Giuffre_Maxwell_Batch1_p00939.png

Case 1:15-cv-07433-LAP Document 1320-40 Filed 01/03/24 Page 15 of 19 IL. 77. 78. 79. 80. Telephone number unknown at this time Mr. Wilson may have knowledge concerning matters at issue, including Plaintiff's activities during 1996 — 2002. Andrew Albert Christian Edwards, Duke of York Address unknown at this time Telephone number unknown at this time The Duke has knowledge concerning Plaintiffs false statements to the press, in court pleadings, and in sworn testimony as well as the events of 1999-2002. Witnessed identified by Plaintiff in any of the various versions of her Rule 26 disclosures. Witnesses whose identities and contact information can be identified in law enforcement reports disclosed herein. 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. 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). 14