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Case 1:15-cv-07433-LAP Document 1320-40 Filed 01/03/24 Page 18 of 19 Defendant reserves the right to identify additional documents, data, compilations and tangible things as discovery continues and to supplement this list accordingly. Il. 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 10" Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 Imenninger@hmflaw.com jpagliuca@hmflaw.com Attorneys for Ghislaine Maxwell 17