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EXHIBIT N
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United States District Court

Southern District Of New York

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..........................................
VIRGINIA L. GIUFFRE,

Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,

Defendant.

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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
[email protected]

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
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has knowledge concerning matters at issue in the Complaint,

including her own whereabouts and activities during the period 2000-2002.

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

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Mr. Schoettle may have knowledge concerning Plaintiff’s false claims against
Defendant.

63. Cecilia Stein

Address unknown at this time
Telephone number unknown at this time

Ms. Stein may have knowledge concerning Plaintiff’s false claims against
Defendant.

64. Mark Tafoya

Address unknown at this time
Telephone number unknown at this time

Mr. Tafoya may have knowledge concerning Plaintiff’s false claims against
Defendant.

65. Brent Tindall

Address unknown at this time
Telephone number unknown at this time

66. Kevin Thompson

Address unknown at this time

Kevin Thompson has knowledge concerning Plaintiff’s credibility, including false

claims of sexual assault.

67. Ed Tuttle
Address unknown at this time
Telephone number unknown at this time

Mr. Tuttle may have knowledge concerning Plaintiff’s false claims against
Defendant.

68. Emma Vaghan

Address unknown at this time
Telephone number unknown at this time

Ms. Vaghan may have knowledge concerning Plaintiff’s false claims against
Defendant.

69. Kimberly Vaughan-Edwards

Address unknown at this time
Telephone number unknown at this time
Believed to be in the UK

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Ms. Vaughan-Edwards has knowledge concerning facts relevant to this dispute

and Ms. Maxwell’s character.

70. Cresenda Valdes

Address unknown at this time
Telephone number unknown at this time

Ms. Valdes may have knowledge concerning Plaintiff’s false claims against
Defendant.

71. Anthony Valladares

Address unknown at this time
Telephone number unknown at this time

Mr. Valladares may have knowledge concerning matters at issue, including

Plaintiff’s activities during 1996 – 2002.

72. Maritza Vazquez

Address unknown at this time
Telephone number unknown at this time

Ms. Vazquez may have knowledge concerning Plaintiff’s false claims against
Defendant.

73. Vicky Ward

Address unknown at this time
Telephone number unknown at this time

Ms. Ward may have knowledge concerning Plaintiff’s false claims against
Defendant.

74. Jarred Weisfeld

Address unknown at this time

Mr. Weisfeld may have knowledge concerning matters at issue, including

Plaintiff’s attempted publication of false allegations concerning Defendant and
others.

75. Courtney Wild

Pinellas County Jail

Ms. Wild may have knowledge concerning Plaintiff’s false claims against
Defendant.

76. Daniel Wilson

Address unknown at this time

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Telephone number unknown at this time

Mr. Wilson may have knowledge concerning matters at issue, including Plaintiff’s
activities during 1996 – 2002.

77. Andrew Albert Christian Edwards, Duke of York

Address unknown at this time
Telephone number unknown at this time

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.

78. Witnessed identified by Plaintiff in any of the various versions of her Rule 26
disclosures.

79. Witnesses whose identities and contact information can be identified in law
enforcement reports disclosed herein.

80. 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, or endorsed by
Plaintiff.

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. 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.

2. News articles from the internet:

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).

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d. “Virginia Roberts' account of the explosive Prince Andrew 'sex slave'

drama,” Daily Mail Online (Jan. 3, 2015).

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).

i. “Harvard professor Alan Dershowitz denies charges of sex with

underage girl,” Boston Globe (Jan. 22, 2015).

j. “Virginia Roberts’s Aunt Reveals Jeffrey Epstein Girl Says I Am In

Fear for My Life,” Daily Mail Online, (Jan. 10, 2015).

k. “EXCLUSIVE: Alleged ‘sex slave’ of Jeffrey Epstein, Prince Andrew

accused two men of rape in 1998, but was found not credible,” NY
Daily News (Feb. 23, 2015).

l. “Jeffrey Epstein accuser was not a sex slave, but a money-hungry sex
kitten, her former friends say,” NY Daily News (Mar. 1, 2015).

m. “Twat Claims She Was Underage Sex Slave Bedding Prince Andrew,”
http://www.mgtowhq.com/viewtopic.php?f=2&t=6676 (Jan. 5, 2015).

n. “Exclusive: Prince Andrew at Heidi Klum’s ‘Hookers and Pimps’

party with the New York socialite accused of procuring underage girls
for his billionaire pedophile friend” Daily Mail Online (May 10,
2016).

3. Email from Ross Gow to various news organizations, Subject: “Ghislaine

Maxwell,” (Jan. 2, 2015).

4. “Lawyers Acknowledge Mistake In Filing Sexual Misconduct Charges

Against Professor Dershowitz,” Joint Statement of Brad Edwards, Paul
Cassell and Alan Dershowitz (Apr. 8, 2016).

5. Edwards and Cassell v. Dershowitz, In the Circuit Court of the Seventeenth

Judicial District In and For Broward County Florida to include:

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a. Deposition testimony of Paul G. Cassell, dated October 16, 2015 and

October 17, 2015.

6. Jane Doe #1 and #2 v. United States, U.S. District Court for the Southern
District of Florida, 08-cv-80736-KAM pleadings to include:

a. Motion for Limited Appearance, Consent to Designation and Request

to Electronically Receive Notices of Electronic Filing (July 28, 2008)
(Doc. # 16)

b. Notice of Change of Address and Firm Affiliation (Apr. 9, 2009) (Doc.

# 37)

c. Order Denying Petitioners’ Motion to Join Under Rule 21 and Motion

to Amend Under Rule 15 (Apr. 7, 2015) (Doc. #324)

d. Order Scheduling Settlement Conference Before the Magistrate Judge,

U.S. District Court (Mar. 31, 2016) (Doc. #378)

7. Epstein v. Scott Rothstein and Bradley J. Edwards, In the Circuit Court of the
Fifteenth Judicial Circuit in and for Palm Beach County, Florida, 09-ca-
040800, pleadings to include:

a. Complaint (Dec. 7, 2009).

8. Law enforcement records obtained from the Palm Beach County (Florida)
Sheriff’s Office, the Royal Palm Beach (Florida) Police Department, the
County Court in and for Palm Beach County (Florida), the Greenacres
(Florida) Department of Public Safety, and the Fremont County (Colorado)
Sheriff’s Office.

9. Employment records obtained from ET Employment Training and Recruiting

Australia.

10. Education records obtained from Royal Palm Beach Community High School
and Forest Hills High School.

11. Documents received from Palm Beach County Library System.

12. 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.

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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 as necessary.

IV. INSURANCE AGREEMENT UNDER WHICH ANY PERSON CARRYING

ON AN INSURANCE BUSINESS MAY BE LIABLE TO SATISFY A PART
OR ALL OF A JUDGMENT

Ms. Maxwell’s AIG Homeowners and Excess Liability insurance policies.

Coverage has been denied by AIG, as their letter of April 18, 2016 to Ms.
Maxwell, copied to Ms. McCawley, attests.

Dated: June 17, 2016.

Respectfully submitted,

s/ Laura A. Menninger
Laura A. Menninger
Jeffrey S. Pagliuca
HADDON, MORGAN AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
[email protected]
[email protected]

Attorneys for Ghislaine Maxwell

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CERTIFICATE OF SERVICE

I certify that on June 17, 2016, I electronically served this DEFENDANT GHISLAINE
MAXWELL’S THIRD SUPPLEMENTAL F.R.C.P. 26(A)(1) DISCLOSURES via e-mail on the
following:

Sigrid S. McCawley Paul G. Cassell

Meredith Schultz 383 S. University Street
BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112
401 East Las Olas Boulevard, Ste. 1200 [email protected]
Ft. Lauderdale, FL 33301
[email protected]
[email protected]
J. Stanley Pottinger
Bradley J. Edwards 49 Twin Lakes Rd.
FARMER, JAFFE, WEISSING, EDWARDS, South Salem, NY 10590
FISTOS & LEHRMAN, P.L. [email protected]
425 North Andrews Ave., Ste. 2
Ft. Lauderdale, FL 33301
[email protected]
s/

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