UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK po | CASE NO. 17 Civ 616 (JGK) Plaintiff, Vs. JEFFREY EPSTEIN. GHISLAINE Defendants. INITIAL RULE 26(a)(1)(A) DISCLOSURE STATEMENT Defendan fila by and through her attorneys, Steptoe & Johnson LLP, hereby submits her Initial Disclosures pursuant to Rule 26(a)(1)(A) of the Federal Rules of Civil Procedure based upon information currently known or available. PRELIMINARY STATEMENT | the protections of the self-incrimination clause of the Fifth Amendment to the United States Constitution (the “Fifth Amendment”). It is | express intent in this Disclosure Statement to claim the fullest possible protection of the United States Constitution. i... not intend by any of her disclosures to waive such protection and requests that, in cases of any doubt or ambiguity, her disclosures be construed as an assertion rather than a waiver of such privilege. J aiso reserves her right to amend her disclosures without compromising her rights under the Fifth Amendment. In addition, the production of any documents referred to in this Disclosure Statement shall not be construed to waive: (i) the attorney-client privilege and/or the work-product doctrine, either generally or as they may attach to particular documents; or (ii) the admissibility of the EFTA00310344

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documents in this case. This Disclosure Statement shall not in any way constitute a waiver of | BM eserves her right to supplement and amend these Initial Disclosures as discovery proceeds and additional information becomes known or discoverable without compromising any of the aforementioned rights, privileges, protections, or the admissibility of any documents. Disclosures I. Rule 26(a)(1)(A)(i) Disclosures Bi esse: her right under the Fifth Amendment to decline to make this disclosure. II. Rule 26(a)(1)(A)(ii) Disclosures BB asserss her right under the Fifth Amendment to decline to make this disclosure. Ill. Rule 26(a)(1)(A)(iii) Disclosures ae: not currently claim any damages in connection with this action. IV. Rule 26(a)(1)(A)(iv) Disclosures Subject to and without compromising any of the above-referenced rights, privileges, protections, and/or the admissibility of any documents nas no insurance agreements under which an insurance business may be liable to satisfy all of part of a possible judgment or to indemnify or to reimburse for payments made to satisfy the judgment. EFTA00310345

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Dated: August 28, 2018 New York, New York STEPTOE & JOHNSON LLP By: — /s/ Michael C. Miller Michael C. Miller Attorneys for Defendants Jeffrey Epstein, || EFTA00310346

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CERTIFICATE OF SERVICE I hereby certify that, on August 28, 2018, I served the foregoing document via e-mail on the counsel of record for all parties appearing in this matter. /s/ Justin Y.K. Chu EFTA00310347