gov.uscourts.nysd.447706.605.0.pdf

Case 1:15-cv-07433-LAP Document 605 Filed 02/09/17 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ----------------------------------------------------------x VIRGINIA L. GUIFFRE, : : Plaintiff, : : Case No.: 15-cv-7433 (RWS) -against- : : GHISLAINE MAXWELL, : : Defendant. : : ----------------------------------------------------------x DECLARATION OF JAY M. WOLMAN IN SUPPORT OF REPLY TO PLAINTIFF’S OPPOSITION TO MOTION TO INTERVENE AND UNSEAL I, Jay M. Wolman, declare: 1. I am over the age of 18 years and am fully competent to make this Declaration. The facts set forth herein are within my personal knowledge and are true and correct. 2. I am an attorney duly licensed in the State of New York and admitted to practice before this Court. I am counsel of record for proposed intervenor Michael Cernovich in this matter, and I respectfully submit this Declaration in support the Reply to Plaintiff’s Opposition to Motion to Intervene and Unseal, filed herewith. 3. Attached hereto as Exhibit 1 is a true and correct copy the article: Gould, Martin, “EXCLUSIVE: Pedophile Jeffrey Epstein is accused of luring an underage girl into his elaborate sex trafficking enterprise under the guise of using his wealth and connections to get her into a prestige NYC college”, Daily Mail (Jan. 27, 2017), available at <http://www.dailymail.co.uk/news/article-4164082/Pedophile-Jeffrey-Epstein-accused-new-sex- traffick-case.html> 4. Attached hereto as Exhibit 2 is a true and correct copy of the article: “High-profile cases: Crimes that shook Palm Beach through the decades”, Palm Beach Daily News (Feb. 2, 2017), available at <http://www.palmbeachdailynews.com/news/local/high-profile-cases-crimes- that-shook-palm-beach-through-the-decades/9B1wc5GHCMqHHUOeFotwBI/>. 1  Case 1:15-cv-07433-LAP Document 605 Filed 02/09/17 Page 2 of 2 5. Attached hereto as Exhibit 3 is the cast list of the movie Silenced: Our War on Free Speech (Danger & Play Prods. 2016), as found at the URL: <http://www.silencedmovie.com/category/cast-crew/>. I declare under penalty of perjury that the foregoing is true and correct. Executed on February 9, 2017. /s/ Jay M. Wolman Jay M. Wolman CASE NO. 15-cv-7433 (RWS) CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 9th day of February 2017, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that a true and correct copy of the foregoing document is being served via transmission of Notices of Electronic Filing generated by CM/ECF. Respectfully submitted, /s/ Jay M. Wolman Jay M. Wolman 2