gov.uscourts.nysd.447706.55.0.pdf
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 SUPPORT OF PLAINTIFF VIRGINIA
GIUFFRE’S REPLY IN RESPONSE TO DEFENDANT’S SUPPLEMENTAL RESPONSE
TO MOTION TO COMPEL PRODUCTION OF DOCUMENTS SUBJECT TO
IMPROPER OBJECTIONS
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 September 29, 2015
Order granting my Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in support of Plaintiff Virginia Giuffre’s
Reply In Response to Defendant’s Supplemental Response to Motion To Compel Production of
Documents Subject To Improper Objections [D.E. 45].
3. Attached hereto as Exhibit 1, is a true and correct copy of the Palm Beach Police
Department’s Report.
4. Attached hereto as Exhibit 2, is a true and correct copy of the Flight Logs from
Jeffrey Epstein’s private plane.
5. Attached hereto as Exhibit 3, is a true and correct copy of the Message Pads from
Law Enforcement’s trash pulls from Jeffrey Epstein’s Palm Beach mansion.
6. Attached hereto as Exhibit 4, is a true and correct copy of the 2009 Notice of
Deposition of Ghislaine Maxwell, Subpoena and Cancellation Payment Notice, and January 13,
2015 Daily Mail Article.
7. Attached hereto as Exhibit 5, is a true and correct copy of Excerpts from the
January 12, 2016 Deposition Transcript of Alan Dershowitz.
8. Attached hereto as Exhibit 6, is a true and correct copy of Defendant Ghislaine
Maxwell’s Privilege Log.
9. Attached hereto as Exhibit 7, is a true and correct copy of the Deposition
Transcripts of Juan Alessi.
10. Attached hereto as Exhibit 8, is a true and correct copy of the February 2, 2015
Page Six Article.
11. Attached hereto as Exhibit 9, is a true and correct copy of the September 23, 2007
Red Ice Creations Article.
12. Attached hereto as Exhibit 10, is a true and correct copy of the April 13, 2010
Deposition Transcript of Nadia Marcinkova.
13. Attached hereto as Exhibit 11, is a true and correct copy of the March 24, 2010
Deposition Transcript of Sarah Kellen.
14. Attached hereto as Exhibit 12, is a true and correct copy of a photograph taken by
Ms. Giuffre of Defendant Ghislaine Maxwell, Emmy Taylor, and Jeffrey Epstein while they
were all in Europe.
2
15. Attached hereto as Exhibit 13, is a true and correct copy of the Deposition
Transcripts of Alfredo Rodriguez.
I declare under penalty of perjury that the foregoing is true and correct.
/s/ Sigrid S. McCawley______
Sigrid S. McCawley, Esq.
3
Dated: March 14, 2016
Respectfully Submitted,
BOIES, SCHILLER & FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid McCawley (Pro Hac Vice)
Boies, Schiller & Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale, FL 33301
(954) 356-0011
David Boies
Boies, Schiller & Flexner LLP
333 Main Street
Armonk, NY 10504
Ellen Brockman
Boies, Schiller & Flexner LLP
575 Lexington Ave
New York, New York 10022
(212) 446-2300
4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on March 14, 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 this day on the individuals identified below via transmission of Notices
of Electronic Filing generated by CM/ECF.
Laura A. Menninger, Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Tel: (303) 831-7364
Fax: (303) 832-2628
Email: lmenninger@hmflaw.com
/s/ Sigrid S. McCawley
Sigrid S. McCawley
5
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 SUPPORT OF PLAINTIFF VIRGINIA
GIUFFRE’S REPLY IN RESPONSE TO DEFENDANT’S SUPPLEMENTAL RESPONSE
TO MOTION TO COMPEL PRODUCTION OF DOCUMENTS SUBJECT TO
IMPROPER OBJECTIONS
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 September 29, 2015
Order granting my Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in support of Plaintiff Virginia Giuffre’s
Reply In Response to Defendant’s Supplemental Response to Motion To Compel Production of
Documents Subject To Improper Objections [D.E. 45].
3. Attached hereto as Exhibit 1, is a true and correct copy of the Palm Beach Police
Department’s Report.
4. Attached hereto as Exhibit 2, is a true and correct copy of the Flight Logs from
Jeffrey Epstein’s private plane.
5. Attached hereto as Exhibit 3, is a true and correct copy of the Message Pads from
Law Enforcement’s trash pulls from Jeffrey Epstein’s Palm Beach mansion.
6. Attached hereto as Exhibit 4, is a true and correct copy of the 2009 Notice of
Deposition of Ghislaine Maxwell, Subpoena and Cancellation Payment Notice, and January 13,
2015 Daily Mail Article.
7. Attached hereto as Exhibit 5, is a true and correct copy of Excerpts from the
January 12, 2016 Deposition Transcript of Alan Dershowitz.
8. Attached hereto as Exhibit 6, is a true and correct copy of Defendant Ghislaine
Maxwell’s Privilege Log.
9. Attached hereto as Exhibit 7, is a true and correct copy of the Deposition
Transcripts of Juan Alessi.
10. Attached hereto as Exhibit 8, is a true and correct copy of the February 2, 2015
Page Six Article.
11. Attached hereto as Exhibit 9, is a true and correct copy of the September 23, 2007
Red Ice Creations Article.
12. Attached hereto as Exhibit 10, is a true and correct copy of the April 13, 2010
Deposition Transcript of Nadia Marcinkova.
13. Attached hereto as Exhibit 11, is a true and correct copy of the March 24, 2010
Deposition Transcript of Sarah Kellen.
14. Attached hereto as Exhibit 12, is a true and correct copy of a photograph taken by
Ms. Giuffre of Defendant Ghislaine Maxwell, Emmy Taylor, and Jeffrey Epstein while they
were all in Europe.
2
15. Attached hereto as Exhibit 13, is a true and correct copy of the Deposition
Transcripts of Alfredo Rodriguez.
I declare under penalty of perjury that the foregoing is true and correct.
/s/ Sigrid S. McCawley______
Sigrid S. McCawley, Esq.
3
Dated: March 14, 2016
Respectfully Submitted,
BOIES, SCHILLER & FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid McCawley (Pro Hac Vice)
Boies, Schiller & Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale, FL 33301
(954) 356-0011
David Boies
Boies, Schiller & Flexner LLP
333 Main Street
Armonk, NY 10504
Ellen Brockman
Boies, Schiller & Flexner LLP
575 Lexington Ave
New York, New York 10022
(212) 446-2300
4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on March 14, 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 this day on the individuals identified below via transmission of Notices
of Electronic Filing generated by CM/ECF.
Laura A. Menninger, Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Tel: (303) 831-7364
Fax: (303) 832-2628
Email: lmenninger@hmflaw.com
/s/ Sigrid S. McCawley
Sigrid S. McCawley
5