Documents:
Giuffre v. Maxwell (1:15-cv-07433)
District Court, S.D. New York
Last Updated: Jan. 3, 2024, 7:12 p.m.
Assigned To: Loretta A. Preska
Citation: Giuffre v. Maxwell, 1:15-cv-07433, (S.D.N.Y.)
Date Filed: Sept. 21, 2015
Date Terminated: May 25, 2017
Date of Last Known Filing: Jan. 3, 2024
Cause: 28:1332ct Diversity-(Citizenship)
Nature of Suit: 320 Assault Libel & Slander
Jury Demand: Both
Jurisdiction Type: Diversity
All 943 pages: https://s3.documentcloud.org/documents/24253240/1324-epstein-documents-943-pages.pdf
01/03/2024
1320
NOTICE of Documents Ordered Unsealed by Court Order of December 18, 2023 re: 1315 Order. Document filed by Virginia L. Giuffre.
Main Document – Notice (Other)
#1 Exhibit DE 122-4: Weird Maxwell email. Attachment 1
#2 Exhibit DE 143: PLAINTIFF'S MOTION TO COMPEL DEFENDANT TO ANSWER DEPOSITION QUESTIONS FILED UNDER SEAL.
#3 Exhibit DE 144-4: Videotaped deposition of Maxwell about how she gave “career advice” to young masseuses.
Named: Glenn Dubin
#4 Exhibit DE 144-6:
#5 Exhibit DE 150-1
# 6 Exhibit DE 152
# 7 Exhibit DE 153-7, # 8 Exhibit DE 160, # 2 Exhibit DE 165-3, # 10 Exhibit DE 172, # 11 Exhibit DE 173, # 12 Exhibit DE 173-5, # 13 Exhibit DE 173-8, # 14 Exhibit DE 180-1, # 15 Exhibit DE 180-2, # 16 Exhibit DE 180-3, # 17 Exhibit DE 180-6, # 18 Exhibit DE 184, # 12 Exhibit DE 185-11, # 20 Exhibit DE 189, #21 Exhibit DE 203, # 22 Exhibit DE 204, # 23 Exhibit DE 204-1, # 24 Exhibit DE 211, # 25 Exhibit DE 212, # 26 Exhibit DE 212-1, # 27 Exhibit DE 224, # 28 Exhibit DE 228, # 29 Exhibit DE 229-1, # 30 Exhibit DE 229-4, # 31 Exhibit DE 229-6, # 32 Exhibit DE 229-12, # 33 Exhibit DE 231, #34 Exhibit DE 232, # 35 Exhibit DE 232-7, # 36 Exhibit DE 235, # 37 Exhibit DE 235-3, # 38 Exhibit DE 235-4, # 39 Exhibit DE 235-10, # 40 Exhibit DE 235-13). (McCawley, Sigrid) (Entered: 01/03/2024)
Case 1:15-cv-07433-LAP Document 1320-40 Filed 01/03/24 Page 1 of 19
EXHIBIT N
Case 1:15-cv-07433-LAP Document 1320-40 Filed 01/03/24 Page 2 of 19
United States District Court
Southern District Of New York
--------------------------------------------------X
..........................................
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
DEFENDANT GHISLAINE MAXWELL’S
THIRD SUPPLEMENTAL F.R.C.P. 26(A)(1)(A) DISCLOSURES
Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE
INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
c/o Laura A. Menninger, Esq.
Haddon, Morgan & Foreman, P.C.
150 E. 10th Ave.
Denver, CO 80203
303-831-7364
LMenninger@HMFLaw.com
Ms. Maxwell is the Defendant and may have knowledge concerning matters at
issue, including the events of 1999-2002 and the publication of statements in the
press in 2011-2015.
2. Virginia Lee Roberts Giuffre
c/o Sigrid S. McCawley, Esq.
Boies, Schiller & Flexner LLP
401 East Las Olas Boulevard, Suite 1200
Case 1:15-cv-07433-LAP Document 1320-40 Filed 01/03/24 Page 3 of 19
Miami, Florida 33301
(954) 356-0011
smccawley@bsfllp.com
Ms. Giuffre is the Plaintiff and has knowledge concerning the matters at issue in
her Complaint, including the events of 1996-2015 and the publication of
statements in the press in 2011-2015.
3. Kathy Alexander
Address unknown at this time
Telephone number unknown at this time
Ms. Alexander has knowledge about matters at issue, including Plaintiff’s
whereabouts during 2000-2002 and her false claims concerning Defendant and
others.
4. Miles Alexander
Address unknown at this time
Telephone number unknown at this time
Mr. Alexander has knowledge about matters at issue, including Plaintiff’s
whereabouts during 2000-2002 and her false claims concerning Defendant and
others.
5. James Michael Austrich
10108 NW 261 Terrace
High Springs, Florida, 32643
Mr. Austrich has knowledge concerning matters at issue in the Complaint,
including events of 1996-2002.
6. Philip Barden
Devonshires Solicitors LLP
30 Finsbury Circus
London, United Kingdom
EC2M 7DT
DX: 33856 Finsbury Square
(020) 7628-7576
Philip.Barden@devonshires.co.uk
Mr. Barden has knowledge concerning press statements by Plaintiff and
Defendant in 2011-2015 at issue in this matter.
7. Jane Doe 2
2
Case 1:15-cv-07433-LAP Document 1320-40 Filed 01/03/24 Page 4 of 19
Jane Doe 2
8. David Boies
Boies, Schiller, Flexner LLP
575 Lexington Ave.
New York, NY 10022
(212) 446-2300
Mr. Boies has knowledge concerning matters at issue in the Complaint and in
Plaintiff’s pleadings and sworn statements in other litigations, including in
particular her publicly filed allegations concerning Defendant and Alan
Dershowitz.
9. Laura Boothe
The Mar-a-Lago Club, LC.
1100 South Ocean Boulevard,
Palm Beach, FL 33480
Ms. Boothe has knowledge concerning matters at issue, including the date that
Sky Roberts began working at the Mar-a-Lago Club, and the human resources
department at Mar-A-Lago.
10. Evelyn Boulet
Address unknown at this time
Telephone number unknown at this time
Ms. Boulet may have knowledge concerning Plaintiff’s false claims against
Defendant.
11. Rebecca Boylan
Address unknown at this time
Telephone number unknown at this time
Ms. Boylan has knowledge concerning Plaintiff during the relevant time period
including claims for damages, motive and bias.
12. Joshua Bunner
Address unknown at this time
Joshua Bunner has knowledge concerning Plaintiff’s credibility, including false
claims of sexual assault.
13. Carolyn Casey
Address unknown at this time
Telephone number unknown at this time
3
Case 1:15-cv-07433-LAP Document 1320-40 Filed 01/03/24 Page 5 of 19
Ms. Casey may have knowledge concerning Plaintiff’s false claims against
Defendant.
14. Paul Cassell
383 South University Street
Salt Lake City, UT 84112
801-585-5202
paul.cassell@law.utah.edu
Mr. Cassell has knowledge concerning press statements by Plaintiff, Plaintiff’s
court pleadings, and Plaintiff’s sworn testimony.
15. Sharon Churcher
3 Deveau Road
N. Salem, NY 10560
Ms. Churcher has knowledge concerning matters at issue, including Plaintiff’s
statements regarding Defendant and others.
16. Alexandra Cousteau
Address unknown at this time
Telephone number unknown at this time
Ms. Cousteau may have knowledge concerning Plaintiff’s false claims against
Defendant and others.
17. Alan Dershowitz
c/o Richard A. Simpson, Esq.
WILEY REIN, LLP
1776 K Street NW
Washington, D.C. 20006
(202) 719-7000
Mr. Dershowitz has knowledge concerning Plaintiff’s false statements to the
press, in court pleadings, and in sworn testimony, at issue in this matter.
18. Dr. Mona Devanesan
PO Box 3250
601 E. Delmonte Avenue
Clerwiston, FL 33440
(561) 254-2502
modev358@aol.com
Dr. Devanesan has knowledge about matters at issue, including Plaintiff’s
whereabouts during 2001 and her claimed damages.
4
Case 1:15-cv-07433-LAP Document 1320-40 Filed 01/03/24 Page 6 of 19
19. Jane Doe 2
Address unknown at this time
Telephone number unknown at this time
Jane
Jane Doe
Doe 2 2
20. Bradley Edwards
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.
425 N. Andrews Ave., Suite 2
Ft. Lauderdale, FL 33301
(954) 524-2820
brad@pathtojustice.com
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.”
21. Amanda Ellison
Address unknown at this time
561-628-4338
Ms. Ellison has knowledge concerning Plaintiff’s false allegations concerning
Defendant.
22. Cimberly Espinosa
1113 West Columbine Ave.
Santa Ana, CA 92707
Ms. Espinosa has knowledge concerning Plaintiff’s false allegations concerning
Defendant.
23. Jeffrey Epstein
c/o Tonja Haddad Coleman, Esq.
315 SE 7th Street, Suite 301
Fort Lauderdale, FL 33301
(954) 467-1223
Mr. Epstein has knowledge concerning Plaintiff’s false statements to the press and
in court pleadings, as well as the events of 1999-2002 concerning Plaintiff and
Defendant.
24. Annie Farmer
Address unknown at this time
Telephone number unknown at this time
5
Case 1:15-cv-07433-LAP Document 1320-40 Filed 01/03/24 Page 7 of 19
Ms. Farmer may have knowledge concerning Plaintiff’s false claims against
Defendant.
25. Marie Farmer
Address unknown at this time
Telephone number unknown at this time
Ms. Farmer may have knowledge concerning Plaintiff’s false claims against
Defendant.
26. Alexandra Fekkai
Address unknown at this time
Telephone number unknown at this time
Ms. Fekkai may have knowledge concerning Plaintiff’s false claims against
Defendant and others.
27. Crystal Figueroa
Address unknown at this time
Ms. Figueroa may have knowledge concerning matters at issue, including
Plaintiff’s activities during 1996 – 2002
28. Anthony Figueroa
38 Bunker View Drive
Palm Coast, FL
Mr. Figueroa has knowledge concerning matters at issue, including Plaintiff’s
activities during 1996 – 2002.
29. Louis Freeh
Address unknown at this time
(202) 215-8321
Freeh@FreehGroup.com
Mr. Freeh may have knowledge concerning travel of Bill Clinton.
30. Eric Gany
Address unknown at this time
Telephone number unknown at this time
Mr. Gany may have knowledge concerning Plaintiff whereabouts during 2000-
2002 and her false claims against Defendant.
31. Meg Garvin
Lewis & Clark Law School
6
Case 1:15-cv-07433-LAP Document 1320-40 Filed 01/03/24 Page 8 of 19
10015 S.W. Terwilliger Boulevard MSC 51
Portland, Oregon 97219
Ms. Garvin has knowledge concerning matters at issue including Victims Refuse
Silence and Plaintiff’s damages.
32. Sheridan Gibson-Butte
Address unknown at this time
Telephone number unknown at this time
Ms. Gibson-Butte may have knowledge concerning Plaintiff’s false claims
against Defendant.
33. Robert Giuffre
Queensland, Australia
Mr. Giuffre is may have knowledge concerning matters at issue, including
Plaintiff’s activities during 2002-2016 and her damages allegations.
34. Ross Gow
Acuity Representation
23 Berkeley Square
London W1J 6HE
44 (0) 777 875 5251
ross@acuityreputation.com
Mr. Gow may have knowledge concerning matters at issue, including the
publication of statements in the press in 2011-2015 concerning Plaintiff and
Defendant.
35. Fred Graff
Address unknown at this time
Telephone number unknown at this time
Mr. Graff may have knowledge concerning Plaintiff’s false claims against
Defendant.
36. 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.
37. Jane Doe 2
Jane Doe 2
7
Case 1:15-cv-07433-LAP Document 1320-40 Filed 01/03/24 Page 9 of 19
Jane Doe 2
-
Jane Doe 2
may have knowledge concerning matters at issue.
38. Shannon Harrison
Address unknown at this time
Telephone number unknown at this time
Ms. Harrison may have knowledge concerning Plaintiff’s false claims against
Defendant.
39. Victoria Hazel
Address unknown at this time
Telephone number unknown at this time
Ms. Hazel may have knowledge concerning Plaintiff’s false claims against
Defendant.
40. Brittany Henderson
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.
425 N. Andrews Ave., Suite 2
Ft. Lauderdale, FL 33301
Ms. Henderson has knowledge concerning matters at issue including Victims
Refuse Silence and Plaintiff’s damages.
41. Brett Jaffe
Address unknown at this time
Telephone number unknown at this time
Mr. Jaffe has knowledge concerning Plaintiff’s false claims concerning Ms.
Maxwell including her compliance with any deposition subpoena in the CVRA matter.
42. 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.
43. Dr. Karen Kutikoff
12957 Palms W Drive #101, FL 33470
Dr. Kutifkoff may have knowledge concerning matters at issue, including
Plaintiff’s whereabouts during 1998-2002 and Plaintiff’s damages.
44. Peter Listerman
Address unknown at this time
Telephone number unknown at this time
Mr. Listerman may have knowledge concerning Plaintiff’s false claims against
Defendant.
45. Tony Lyons
Skyhorse Publishing, Inc.
307 West 36th Street, 11th Floor
New York, NY 10018
Mr. Lyons may have knowledge concerning matters at issue, including Plaintiff’s
false allegations concerning Defendant and others.
46. Bob Meister
101 Seminole Avenue,
Palm Beach, FL 38480
(561) 650-0083
Mr. Meister may have knowledge concerning Plaintiff’s false claims against
Defendant.
47. Jamie A. Melanson
5280 NW 53rd Ave.
Coconut Creek, FL 33073
Mr. Melanson has knowledge concerning Plaintiff’s honesty and truthfulness.
48. Lynn Miller
936 O Street
Penrose, CO 81240
Ms. Miller may have knowledge concerning matters at issue, including Plaintiff’s
activities during 1996 – 2002.
49. Marvin Minsky
Address unknown at this time
Telephone number unknown at this time
9
Case 1:15-cv-07433-LAP Document 1320-40 Filed 01/03/24 Page 11 of 19
Mr. Minsky may have knowledge concerning Plaintiff’s false claims against
Defendant and others.
50. Jane Doe 2
Jane Doe 2Tom Pritzker
rabbis should condemn the massacres of the israeli military , just like we muslims had to
largely jewish. i heard halacha allows targeting of children in war. we do not need to take lessons from them