gov.uscourts.nysd.447706.1331.8.pdf

Case 1:15-cv-07433-LAP Document 1331-8 Filed 01/05/24 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 Defendant’s Motion In Limine To Exclude In Toto Certain Depositions Designated By Plaintiff For Use At Trial 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 in this action. I respectfully submit this Declaration in support of Ms. Maxwell’s Motion in Limine to Exclude In Toto Certain Depositions Designated by Plaintiff for Use at Trial. 2. Attached as Exhibit A (filed under seal) are true and correct copies of excerpts from the deposition of Ronald Rizzo on June 10, 2016, designated Confidential under the Protective - Order.  Case 1:15-cv-07433-LAP Document 1331-8 Filed 01/05/24 Page 2 of 3 3. Attached as Exhibit B (filed under seal) are tme and con ect copies of excerpts from the deposition of Detective Joseph Recarey on June 21, 2016, designated Confidential under the Protective Order. 4. Attached as Exhibit C (filed under seal) are tme and con ect copies of excerpts from the deposition of Jeffrey Epstein on September 9, 201 6, designated Confidential under the Protective Order. 5. Attached as Exhibit D (filed under seal) are tme and con ect copies of excerpts from the deposition of on June 20, 201 6, designated Confidential under the Protective Order. 6. Attached as Exhibit E (filed under seal) are hue and con ect copies of excerpts from the continuous days of deposition of Alfredo Rodriguez on July 29 and August 7, 2009 designated Confidential under the Protective Order multiple and various cases. I declare under penalty of pe1jury that the foregoing is tme and coITect. Executed on Janua1y 27, 2017. s/ Laura A. Menninger Laura A. Menninger 2  Case 1:15-cv-07433-LAP Document 1331-8 Filed 01/05/24 Page 3 of 3 CERTIFICATE OF SERVICE I certify that on January 27, 2017, I electronically served this Declaration of Laura A. Menninger in Support of Defendant’s Motion in Limine to Exclude In Toto Certain Depositions Designated by Plaintiff for Use at Trial 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