gov.uscourts.nysd.447706.1295.12.pdf

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 to Compel Non-Party Witness to Produce Documents, Respond to Depositions Questions, and Response to Motion for Protective Order 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 to Compel Non-Party Witness to Produce Documents, Respond to Deposition Questions, and Response to Motion for Protective Order. 2. Attached as Exhibit A (filed under seal) are true and correct copies of excerpts from the deposition of Sarah Ransome on February 17, 2017, designated Confidential under the Protective Order.  3. Attached as Exhibit B (filed under seal) is a true and correct copy of Exhibit 11 from the deposition of Sarah Ransome on February 17, 2017, designated Confidential under the Protective Order. 4. Attached as as Exhibit C (filed under seal) is a true and correct copy of the engagement letter between Ms. Ransome and Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L., J. Stanley Pottinger PLLC, and Paul Cassell, Esq., dated November 7, 201, Bates stamped Ransome_000016. 5. Attached as Exhibit D (filed under seal) is a true and correct copy of Exhibit 5 from the deposition of Sarah Ransome on February 17, 2017, designated Confidential under the Protective Order. 6. Attached as Exhibit E (filed under seal) is a true and correct copy of Non-Party Sarah Ransome’s Response and Objections to Defendant’s Subpoena Request, dated February 13, 2017. 7. Attached as Exhibit F (filed under seal) is a true and correct copy of Exhibit 3 from the deposition of Sarah Ransome on February 17, 2017, designated Confidential under the Protective Order. 8. Attached as Exhibit G (filed under seal) is a true and correct copy of Exhibit 9 from the deposition of Sarah Ransome on February 17, 2017, designated Confidential under the Protective Order. 9. Attached as Exhibit H (filed under seal) is a true and correct copy of Exhibit 10 from the deposition of Sarah Ransome on February 17, 2017, designated Confidential under the Protective Order. 2  10. Attached as Exhibit I (filed under seal) is a true and correct copy of Exhibit 8 from the deposition of Sarah Ransome on February 17, 2017, designated Confidential under the Protective Order. I declare under penalty of perjury that the foregoing is true and correct. Executed on March 2, 2017. s/ Laura A. Menninger Laura A. Menninger 3  CERTIFICATE OF SERVICE I certify that on March 2, 2017, I electronically served this Declaration of Laura A. Menninger in Support of Defendant’s Motion to Compel Non-Party Witness to Produce Documents, Respond to Deposition Questions, and Response to Motion for Protective Order 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 4