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Epsteins List - by Asra Q. Nomani

Documents:

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 2

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