EFTA01079536.pdf

United States District Court Southern District Of New York X Plaintiff, v. Ghislaine Maxwell, Defendant. X DEFENDANT GHISLAINE MAXWELL'S INITIAL F.R.C.P. 26(a)(1)(A) DISCLOSURES Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following disclosures: I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH PARTICULARITY IN THE PLEADINGS I. Ghislaine Maxwell do Laura A. Menninger, Esq. Haddon, Morgan & Foreman, P.C. 150 E. 10ih Ave. i Denver mCO 80203 Ms. Maxwell is the Defendant and may have knowledge concerning matters at issue, including the events of 1999-2002 and the publication of statements in the press in 2011-2015. 2. do Sigrid S. McCawley, Esq. Boies, Schiller & Flexner LLP 401 East Las Olas Boulevard, Suite 1200 EFTA01079536  iami,m Florida a 33301 i is the Plaintiff and has knowledge concerning the matters at issue in er omp aint, including the events of 1996-2015 and the publication of statements in the press in 2011-2015. 3. Philip Barden Devonshires Solicitors LLP 30 Finsbury Circus London, United Kingdom EC2M 7DT DX: 33856 Finsbur Square Mr. Barden has knowledge concerning press statements by Plaintiff and Defendant in 2011-2015 at issue in this matter. 4. Paul Cassell College of Law, University of Utah 383 South University Street alt Lake it , UT 84112 Mr. Cassell has knowledge concerning press statements by Plaintiff, Plaintiff's court pleadings, and Plaintiff's sworn testimony. 5. Alan Dershowitz do Richard A. Simpson, Esq. WILEY REIN, LLP 1776 K Street NW Washin ton D.C. 20006 Mr. Dershowitz has knowledge concerning Plaintiff's false statements to the press, in court pleadings, and in sworn testimony, at issue in this matter. 6. Bradley Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Ft. Lauderdale FL 33301 2 EFTA01079537  Mr. Edwards has knowledge concerning Plaintiff's false statements to the press, in court pleadings, and in sworn testimony at issue in this matter. Mr. Edwards also has knowledge concerning "Victim's Refuse Silence, Inc." 7. Jeffrey Epstein do Tonja Haddad Coleman, Esq. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Mr. Epstein has knowledge concerning Plaintiff's false statements to the press and in court pleadings, as well as the events of 1999-2002 concerning Plaintiff and Defendant. 8. RPM• this time Telephone number unknown at this time anay have knowledge concerning matters at issue, including Plaintiff's activities during 1996 — 2002. 9. Louis Freeh Address unknown at this time Mr. Freeh may have knowledge concerning travel of Bill Clinton. 10. ss un nown at this time Telephone number unknown at this time is may have knowledge concerning matters at issue, including Plaintiff's activities during 2002-2016 and her damages allegations. II. Ross Gow Acuity Representation 23 Berkeley Square London W1J 6HE Mr. Gow may have knowledge concerning matters at issue, including the publication of statements in the press in 2011-2015 concerning Plaintiff and Defendant. 3 EFTA01079538 12. Philip Guderyon Address unknown at this time Telephone number unknown at this time Mr. Guderyon may have knowledge concerning matters at issue, including Plaintiff's activities during 1996 — 2002. 13. Carol Roberts Kess Address unknown at this time Telephone number unknown at this time Ms. Kess may have knowledge concerning matters at issue, including Plaintiff's activities during 1996 — 2002. 14. Lynn Miller Address unknown at this time Telephone number unknown at this time Ms. Miller may have knowledge concerning matters at issue, including Plaintiff's activities during 1996 — 2002. 15 ss tin nown at this time Telephone number unknown at this time Mr. Roberts may have knowledge concerning matters at issue, including Plaintiff's activities during 1996 — 2002. Address unknown at this time Telephone number unknown at this time may have knowledge concerning matters at issue, including aim' s activities during 1996 — 2002. 17. ress un known at t is time Telephone number unknown at this time may have knowledge concerning matters at issue, including Plaintiff's activities during 1996 — 2002. 18. Andrew Albert Christian Edwards, Duke of York Address unknown at this time Telephone number unknown at this time 4 EFTA01079539  The Duke has knowledge concerning Plaintiff's false statements to the press, in court pleadings, and in sworn testimony as well as the events of 1999-2002. 19. Any other witness learned through the discovery process. Defendant Ghislaine Maxwell reserves her right to supplement these disclosures as additional witnesses are learned through the discovery process. II. DOCUMENTS, DATA, COMPILATIONS AND TANGIBLE THINGS IN POSSESSION, CUSTODY OR CONTROL OF DEFENDANT THAT MAY BE USED TO SUPPORT DEFENDANT'S CLAIM OR DEFENSES' 1. News articles from the intemet: a. "Sordid friends and why he isn't fit for the job: Duke of York risks losing ambassador role," Daily Mail Online (Feb. 28, 2011). b. "Prince Andrew and the 17-year-old girl his sex offender friend flew to Britain to meet him," Daily Mail Online (corrected Mar. 2, 2011). c. "Unsavoury association: How Robert Maxwell's daughter 'procured young girls' for Prince Andrew's billionaire friend," Daily Mail Online (Mar. 5, 2011). d. e. "Court papers put daughter of Robert Maxwell at centre of 'sex slave' scandal," The Guardian (Jan. 4, 2015). f. "Prince Andrew denies sexual abuse allegations in unprecedented Buckingham Palace statement: The Duke of York denies having relations with alleged 'sex slave,'" The Independent (Jan. 4, 2015). g. "Prince Andrew story runs and runs - but editors should beware," The Guardian (Jan. 5, 2015). h. "US lawyer sues in Prince Andrew sex claims case," Time (Jan 6, 2015). All non-privileged listed documents are located at defense counsel's offices. Copies will be provided upon request. 5 EFTA01079540  i. "Harvard professor Alan Dershowitz denies charges of sex with underage girl," Boston Globe (Jan. 22, 2015). 2. Email from Ross Gow to various news organizations, Subject: "Ghislaine Maxwell," (Jan. 2, 2015). 3. Email correspondence between Philip Barden and Ghislaine Maxwell concerning the issuance of statements to the press (March 2011 — January 2015) (Attorney-Client privileged communications). 4. Documents received from any other party through disclosures and/or in discovery, including any deposition exhibits, will not be identified or produced, though they technically may fall within this category "II", and Defendant reserves the right to utilize such documents at any hearing or trial on this matter. Defendant reserves the right to identify additional documents, data, compilations and tangible things as discovery continues and to supplement this list accordingly. III. DESCRIPTION OF CATEGORIES OF DAMAGES SOUGHT AND COMPUTATION OF ECONOMIC DAMAGES CLAIMED BY THE DISCLOSING PARTY Not applicable at this time. Ms. Maxwell reserves her right to supplement these disclosures following the filing of any counterclaims she may have in this case. IV. INSURANCE AGREEMENT UNDER WHICH ANY PERSON CARRYING ON AN INSURANCE BUSINESS MAY BE LIABLE TO SATISFY A PART OR ALL OF A JUDGMENT None. 6 EFTA01079541  Dated: February 24, 2016. Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Phone: Attorneyfor Ghisiaine Maxwell CERTIFICATE OF SERVICE I certify that on February 24, 2016, I electronically served this DEFENDANT GHISLAINE MAXWELL'S INITIAL F.R.C.P. 26(A)(I) DISCLOSURES via e-mail on the following: Sigrid S. McCawley Bows, $CHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 s/ Laura A. Menninger Laura A. Menninger 7 EFTA01079542