gov.uscourts.nysd.447706.1198.14.pdf

Case 1:15-cv-07433-LAP Document 1198-14 Filed 01/27/21 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X .......................................... VIRGINIA L. GIUFFRE, Plaintiff, v. 15-cv-07433-RWS ...... GHISLAINE MAXWELL, Defendant. --------------------------------------------------X Declaration Of Laura A. Menninger In Support Of Reply to Plaintiff’s Opposition to Defendant’s Motion for Rule 37(b) Sanctions I, Laura A. Menninger, declare as follows: 1. I am an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in support of Reply to Plaintiff’s Opposition to Defendant’s Motion for Rule 37(b) Sanctions. 2. Attached as Exhibit O (filed under seal) are true and correct copies of medical records bates labeled GIUFFRE 6631-6635, designated as Confidential under the Protective Order. 3. Attached as Exhibit P (filed under seal) are true and correct copies of excerpts from the deposition of Plaintiff Virginia Giuffre, designated as Confidential under the Protective Order.  Case 1:15-cv-07433-LAP Document 1198-14 Filed 01/27/21 Page 2 of 3 4. Attached as Exhibit Q (filed under seal) is a true and correct copy of a subpoena served on Dr. Steven Olson on April 6, 2016. 5. Attached as Exhibit R (filed under seal) is a chart reflecting Plaintiff’s counsel’s statements concerning their production of health care providers’ identities and records. 6. Attached as Exhibit S is a true and correct copy of letters from Meredith Schultz to Laura Menninger dated May 25, 2016 and June 1, 2016, producing documents by Plaintiff bates labeled GIUFFRE 005439- 005606. 7. Attached as Exhibit T (filed under seal) is a true and correct copy of GIUFFRE 006636 produced on June 28, 2016 by Plaintiff and designated as Confidential under the Protective Order. Dated: July 8, 2016 By: /s/ Laura A. Menninger Laura A. Menninger 2  Case 1:15-cv-07433-LAP Document 1198-14 Filed 01/27/21 Page 3 of 3 CERTIFICATE OF SERVICE I certify that on July 8, 2016, I electronically served this Declaration Of Laura A. Menninger In Support Of Reply to Plaintiff’s Opposition to Defendant’s Motion for Rule 37(b) Sanctions via ECF 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/ Nicole Simmons Nicole Simmons 3