gov.uscourts.nysd.447706.385.0.pdf

Case 1:15-cv-07433-LAP Document 385 Filed 08/19/16 Page 1 of 2 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 I, , declare as follows: 1. I am an attorney at law duly licensed in the District of Columbia. 2. I am familiar generally with the subject matter of this action, No. 15-cv-07433-RWS (S.D.N.Y.). 3. From 2015 to the present time I have been representing . Although Ms. Giuffre is not a , central to that action are her allegations that she was the victim of “sexual trafficking.” 4. Based on my knowledge of the action and this action, I and Defendant Ghislaine Maxwell have a , namely, of defending against allegations by and on behalf of Ms. Giuffre regarding alleged abuse. 5. During the course of my representation , I have on various occasions exchanged information via email with Ms. Maxwell’s counsel Laura Menninger. These emails are attorney work product because the information we exchanged implicates my or  Case 1:15-cv-07433-LAP Document 385 Filed 08/19/16 Page 2 of 2 Ms. Menninger’s or both of our mental impressions, conclusions, opinions and/or theories concerning the defense of Ms. Giuffre’s allegations and related factual and legal matters. I declare under penalty of perjury that the foregoing is true and correct. Executed on August 19, 2016. s/ CERTIFICATE OF SERVICE I certify that on August 19, 2016, I electronically served this Declaration of 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, FISTOS South Salem, NY 10590 & LEHRMAN, P.L. [email protected] 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 [email protected] /s/ Nicole Simmons Nicole Simmons 2