Yes. There were several models who used the name"Penny" in the 1970s, and this girl
does look a lot like Penny Ellington, but she is not. There are several photos that took
some careful examination. This one below, for example, is Penny Ellington for sure, but
looks a lot like the other Penny:
BTW, Ishy137, you mentioned that it looked as though most of the pictures were taken in the same flat. You have, of course, noticed the stately apartment of that famed fat photographic force of yesteryear, the late John Kirk. Among the young ladies who bared their boobs for us in his apartment were: Roberta Pedon, Marilyn Davies, Nannette Shelton, Darlene English, and several others. However, John was not a meticulous housekeeper.