gov.uscourts.nysd.447706.122.0.pdf
Case 1:15-cv-07433-RWS Document 122 Filed 04/25/16 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.
______________________________/
REDACTED DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF
PLAINTIFF VIRGINIA GIUFFRE’S REPLY IN SUPPORT OF MOTION FOR
FORENSIC EXAMINATION
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 Support of Motion For Forensic Examination.
3. Attached hereto as Exhibit 1, is a true and correct copy of Letter dated April 11,
2016 from Laura Menninger, Counsel for Defendant.
4. Attached hereto as Exhibit 2, is a true and correct copy of Message Pads
messages.
Case 1:15-cv-07433-RWS Document 122 Filed 04/25/16 Page 2 of 4
5. Attached hereto as Exhibit 3, is a true and correct copy of Defendant Ghislaine
Maxwell’s Responses and Objections to Plaintiff’s First Request For Production of Documents.
6. Attached hereto as Exhibit 4, is a true and correct copy of
7. Attached hereto as Exhibit 5, is a true and correct copy of correspondence dated
April 7, 1026 from Sigrid McCawley, Counsel for Plaintiff.
8. Attached hereto as Exhibit 6, is a true and correct copy of correspondence dated
March 10, 2016 from Sigrid McCawley, Counsel for Plaintiff.
9. Attached hereto as Exhibit 7, is a true and correct copy of an excerpt from the
Deposition of Ghislaine Maxwell taken April 22, 2016.
10. Attached hereto as Exhibit 8, is a true and correct copy of an excerpt from the
Deposition of Ghislaine Maxwell taken April 22, 2016.
I declare under penalty of perjury that the foregoing is true and correct.
/s/ Sigrid S. McCawley ____
Sigrid S. McCawley, Esq.
Case 1:15-cv-07433-RWS Document 122 Filed 04/25/16 Page 3 of 4
Dated: April 25, 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
Case 1:15-cv-07433-RWS Document 122 Filed 04/25/16 Page 4 of 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on April 25, 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.
Jeffrey Paliuca, 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, Esq.
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
______________________________/
REDACTED DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF
PLAINTIFF VIRGINIA GIUFFRE’S REPLY IN SUPPORT OF MOTION FOR
FORENSIC EXAMINATION
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 Support of Motion For Forensic Examination.
3. Attached hereto as Exhibit 1, is a true and correct copy of Letter dated April 11,
2016 from Laura Menninger, Counsel for Defendant.
4. Attached hereto as Exhibit 2, is a true and correct copy of Message Pads
messages.
Case 1:15-cv-07433-RWS Document 122 Filed 04/25/16 Page 2 of 4
5. Attached hereto as Exhibit 3, is a true and correct copy of Defendant Ghislaine
Maxwell’s Responses and Objections to Plaintiff’s First Request For Production of Documents.
6. Attached hereto as Exhibit 4, is a true and correct copy of
7. Attached hereto as Exhibit 5, is a true and correct copy of correspondence dated
April 7, 1026 from Sigrid McCawley, Counsel for Plaintiff.
8. Attached hereto as Exhibit 6, is a true and correct copy of correspondence dated
March 10, 2016 from Sigrid McCawley, Counsel for Plaintiff.
9. Attached hereto as Exhibit 7, is a true and correct copy of an excerpt from the
Deposition of Ghislaine Maxwell taken April 22, 2016.
10. Attached hereto as Exhibit 8, is a true and correct copy of an excerpt from the
Deposition of Ghislaine Maxwell taken April 22, 2016.
I declare under penalty of perjury that the foregoing is true and correct.
/s/ Sigrid S. McCawley ____
Sigrid S. McCawley, Esq.
Case 1:15-cv-07433-RWS Document 122 Filed 04/25/16 Page 3 of 4
Dated: April 25, 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
Case 1:15-cv-07433-RWS Document 122 Filed 04/25/16 Page 4 of 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on April 25, 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.
Jeffrey Paliuca, 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, Esq.