gov.uscourts.nysd.447706.1198.6_2.pdf

Case 1:15-cv-07433-LAP Document 1198-6 Filed 01/27/21 Page 1 of 4 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ______________________________/ DECLARATION OF SIGRID S. MCCAWLEY IN PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION FOR DEFENDANT’S RULE 37(b) &(c) SANCTIONS FOR FAILURE TO COMPLY WITH COURT ORDER AND FAILURE TO COMPLY WITH RUILE 26(a) I, Sigrid S. McCawley, declare that the below is true and correct to the best of my knowledge as follows: 1. I am a Partner with the law firm of Boies, Schiller & Flexner LLP and duly licensed to practice in Florida and before this Court pursuant to this Court’s Order granting my Application to Appear Pro Hac Vice. 2. I respectfully submit this Declaration in response to Defendant’s Motion for Defendant’s Rule 37(b) &(c) Sanctions for Failure to Comply with Court Order and Failure to Comply with Rule 26(a). 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Excerpts from the May 18, 2016 Deposition of . 4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of Excerpts from the  Case 1:15-cv-07433-LAP Document 1198-6 Filed 01/27/21 Page 2 of 4 June 10, 2016 Deposition of . 5. Attached hereto as Sealed Exhibit 3 is a true and correct copy of Excerpts from the June 20, 2016 Deposition of 6. Attached hereto as Sealed Exhibit 4 is a true and correct copy of Excerpts from the June 21, 2016 Deposition of Joseph Recarey. 7. Attached hereto as Sealed Composite Exhibit 5 is a true and correct copy of E-mail Correspondences to Laura Menninger. 8. Attached hereto as Sealed Composite Exhibit 6 is a true and correct copy of Medical Release Letter to Providers. 9. Attached hereto as Sealed Composite Exhibit 7 is a true and correct copy of April 29, 2016 Signed Medical Releases to Opposing Counsel. 10. Attached hereto as Sealed Exhibit 8 is a true and correct copy of Judith Lightfoot’s Redacted Medical Release (Giuffre005431-005438). 11. Attached hereto as Sealed Exhibit 9, is a true and correct copy of Excerpts from the June 24, 2016 Deposition of . 12. Attached hereto as Sealed Exhibit 10 is a true and correct copy of Excerpt from the May 26, 2016 Confidential Deposition of Dr. Steven Olson. I declare under penalty of perjury that the foregoing is true and correct. /s/ Sigrid McCawley Sigrid McCawley 2  Case 1:15-cv-07433-LAP Document 1198-6 Filed 01/27/21 Page 3 of 4 Dated: June 28, 2016 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies, Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 Tel: (954) 356-0011 Email: [email protected] David Boies Boies, Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Paul G. Cassell (Pro Hac Vice) Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112-0730 (801) 585-5202 (phone) (801) 585-2750 (fax) Email: [email protected] Bradley Edwards (Pro Hac Vice) Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 Fax: (954) 524-2822 Email: [email protected] 3  Case 1:15-cv-07433-LAP Document 1198-6 Filed 01/27/21 Page 4 of 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 28, 2016, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Paliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: [email protected] /s/ Sigrid S. McCawley Sigrid S. McCawley, Esq. 4