gov.uscourts.nysd.447706.165.0.pdf

Case 1:15-cv-07433-LAP Document 165 Filed 05/26/16 Page 1 of 4 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 Motion To Compel All Attorney-Client Communications and Attorney Work Product Placed At Issue by Plaintiff and Her Attorneys 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 Ms. Maxwell’s Motions to Compel All Attorney-Client Communications and Attornty Work Product Placed At Issue by Plaintiff and Her Attorney. 2. Attached as Exhibit A is a true and correct copy of excerpts categorically logged entries from Plaintiff Giuffre's Revised Supplemental Privilege Log dated April 29, 2016. 3. Attached as Exhibit B is a true and correct copy of Plaintiff Giuffre’s Discovery Second Amended Supplemental Response to Interrogatory No. 3 concerning her attorney representations, dated April 29, 2016.  Case 1:15-cv-07433-LAP Document 165 Filed 05/26/16 Page 2 of 4 4. Attached as Exhibit C (filed under seal) 5. Attached as Exhibit D is a true and correct copy of the Order in the CVRA Case dated April 6, 2015. 6. Attached as Exhibit E is a true and correct copy of the Motion for Summary Judgment in the Edwards and Cassell v. Dershowitz, Case No. 15-00072, In and for the Seventeenth Judicial District, Broward County, Florida (“Dershowitz Case”) dated November 25, 2015. 7. Attached as Exhibit F is a true and correct copy of the Complaint in the Dershowitz Case dated January 6, 2015. 8. Attached as Exhibit G is a true and correct copy of the Notice of Serving Answers to Interrogatories in Dershowitz Case dated March 13, 2015. 9. Attached as Exhibit H (filed under seal) 10. Attached as Exhibit I is a true and correct copy of the Declaration of Virginia Giuffre in the Dershowitz Case dated November 20, 2015. 11. Attached as Exhibit J (filed under seal) 2  Case 1:15-cv-07433-LAP Document 165 Filed 05/26/16 Page 3 of 4 12. Attached as Exhibit K (filed under seal) 13. Attached as Exhibit L is a true and correct copy of the October 16, 2015 Deposition of Paul G. Cassell taken in the Edwards and Cassell v. Dershowitz, In and for the Seventeenth Judicial District, Broward County, Florida matter. 14. Attached as Exhibit M is a true and correct copy of the press release issued by the parties in the Dershowitz Case on April 8, 2016. 15. Attached as Exhibit N is a true and correct copy of the interview of Virginia Roberts by Edwards and Scarola in the Epstein v. Rothstein, Edwards, and L.M, In and for the Fifteenth Judicial District, Palm Beach County, Florida (“Epstein Case”). 16. Attached as Exhibit O is a true and correct copy of the May 17, 2011 Notice of Filing of the interview in the Epstein Case. 17. Attached as Exhibit P is a true and correct copy of a portion of the ECF Docket Sheet in the CVRA Case. 18. Attached as Exhibit Q is a true and correct copy of the document produced by Plaintiff in this matter as GIUFFRE000862-000887. By: /s/ Laura A. Menninger Laura A. Menninger 3  Case 1:15-cv-07433-LAP Document 165 Filed 05/26/16 Page 4 of 4 CERTIFICATE OF SERVICE I certify that on May 26, 2016, I electronically served this Declaration Of Laura A. Menninger In Support Of Motion To Compel All Attorney-Client Communications and Attornty Work Product Placed At Issue by Plaintiff and her Attorney via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meridith Schultz S.J. Quinney College of Law, University of BOIES, SCHILLER & FLEXNER, LLP Utah 401 East Las Olas Boulevard, Ste. 1200 383 S. University Street Ft. Lauderdale, FL 33301 Salt Lake City, UT 84112 [email protected] [email protected] [email protected] Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 [email protected] /s/ Nicole Simmons Nicole Simmons 4