gov.uscourts.nysd.447706.381.0.pdf

Case 1:15-cv-07433-LAP Document 381 Filed 08/18/16 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 Response In Opposition To Motion For Protective Order And Motion For the Court toDirect Defendant to Disclose All Individuals to Whom Defendant Has Disseminated Confidential Information 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 (“Maxwell”) in this action. I respectfully submit this declaration in support of Defendant’s Reponse in Opposition to Motion for Protective Order and Motion for the Court to Direct Defendant to Disclose All Individuals Whom Defendant has Disseminated Confidential Information. 2. Attached as Exhibit A is a true and correct copy of records from , designated as Confidential by Plaintiff in this case. Such Confidential designation has been challenged by the defense. 3. Attached as Exhibit B is a true and correct copy of records from , designated as Confidential by Plaintiff in this case. Such Confidential designation has been challenged by the defense.  Case 1:15-cv-07433-LAP Document 381 Filed 08/18/16 Page 2 of 3 4. Attached as Exhibit C is a true and correct copy of records from , designated as Confidential by Plaintiff in this case. Such Confidential designation has been challenged by the defense. 5. Attached as Exhibit D is a true and correct copy of records from , designated as Confidential by Plaintiff in this case. Such Confidential designation has been challenged by the defense. 6. Attached as Exhibit E is a true and correct copy of records from , designated as Confidential by Plaintiff in this case. Such Confidential designation has been challenged by the defense. 7. Attached as Exhibit F is a true and correct copy of records from , designated as Confidential by Plaintiff in this case. Such Confidential designation has been challenged by the defense. 8. Attached as Exhibit G is a true and correct copy of records from , designated as Confidential by Plaintiff in this case. Such Confidential designation has been challenged by the defense. Dated: August 18, 2016 By: /s/ Laura A. Menninger Laura A. Menninger 2  Case 1:15-cv-07433-LAP Document 381 Filed 08/18/16 Page 3 of 3 CERTIFICATE OF SERVICE I certify that on August 18, 2016, I electronically served this Declaration Of Laura A. MenningerIn Support Of Defendant’s Defendant’s Reponse in Opposition to Motion for Protective Order and Motion for the Court to Direct Defendant to Disclose All Individuals Whom Defendant has Disseminated Confidential Information. 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 3