gov.uscourts.nysd.447706.1328.36.pdf

Case 1:15-cv-07433-LAP Document 1328-36 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 For Leave to File A Sur-Reply Or, Alternatively, to Strike Plaintiff’s Misrepresentations of Fact to the Court 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 for Leave to File A Sur-Reply Or, Alternatively, to Strike Plaintiff’s Misrepresentations of Fact to the Court. 2. Attached as Exhibit A (filed under seal) are true and correct copies of excerpts from the July 22, 2016 deposition of Ghislaine Maxwell, designated as Confidential under the Protective Order.  Case 1:15-cv-07433-LAP Document 1328-36 Filed 01/05/24 Page 2 of 3 3. Attached as Exhibit B (filed under seal) are true and correct copies of excerpts from the April 22, 2016 deposition of Ghislaine Maxwell, designated as Confidential under the Protective Order. 4. Attached as Exhibit C (filed under seal) are true and correct copies of excerpts from the deposition of Detective Joseph Recarey designated as Confidential under the Protective - Order. 5. Attached as Exhibit D (filed under seal) are true and correct copies of excerpts from the deposition of Johanna Sjoberg, designated as Confidential under the Protective Order. 6. Attached as Exhibit E (filed under seal) are true and correct copies of excerpts from the deposition of Juan Alessi, designated as Confidential under the Protective Order. 7. Attached as Exhibit F (filed under seal) are true and correct copies of excerpts from the deposition of Tony Figueroa, designated as Confidential under the Protective Order. Executed on August 25, 2016 By: /s/ Laura A. Menninger Laura A. Menninger 2  Case 1:15-cv-07433-LAP Document 1328-36 Filed 01/05/24 Page 3 of 3 CERTIFICATE OF SERVICE I certify that on August 25, 2016, I electronically served this Declaration Of Laura A. Menninger In Support Of Defendant’s Motion for Leave to File A Sur-Reply Or, Alternatively, to Strike Plaintiff’s Misrepresentations of Fact to the Court 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