202-6360 Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 68. Leslie Wexner do John W. Zeiger, Esq., Zeiger, Tigges & Little LLP 41 South High Street, Suite 3500, Columbus, Ohio 43215 Tel: (614) 365-9900 Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors.. 69. Igor Zinoview Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors. 70. All other then-minor girls, recruited by Ghislaine Maxwell, whose identities Ms. Giuffre will attempt to determine, with whom Defendant, Ghislaine Maxwell and Jeffrey Epstein, have engaged in sexual activity. 71. 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. 72. All staff and employees at the Mar-a-Lago Club during 1999-2002. 73. All other witnesses learned through discovery process. B. Exhibits- 1. Palm Beach Police Department report and documents contained within Jeffrey Epstein's criminal files, attached hereto as Exhibit 1. 13 EFTA01183058 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 15 of 21 2. March 10, 2011 Statement on behalf of Ghislaine Maxwell by Media agent Ross Gow, attached hereto as Exhibit 2. 3. September 3, 2008 Victim Notification Letter, attached hereto as Exhibit 3. 4. May I, 2009 Complaint in Jane Doe No. 102 v. Jeffrey Epstein, CIV-09-80656, in the Southern District of Florida, attached hereto as Exhibit 4. 5. FBI 302 Statement, attached hereto as Exhibit 5. 6. Flight Logs, attached hereto as Composite Exhibit 6. 7. Message Pads from Law Enforcement from trash pull of Jeffrey Epstein's Palm Beach home, attached hereto as Exhibit 7. 8. Jeffrey Epstein's Phone Book, also referred to as his "Black Book," attached hereto as Exhibit 8. 9. Deposition of Sarah Kellen, attached hereto as Composite Exhibit 9. 10. Deposition Transcripts of Juan Alessi, attached hereto as Exhibit 10. II. Deposition Transcripts of Alfredo Rodriguez, attached hereto as Exhibit 11. 12. January 2, 2015 Corrected Joinder Motion [DE 280] filed in the CVRA action pending in the Southern District of Florida, attached hereto as Exhibit 12. [All paragraphs between "The Government then concealed from Jane Doe No. 3 the existence of the NPA (pg. 3) and "The Government was well aware of Jane Doe No. 3 when it was negotiating the NPA" (pg. 6) were stricken by Judge Marra.] 13. January 21, 2015 Declaration of Jane Doe No. 3 filed in the CVRA action pending in the Southern District of Florida, attached hereto as Exhibit 13. [Paragraphs 4, 5, 7, 11, 13, 15, 19-53, and 59 were stricken by Judge Marra] 14. February 6, 2015 Declaration of Jane Doe No. 3 filed in the CVRA action pending in the Southern District of Florida, attached hereto as Exhibit 14. [Paragraphs 7- 12, 16, 39 and 49 were stricken by Judge Marra.] 15. November 25, 2015 Affidavit of [REDACTED], filed in the Bradley Edwards and Paul Cassell v. Alan Dershowitz matter, pending in the Seventeenth Judicial Circuit, Broward County, Florida, attached hereto as Exhibit 15. 16. [REDACTED]' passport, attached hereto as Exhibit 16. 17. Judge Thomas Lynch's January 12, 2016 Confidentiality Order regarding Virginia Giuffre's deposition, attached hereto as Exhibit 17. 18. Documents produced and bates labelled Non-Party VR 000001 — Non-Party VR 000644, in the Bradley Edwards and Paul Cassell v. Alan Dershowitz matter, 14 EFTA01183059 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 16 of 21 pending in the Seventeenth Judicial Circuit, Broward County, Florida, attached hereto as Exhibit 18. 19. Victims Refuse Silence Articles of Incorporation and Amendment, attached hereto as Composite Exhibit 19. 20. Victims Refuse Silence By-laws, attached hereto as Exhibit 20. 21. Victims Refuse Silence 2016 Annual Report, attached hereto as Exhibit 21. 22. 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 22. 23. 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 23. 24. 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 24. 25. February 1, 2015 Mirror article: "Prince Andrew's Pal Ghislaine Maxwell May Sue Over Madam Allegations," attached hereto as Exhibit 25. 26. September 23, 2007 Red Ice Creations Article "Prince Andrew's Friend, Ghislaine Maxwell, Some Underage Girls, and A Very Disturbing Story," attached hereto as Exhibit 26. 27. Photographs, attached hereto as Exhibit 27. 28. April 13, 2010 Deposition Transcript of Nadia Marcinkova, attached hereto as Exhibit 28. C. Computation of damages: Physical, psychological and psychiatric injuries and resulting medical expenses — in an amount of approximately $ 102,200 present value. a. Computation Analysis: i. Giuffre has had to receive treatment for the psychological harm as a result of Maxwell's conduct towards Giuffre. ii. The average annual expenditures for mental health services for adults 18-64 in the United States is $1,751. 15 EFTA01183060 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 17 of 21 iii. Giuffre needs continuing care as a result of the harm she has suffered. Ms. Giuffre was born August 9, 1983 and was 31.4 years old at the beginning of 2015 when the alleged harm occurred. The average remaining life expectancy for a 31 year old female is 51.1 years. iv. Based on a remaining life expectancy of 51.1 years, annual healthcare cost growth of 3.3% and a discount rate of 2.7%, the present value of expected treatment costs is $102,200 as of 1/1/2015. b. Supporting Evidence: i. Ms. Giuffre is in the process of collecting records from her physicians ii. Ms. Giuffre's testimony iii. Ms. Giuffre is in the process of retaining an expert to calculate damages, and will provide further information through expert disclosure. 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 not less than $30,000,000.00. 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 v. Filipino Reporter Enterprises Inc., 209 F.3d 163, 179 (2nd Cir. 2000) (Second Circuit holding that lip' a statement is defamatory per se, injury is assumed. In such a case `even where the plaintiff can show no actual damages at all, a plaintiff who has otherwise shown defamation may recover at least nominal damages' and the Second Circuit also confirmed an award of punitive damages). Ms. Giuffre has been severely damaged by the defamation of the defendant, by calling her claims of sexual abuse "obvious lies". The defamation caused Ms. Giuffre to re-live the sexual abuse she previously endured. Ms. Giuffre has suffered and continues to suffer from the pain, 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. The computation of this amount is in the province of the jury but Ms. Giuffre contends, including but not limited to, awards in other similar matters, that the 16 EFTA01183061 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 18 of 21 amount is not less than $30,000,000.00. Ms. Giuffre is in the process of retaining an expert, and will provide further information through expert disclosure. b. Supporting Evidence i. Ms. Giuffre's testimony ii. Witness testimony iii. Awards in similar matters iv. Ms. Giuffre is in the process of retaining an expert, and will provide further information through expert disclosure. 3. Estimated lost income of $180,000 annually. Present value of $3,461,000 to $5,407,000. a. Computation Analysis i. Ms. Giuffre's estimated compensation capacity is $180,000 annually. Ms. Giuffre was born August 9, 1983 and was 31.4 years old at the beginning of 2015 when the alleged injury occurred. Her expected remaining work life based on mortality and probability of continued work was 20.2 years. Based on these factors, a 2% annual growth rate and a 2.4% discount rate, the present value of lost compensation is $3,461,000 as of 1/1/2015. ii. Alternatively, if Ms. Giuffre is assumed to work until a normal retirement age of 65, or 33.6 years from her age at the beginning of 2015, and based on an annual growth rate of 2.0% and a discount rate of 2.7%, the present value of lost compensation is $5,407,000 as of 1/1/2015. b. Supporting Evidence i. Materials regarding compensation and work life expectancy I) 2010 Life Table for Females, National Vital Statistics Report, November 6, 2014, U.S. Department of Health & Human Services, Centers for Disease Control & Prevention, National Center for Health Statistics. 17 EFTA01183062 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 19 of 21 2) "Calculation of Work life Expectancy Using the Life, Participation, Employment Method," Vocational Econometrics, Inc. 3) Consumer Price Index for Urban Wage Earners and Clerical Workers, United States Department of Labor, Bureau of Labor Statistics. 4) Federal Reserve Statistical Release H.15, 11512015. ii. Ms. Giuffre's testimony iii. Ms. Giuffre is in the process of retaining a damages expert and will provide further information through expert disclosures. 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 to punish and deter conduct in view of the vast wealth of Defendant Maxwell, in an amount not less than $50,000,000.00. a. This calculation is in the province of the jury. 18 EFTA01183063 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 20 of 21 Dated March 11, 2016 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 (954) 356-0011 David Boles Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Ellen Brockman Boies Schiller & Flexner LLP 575 Lexington Ave New York, New York 10022 (212) 446-2300 19 EFTA01183064 Case 1:15-cv-07433-RWS Document 76-2 Filed 03/31/16 Page 21 of 21 CERTIFICATE OF SERVICE 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 March, 2016. Laura A. Menninger, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmflaw.com By: /s/ Sigrid McCawley Sigrid McCawley 20 EFTA01183065 Case 1:15-ov-07433-MS Document 76-3 Filed 03/31/16 Page 1 oft EXHIBIT C EFTA01183066 Case 1:15-cv-07433-RWS Document 76-3 Filed 03/31/16 Page 2 of 2 IN THE eiRcurr coma O1: THE 17."' JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION BRADLEY J. EDWARDS, and CASE NO. CACE 15-000072 PAUL G. CASSELL, Plaintiffs, v. ALAN DERSHOW1TZ, Defendant. 'PROPOSED] CONFIDENTIALITY ORDER THIS CAUSE COMES before the Court based on its Order dated November 12, 2015 granting, in part, Non-Party Jane Doe No. 3's Motion to Quash Subpoena or for a Protective Order. This Court ordered that "A Confidentiality Order Shall Be Entered." Accordingly, having reviewed the record and being otherwise duly advised, the Court issues the following Confidentiality Order: 1. The deposition testimony of Non-Party [REDACTED]. will be designated as "Confidential" and not subject to public disclosure. It may only be filed under seal. 2. Documents produced by Non-Party [REDACTED] that are confidential may be marked as "Confidential" and shall be treated in the same manner as confidential testimony. DONE AND ORDERED in Broward County, Florida on this \ 7-211137aJanuary, 2016. Honorable Judge Thomas Lynch Circuit Court Judge cc: Counsel of Record EFTA01183067