gov.uscourts.nysd.447706.156.0.pdf

Case 1:15-cv-07433-LAP Document 156 Filed 05/20/16 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 Motion To Compel Non-Privileged Documents 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 Ms. Maxwell’s Motions to Compel Non-Privileged Documents. 2. Attached as Exhibit A is a true and correct copy of Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated April 29, 2016, served on April 29, 2016. 3. Attached as Exhibit B is a subsection of items on Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated April 29, 2016 relating to media issues and press releases.  Case 1:15-cv-07433-LAP Document 156 Filed 05/20/16 Page 2 of 3 4. Attached as Exhibit C is a subsection of items on Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated April 29, 2016 including J. Stanley Pottinger in the communications. 5. Attached as Exhibit D is a printout of the content of Stan Pottinger’s Official Website, found on the internet at http://stanpottinger.com/home/index.asp 6. Attached as Exhibit E (filed under seal) 7. Attached as Exhibit F is a subsection of items on Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated April 29, 2016 that appear to attach or include pre- existing non-privileged documents that have been withheld or are not identified. 8. Attached as Exhibit G is a subsection of items on Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated April 29, 2016 including unidentified third party “professionals” in the communications. 9. Attached as Exhibit H is a subsection of items on Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated April 29, 2016 relating to communication regarding Victims Refuse Silence. 10. Attached as Exhibit I is a true and correct copy of the Articles of Organization for Victims Refuse Silence, Inc. available through the Florida Secretary of State website at http://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2 014%5C1229%5C67499487.Tif&documentNumber=N14000011657. 2  Case 1:15-cv-07433-LAP Document 156 Filed 05/20/16 Page 3 of 3 11. Attached as Exhibit J (filed under seal) By: /s/ Laura A. Menninger Laura A. Menninger CERTIFICATE OF SERVICE I certify that on May 20, 2016, I electronically served this Declaration Of Laura A. Menninger In Support Of Motion To Compel Non-Privileged Documents via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meridith Schultz S.J. Quinney College of Law, University of BOIES, SCHILLER & FLEXNER, LLP Utah 401 East Las Olas Boulevard, Ste. 1200 383 S. University Street Ft. Lauderdale, FL 33301 Salt Lake City, UT 84112 [email protected] [email protected] [email protected] Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 [email protected] /s/ Nicole Simmons Nicole Simmons 3